Power sector regulatory advisory

Why regulated power costs are hard to manage

For an industrial consumer, the price and terms of supply are set and reset in proceedings, and the record shapes the result. Common problems:

• A new tariff order arrives, and no one can say quickly what it does to your bill or your open access charges.
• A distribution company files a tariff or true-up petition. The window for comments is short, and general objections carry little weight.
• A draft regulation is open for comment, but no one in the business owns the response.
• An order contains directions that apply to you, and nobody follows them up.

How electricity is regulated

The Electricity Act, 2003, as amended, is the base law. It sets up the Central Electricity Regulatory Commission (section 76), the State Electricity Regulatory Commissions (section 82) and the Appellate Tribunal for Electricity (section 110).

Commissions specify the terms and conditions for tariff in regulations (section 61) and then determine tariff (section 62). Under section 86(1), the functions of a State Commission include:

• determining tariff for generation, supply, transmission and wheeling within the State; where open access is allowed, it sets the wheeling charges and surcharge (clause (a));
• regulating the purchase and procurement process of distribution licensees (clause (b));
• facilitating intra-state transmission and wheeling of electricity (clause (c));
• promoting cogeneration and generation of electricity from renewable sources (clause (e)).

CERC's functions under section 79 include regulating the tariff of central and multi-state generating companies, regulating inter-state transmission and its tariff, and licensing inter-state transmission and trading.

In Gujarat, GERC issued the FY 2026-27 tariff orders for the State's distribution companies on 25 March 2026. Two other items are worth watching. GERC has invited proposals for a study on rationalising the retail tariff structure, and a draft National Electricity Policy, 2026 is under government consideration. Neither is a tariff decision. Both may shape later ones.

Where we help

Our electricity regulatory advisory covers the points where regulation meets your costs and your business model:

• Reading tariff orders and regulations, and explaining their effect on your bill, your open access charges or your project.
• Objections and comments on distribution licensees' tariff and true-up petitions, when the commission invites them.
• Petitions of your own, with the supporting analysis, data and documents.
• Open access and the charges under section 42 of the Act: the cross-subsidy surcharge (section 42(2)) and the additional surcharge (section 42(4)). Detailed sourcing work sits under green energy open access and captive power advisory.
• Comments on draft regulations issued by GERC, CERC and the Ministry of Power.
• Following up directions in orders that apply to you.

The value is focus: the points that matter to you, the numbers behind them, and a document ready to file or act on.

What you receive

Each engagement ends in written work you can use:

• Tariff order note: what a new order changes for your consumer category, with the cost effect worked out where your data allows.
• Petition issues list: the items in a distribution licensee's petition that affect you, ranked by effect.
• Objection draft for your review: written objections or comments, in your name or your association's.
• Petition support pack: for a petition of your own, the relief sought, the regulatory basis, data schedules and a draft for your counsel.
• Comments on a draft regulation: the clauses that matter to you and the changes you want, with reasons.
• Hearing brief: for you and your counsel.
• Order follow-up note: what changed, what it costs you, which directions apply to you, and whether a further step is worth discussing with your counsel.

Tariff orders and petitions

Tariff work starts with the record. A distribution licensee's petition sets out its claimed costs and proposed tariffs. The commission examines them and issues an order. To influence the outcome, a consumer needs to engage with that record on specific points, with numbers. Where the numbers are complex, we work with financial modelling and regulatory risk to quantify the effect. When a final order changes a tariff or a charge, a policy impact simulation can show what it means for your own plant, with base, better and worse cases.

Taking part when the commission invites comments

When the commission publishes a petition and invites comments, the public notice sets the deadline, the format and how to ask to be heard. We read the petition against your connection and consumption, pick the points with the largest effect on you, and draft an objection for your review. If you prefer to act through an industry association, we can prepare a joint submission.

How we work

1. Agree the question. For example: "Should we object to this petition, and on what points?"
2. Read the official record. We work from the petition, regulations and orders, and note whether each item is notified, a draft or under petition.
3. Quantify. We work out the effect on your costs from your bills and data.
4. Draft. You review every submission before it is filed. Filings are made in your name.
5. Follow through. We follow the proceeding to its order and tell you what changed.

We do not promise outcomes. Read more about how we work.

Who it is for

This service is for organisations whose electricity costs or business models depend on regulatory decisions. Typical uses:

• An industrial consumer with a high-tension (HT) connection checks a new tariff order before setting its budget.
• A generator or developer reviews a GERC or CERC regulation that affects its project.
• An industry association prepares a joint submission on a draft regulation.

For policy matters beyond electricity, see regulatory affairs and policy advisory.