Smart metering in India is ramping up to pursue the target of 250 million smart meters. Given the complex nature of smart meter implementation, scale of deployments, costs involved, need for data privacy, and other techno-commercial factors, it is important to have appropriate regulatory frameworks to ensure consumer interests are protected and public trust in the system is built. In this article, we analyse national and state level smart metering regulations with respect to key parameters including processes for monitoring the progress, regulatory mechanisms to check meter calibration, consumer onboarding, cost recovery, data access, privacy and security, and reporting requirements. We then arrive at a set of recommendations to strengthen smart metering regulations in the country to enable seamless transition to smart metering systems.

Introduction

In our previous article, “Smart Metering in India: A Work in Progress”, we highlighted the need for a robust regulatory framework to ensure the successful implementation of smart metering, while also building consumer confidence in the system. It also provided a brief overview of relevant regulations at the national level and in select states.

This article takes a closer look at the existing regulatory framework for smart metering and identifies some important gaps that need attention as the rollout gathers pace across the country. Metering and billing are sensitive areas for consumers, directly influencing their trust in distribution companies. In this regard, state-level regulations play a particularly important role. They provide consumers with a framework to hold discoms accountable for supply and service quality, provide information related to metering and lay down procedures for grievance redressal. Strengthening such state-level frameworks are key to ensuring that smart metering is not only installed but also accepted as fair, transparent, and reliable measure by consumers.

Hence, to build trust and ensure smooth adoption, the regulatory framework for smart metering needs to encompass various dimensions across three critical stages:

a. Pre-implementation

Regulations need to set out the mandate for rollout of smart meters, provide guidance on the approval of action plans and associated costs, adopt national level standards for meter technology and procurement, and outline procedures for consumer onboarding and awareness.

b. Implementation

This stage should be guided by regulations that cover project monitoring, data access and privacy, cybersecurity, ensuring secure payment mechanisms, protocols for disconnection and reconnection, grievance redressal, meter testing and calibration, as well as data management.

c. Post implementation

In the post-implementation stage, regulations should establish mechanisms to evaluate the performance of smart metering projects, assess the extent to which expected benefits have been realized, and conduct prudence checks on the costs incurred.

The current regulatory landscape covering these dimensions is spread across multiple instruments, including state-level regulations, technical standards, scheme guidelines, standard bidding documents, and service-level agreements. While discoms and Advanced Metering Infrastructure Service Providers (AMISPs) are central to the implementation of smart metering, several other institutions also have key roles. These include the Ministry of Power (MoP), the Central Electricity Authority (CEA), State Electricity Regulatory Commissions (ERCs), and the nodal agencies for RDSS, namely REC and Power Finance Corporation (PFC).

In the sections that follow, we examine each of these dimensions to assess the extent and robustness of the existing regulatory provisions.

1. The mandate for smart metering

At the national level, the Central Electricity Authority has laid down the mandatory requirements for smart metering through the CEA (Installation and Operation of Meters Regulations), amended in 2022. These regulations mandate: “All consumers in areas with communication network, shall be supplied electricity with Smart Meters working in prepayment mode, conforming to relevant IS, within the timelines as specified by the Central Government,” further “in areas which do not have communication network, installation of prepayment meters, conforming to relevant IS, shall be allowed by the respective State Electricity Regulatory Commission.”

2. Standards for meter technology

The selection and deployment of smart meters by discoms is guided by technical specifications issued by the Central Electricity Authority (CEA), largely based on the Indian Standard IS 16444. These specifications define the essential features of the meters, such as communication protocols, alarms, remote connect/disconnect functions, and data storage capabilities. They also require smart meters to record detailed consumption data in line with IS 16447 and the companion standard IS 15959 (Part 2)¹. The data to be captured covers a wide range of parameters, including instantaneous readings, block load profiles, daily load profiles, billing profiles, event logs, nameplate details, and programmable parameters; of these consumer access to instantaneous parameters is configurable, the rest of the parameters are governed by standards, regulations, and meter communication protocols.

The presence of such clear technical standards for meter selection is significant, as it helps ensure uniformity in smart meter implementation across discoms. This, in turn, enhances prospects for interoperability and strengthens cost benchmarking.

3. Smart metering action plans and DPRs

A significant share of smart metering in India is being implemented under the Revamped Distribution Sector Scheme (RDSS), which provides budgetary support to state discoms for metering, distribution infrastructure, and project management. The RDSS guidelines outline the processes for availing scheme benefits, including preparation of smart metering action plans, their approval by the State Cabinet and the Distribution Reforms Committee (DRC)², and submission to the nodal agencies (PFC/REC). Based on these action plans, discoms must prepare Detailed Project Reports (DPRs), which are then scrutinized by the nodal agency and approved by the Monitoring Committee³.Thus the process for approval of smart metering action plans and DPRs under RDSS is clearly laid out with necessary monitoring by nodal agencies.

