Introduction
While Pakistan’s corporate sector was grappling with the “Super Tax” verdict, another seismic shift hit the energy landscape. On February 9, 2026, the National Electric Power Regulatory Authority (NEPRA) notified the Prosumer Regulations 2026, repealing the decade old Net Metering regime.
For thousands of industrial and residential prosumers (consumers who also produce energy), this wasn’t just a policy update, it was a fundamental change to the financial viability of their green energy investments.
The Shift: From Net Metering to Net Billing
End of Unit‑to‑Unit Swapping:
Under SRO 251(I)/2026, the era of swapping electricity units 1:1 is over.
Buyback Rate Crash:
Prosumers previously sold excess energy at Rs. 25–30 per unit. Now, under Net Billing, the rate has dropped to ~Rs. 11 per unit (National Average Power Purchase Price).
- Purchase Gap: While selling at Rs. 11, consumers still buy electricity at retail tariffs exceeding Rs. 60 per unit during peak hours.
- Capacity Restrictions: New rules prohibit systems larger than sanctioned load, with applications restricted in areas where transformer capacity exceeds 80%.
The Legal Flashpoint: Vested Rights vs. Regulatory Power
Can NEPRA Override Signed Agreements?
The central legal question is whether NEPRA can unilaterally alter the terms of an existing 7‑year net‑metering license.
- Following public outcry, the Prime Minister intervened in late February 2026, leading NEPRA to issue a 30 day protection window for existing licensees. The government later clarified that existing licensees would be grandfathered into the old system until their agreements expire.
- At Robes & Gavel Legal, our position remains that licenses under the 2015 Rules create vested contractual rights that cannot be extinguished retrospectively without due compensation.
The Rise of CTBCM: A Silver Lining for Industry
What is CTBCM?
The Competitive Trading Bilateral Contract Market (CTBCM), fully activated in 2026, is a game‑changer for large industrial consumers (loads over 1MW).
Why CTBCM Matters for Businesses
- Direct Procurement: Industries can sign bilateral contracts directly with IPPs or solar parks.
- Wheeling Auctions: ISMO has launched auctions to allocate grid capacity for wheeling, enabling energy production at one site and consumption at another.
- Cost Predictability: Businesses can lock in energy prices for 5–10 years, shielding themselves from volatile fuel price adjustments (FPA).
Navigating the 2026 Energy Framework
Comparative Table: Old vs. New Regime
| Feature | Old Regime (Pre 2026) | New Regime (2026 Onwards) | Legal Status |
|---|---|---|---|
| Solar Exchange | 1:1 Unit Swap | Cash Credit at -Rs.11 | Active / Contested |
| Market Access | Single Buver (DISCO) | Multi-Seller (CTBCM) | Operational |
| Contract Length | 7 - Year Guaranateed | 5 - Year Reviewable | Regulated |
| Geld Usage | Standard Wheeling | Competitive Auctions | Developing |
Strategic Advice for Investors and Industries
For Existing Solar Users
- Audit DISCO billing immediately.
- Ensure licenses are registered under the February 16th protection amendment.
- Contest premature transitions to Net Billing.
For Large Industries
- Register under CTBCM as a Bulk Power Consumer.
- Exit the inefficient DISCO net and negotiate competitive rates directly.
Battery Storage (BESS)
- With export rates dropping, the legal way to save money is energy storage.
- Board approvals for 25MW+ battery systems have surged by 400%, ensuring Zero Export efficiency.
Final Thoughts
Energy law in Pakistan is no longer about “getting a connection.” It is about navigating NEPRA SROs, CTBCM market codes, and constitutional protections against retrospective policy shifts.
At Robes & Gavel Legal, we ensure your Right to Energy is protected with the most robust legal arguments available.
For legal assistance with CTBCM registration, wheeling agreements, or contesting Net Metering notices, contact our Energy & Infrastructure Desk at Faisal Market, F‑7/1, Islamabad.