The Central Electricity Regulatory Commission (CERC or the Commission) notified the draft Power Market (First Amendment) Regulations, 2025 on 17th June 2025, and invited public comments on the same.

Over the years Over the Counter (OTC) platforms have grown and reached maturity. They will likely grow further still, making accountability in the operations of OTC platforms crucial. The draft document introduces some measures towards increasing accountability of OTC operations, such as an increased minimum net worth requirement of Rs. 35 Crore. 

Given the need for furthering accountability, Prayas (Energy Group) has the following submissions:

1. The Commission should ensure that the requisite explanatory memorandum is published along with any draft regulations.
2. OTC platforms should not be allowed to offer REC contracts, capacity contracts and battery energy storage system contracts.
3. An ID system should be established such that each market participant is assigned a unique ID as an identifier across all OTC platforms and power exchanges.
4. OTC guidelines 2022 should be amended to introduce guiding standardised contracts for each contract type OTC platforms are allowed to offer.
5. OTC platforms should receive formal approval from the Commission before offering any new contract types.
6. Data reporting mandates on OTC platforms via Form IV-I of the CERC trading licensee regulations 2020 should be amended to accommodate the new type of contracts OTC platforms are allowed to offer.
7. The Commission should ensure that OTC platforms make publicly available critical data on all contract types being offered in a easily accessible and downloadable format on their website.
8. Data on OTC platform trades should be separately reported and analysed by the Commission as part of the monthly and annual market monitoring reports.