4. Selection of smart metering service providers

Under RDSS, once action plans and DPRs are approved, discoms select the AMISP for smart metering based on the Standard Bidding Document (SBD) issued by the National Smart Grid Mission (NSGM) which ensures uniformity across discoms. The SBD defines the scope of work, system and quality requirements, service level agreements (SLAs), deliverables, and clauses on data management, privacy, security, consumer interface, and complaint handling. While discoms may make minor modifications with approval from the nodal agency, the SLA between the discom and AMISP ultimately forms the core of smart metering implementation.

5. The need for state level regulations

While service level agreements (SLAs) between discoms and AMISPs are central to project implementation, they are contractual in nature and not mandated to be in the public domain. As a result, they offer limited scope for consumer review. While SERCs prescribe notice and reconnection timelines through their Supply Codes and Standard Operating Procedures (SoP) regulations, most of them are in general practice and not specifically for smart meters, some discoms like Bihar have internal protocols which are not regulator approved.

Moreover, discoms implementing smart metering outside the RDSS framework, such as those using state grants or private discoms, may not be bound by the RDSS Standard Bidding Document. The essential point is that the existing Supply Codes, Standards of Performance and grievance-redressal mechanisms in many states were framed in the context of conventional metering and therefore do not adequately address the new dimensions introduced by smart meters such as remote disconnection, data accuracy disputes, and prepayment functionalities. This gap underscores the need for state-level regulations that go beyond contractual arrangements to establish updated performance standards, consumer protection provisions, and strengthened redressal processes tailored to smart metering.

6. Analysis of State-Level Regulations

Given these gaps, and in the absence of comprehensive national level regulations or guidelines, state-level frameworks play a crucial role in making smart metering implementation robust and consumer-centric. To assess the extent to which existing state level regulations are ensuring this, we examined how eleven states⁴ are addressing key dimensions (as mentioned above). The following sections summarise our findings:

6.1. Types of Regulatory Instruments

States are seen to have different ways of incorporating smart metering related provisions in their regulations. Karnataka and Telangana have issued a separate regulation for smart metering and smart grid respectively; Madhya Pradesh has issued practice directions and Uttar Pradesh has introduced a smart meter roll-out plan approved by the UP electricity regulatory commission (UPERC). Other states have amended their Electricity Supply codes to include clauses related to smart metering. In a few states like Bihar, there is no specific mention of smart metering in the supply code though it refers to prepaid consumer billing.

6.2. Meter testing and calibration

Accurate metering requires regular testing and recalibration. The CEA metering regulations state that The testing of Consumer Meters shall be done at site through accredited test laboratory at least once in five years and recalibrated, if required: Provided that the licensee instead of testing the meter at site can remove the meter and replace the same by a meter duly tested in an accredited test laboratory: Provided further that meter shall be tested if the consumption pattern changes drastically from the similar months or seasons of the previous years or if there is consumer’s complaint pertaining to a meter: Provided also that the meter used for testing shall be of better accuracy class than the meter under test⁵.

State regulations mostly cover initial testing and replacement due to damage. Regulations in Bihar includes periodic testing timelines for different meter types (e.g. LT single phase meters: at least once every 5 years, etc.), while Maharashtra refers to the CEA regulation for periodic testing and maintenance. However, none of the State regulations include any reporting requirements for meter testing or calibration logs.

6.3. Disconnection and Reconnection Protocols

Remote disconnection and reconnection feature of prepaid smart meters offers better control to the discoms for revenue realisation and network maintenance but can pose as a double-edged sword if not managed carefully, like in the case of the automatic disconnection of ~1.6 lakh consumers in Uttar Pradesh in 2020 or abrupt power disconnections in Jaipur.

Across states, disconnection and reconnection protocols for prepaid smart meters vary widely. In some states such as Maharashtra, Tamil Nadu, Gujarat, and Rajasthan, regulations provide for automatic disconnection once credit is exhausted, without specifying advance notice. Uttar Pradesh regulations add safeguards such as “happy hours” during which supply cannot be disconnected and restrict disconnection to working hours. Other states like Karnataka, Andhra Pradesh, Madhya Pradesh, and Bihar (at the discom level) provide more detailed Standard Operating Procedures (SoPs), including consumer notifications, restrictions on disconnection hours, and exceptions on holidays.

