Our group companies sit in different distribution licensee areas. What does each one report under the captive rules?
Per the Ministry of Power's explanatory note, each company claiming captive consumption reports its own consumption to its distribution licensee, with the group's combined captive entitlement and a simple declaration that its consumption is part of the group's pool. The proportionality test applies at group level only.
What the note says each company reports
- Its own electricity consumption, to the distribution licensee in whose area it sits.
- The group's consolidated captive entitlement, with the group treated as one person.
- A simple declaration that its consumption forms part of the group's captive consumption pool.
What is not tested per company
The note says the proportionality test "will apply only at the group level, not to each entity".
Where the note and the rule text sit
This procedure is in the explanatory note, not in the rule's operative text. The note does not say where the group-pool declaration is filed or by when. Rule 3(4)(c) separately refers to a declaration furnished "in accordance with the procedure issued by the nodal agency or NLDC", the National Load Despatch Centre. Ask your distribution licensee and the nodal agency which form they want.
Example using Schedule III Example 4 figures
- Assume A1 sits in one licensee's area and A2 and A3 in another's (an example, not in the source)
- A1 reports its own 30% of generation to its licensee. A2 reports 5% and A3 reports 25% to theirs.
- Each also reports the group's eligibility limit of 48.12% (the figure Schedule III prints, which we treat as the group's consolidated entitlement, my reading) and the declaration
- The test is on 30 + 5 + 25 = 60% against 48.12%, not on each company
The split is an example. Only the 48.12% figure comes from the rules, and equating it with the note's consolidated entitlement is my reading.
What Senseible does here
Senseible reads electricity bills into monthly records. It does not test captive status or work out the limits.
- Parent and subsidiaries as one captive user
- Captive plant fails the 51% test
- Group captive rules for solar
- Group captive solar and Scope 2
- Free carbon calculators
Last reviewed 2026-11-05. Rule 3 of the Electricity Rules, 2005 as substituted by G.S.R. 186(E), 13 March 2026; parts in force from 1 April 2026. Checked 5 November 2026. Check the state nodal agency's or the National Load Despatch Centre's procedure before you file.