On reconnection, five of the eleven states reviewed require supply to be restored once charges are paid or the meter is recharged. Andhra Pradesh and Uttar Pradesh go further by specifying reconnection within 15 minutes and two hours respectively.

The table below summarises these provisions for states where regulations explicitly address disconnection and reconnection for smart or prepaid smart metering. It is important that disconnection is carefully regulated to ensure consumers receive timely alerts before supply is cut off, and that reconnection after recharge happens immediately and within the enforceable timeframe.

Table 1: Disconnection and Reconnection protocols as per State Regulations on smart/prepaid smart metering

Sr. No.	State Electricity Regulatory Commission	Disconnection on exhaust of credit	Disconnection hours/ details	Notifications prior to disconnection	Notifications after disconnection	Emergency credit/ Grace period	Time limit for restoration of supply on recharge for smart meters
1	Tamil Nadu	✓	Not specified	Not specified	Not specified	Not specified	Six hours
2	Uttar Pradesh	✓	Working hours, except for configurable happy hours	Not specified	Not specified	Not specified	Two hours
3	Karnataka	✓	10 am - 1 pm, Not on weekly and other holidays	At 75% energy charges amount	✓	Not specified	Auto reconnection
4	West Bengal	✓	Not on Saturday, Sunday, Holidays	Not specified	Not specified	Not specified	48 hours (not specific to smart meters)
5	Andhra Pradesh	✓	10 am - 1 pm, Not during holidays, non-working hours	Min 3 advance notifications	Not specified	One day consumption	15 minutes of recharge
6	Bihar6	✓	Not specified	15 days’ notice (Not specific for smart meters)	Not specified	Not specified	Not specified
7	Madhya Pradesh	✓	No disconnection between 6 pm - 10 am	Notification/ alert on phone in case of low credit/ negative balance	✓	Grace period of 3 days if the cumulative consumption in the month is within eligible range for govt subsidy	Not specified

6.4. Addressing non-functioning smart meters or network

Smart metering systems rely on robust communication networks. Failures can occur in two ways: (1) the meter itself becomes defective (e.g., burnt, or faulty, inaccurate readings), or (2) the meter functions but fails to communicate with the network.

In the selected states, regulations mostly address the first case, with SoP’s for defective, burnt, or lost meters and related cost treatment. TNERC mentions that in case the meter is defective, the quantity of electricity supplied shall be assessed based on the data downloaded through CMRI (Common meter reading instrument) from the defective meter and scrutiny of the data, load curve, etc. Wherever data cannot be downloaded, the regulations outline procedures for estimating the quantity of electricity supplied. KERC provides details on addressing issues related to billing, in such cases which is based on the past seven days’ average in case of communication failure, while MPERC specifies daily provisional billing for dysfunctional meters. No other state regulations state different billing strategies in case of failure of smart meters or communication networks.

This highlights the need for comprehensive SoPs covering both meter and network failure issues, including abnormal and emergency situations. Clear consumer communication protocols and defined timelines for restoring meters or networks should also form part of discoms’ Standards of Performance.

6.5. Consumer engagement

Building consumer confidence in the smart metering system is an essential step in implementation. Part B of RDSS specifically provides full funding for consumer engagement and awareness on prepaid smart metering. The RDSS guidelines mention that “The nodal agencies shall prepare a multi-modal communication plan in consultation with MoP. Consumer engagement and consumer awareness on prepaid smart metering shall be designed, and campaigning will be carried out in consultation with Nodal Agency. The cost of these activities will be borne out of the MoP component of enabling charges.”

The RDSS SBD requires AMISPs to provide a consumer portal/app and a plan for consumer engagement, but these are outside regulatory supervision, limiting their accountability. A review of state regulations shows inclusion of specific provisions in some states. GERC and MERC mandate provision of prior notice before meter installation, with GERC also requiring conducting awareness sessions during meter replacement. However, timeline on how many days prior to meter replacement has not been included. Anecdotal evidence from on ground suggests a letter to consumers is issued only a day or two before actual meter replacements. TGERC mandates allocation of 1% of smart grid project costs to consumer awareness, while Madhya Pradesh requires advance notice, SoPs, and FAQs related to smart metering are to be published on discom website. No specific measures are mentioned by other state regulations.

Consumer engagement and trust building is an important step in ensuring smooth smart meter installations. Hence, irrespective of availability of funding, state regulations should mandate at least a few consumer awareness measures such as:

• Providing advance notice before migration to smart meters
• Inclusion of FAQs, or audio/video resources on smart metering
• Consumer portal/app for tracking ongoing engagement and progress
• Establishment of a mechanism for query resolution and grievance redressal

6.6. Reporting requirements

Transparency is essential for tracking smart metering outcomes. While portals like RDSS and National Smart Grid Mission (NSGM) report installation progress, other vital information such as efficiency gains, service/opex charges, and contract details is missing in the public domain.

For the selected states, only UPERC requires quarterly reporting on smart metering progress and performance metrics. TGERC mandates periodic evaluation of smart grid programs. Other states do not specify reporting obligations.

6.7. Cost Recovery Mechanisms

The RDSS guidelines envisage that smart metering costs will be met through central grants and efficiency gains from prepaid billing. However, until large-scale deployment and network improvements are achieved it may be difficult to estimate the performance linked benefits. Currently, discoms are adopting different approaches to recover costs. Our analysis of 11 states shows that cost recovery mechanisms most SERCs allow the fixed monthly charges (per meter per month) to be passed on through inclusion in the annual revenue requirement, sparingly some ERC’s have disallowed the pass through of costs stating expenses are to be recovered through efficiency-linked processes. Some ERCs also allow consumers to purchase meters.

In the case of Gujarat, the FY24 tariff orders include approval of RDSS metering operational expenses, which accounts for ~16% of the approved O&M expenses of all the state discoms together. On the other hand, Uttar Pradesh regulatory commission has disallowed smart meter opex recovery through tariffs in the tariff orders for FY23 and FY24, stating that the RDSS is self-sustaining and the costs should stay out of ARR. MERC regulations prohibit meter cost recovery from consumers which is otherwise included in the capital expenditure, except in cases where meters are burnt, lost, or voluntarily purchased.

Detailed analysis of these regulations can be read in our previous article.

6.8. Data access for Consumers

IS 16444 requires smart meters to record consumption parameters with a 10-year retention capacity, while CEA metering regulations mandate at least 35 days of storage and consumer access through web or mobile apps. Although all state regulations, uphold the CEA Metering Regulations yet details on actual data access to consumers through the mobile /app or website is not clearly mentioned in the regulations.  Only, MPERC mandates access to six months of historical data for consumers. However, details on formats, data parameters or sharing protocols is missing in all regulations.

Absence of clear, uniform standards on data parameters, duration of data storage, and consumer data access mechanisms limits usability of smart metering data.

6.9. Data privacy and Cybersecurity

Data privacy and cybersecurity are critical in smart metering, as consumption data can reveal detailed behavioural patterns.

CEA metering regulations require generating companies and licensees to comply with CEA (Cyber Security in Power Sector) Guidelines, 2021. These guidelines designate discoms as “responsible entities,” mandating a cyber security policy aligned with National Critical Information Infrastructure (NCIIPC), annual review of the policy, and inclusion of cyber security clauses in contracts.

The RDSS guidelines also make cyber security provisions mandatory in metering contracts. The Standard Bidding Document (SBD) requires AMISPs to comply with IT Act privacy rules, submit a “Privacy by Design” document, anonymize personal data, establish consent and breach response protocols, and undergo third-party audits.

In this context, we looked at the smart metering regulations in the selected states to understand how they are approaching the space of data privacy and cyber security. Regulations in five out of the eleven states do not have any specific clause about data security. Others stipulate ensuring data privacy and security but do not refer to any standard or regulation. None refer to the CEA cyber security guidelines. In this context it is important to review:

1. CEA regulations are binding but monitoring mechanisms remain unclear.
2. Multiple, overlapping requirements (CEA, RDSS, IT Act) create complexity without clear accountability.
3. State-level regulations are inadequate, five of eleven examined have no data privacy or security provisions, while others lack reference to any standard or the CEA cyber security guidelines.
4. Public access to SLAs and compliance reports is limited, making it difficult to verify whether AMISPs and discoms are fulfilling obligations such as cyber security policies, breach response plans, or independent audits.

We had highlighted these gaps in one of our previous articles back in 2021 and had also suggested a privacy and security framework for smart metering. The present status urgently calls the need for a strong regulatory supervision on these aspects.

Building on the insights from our analysis, we outline key recommendations to enhance the scope and effectiveness of smart metering regulations in India.

Recommendations

Smart meters will become an important part of India’s electricity infrastructure. Once installed, these meters and the systems are expected to operate for at least 10 years. The way regulations are developed today will shape consumer experience, discom operations, data governance, and trust in such systems for decades to come. Hence, a robust and consumer-centric regulatory framework is essential to ensure that the long-term benefits of smart metering like efficiency gains, improved reliability in service, and consumers empowerment through data access are realized.

As discussed in the article, currently most state regulations that deal with smart meter installation, operation and data sharing protocols are scattered across clauses in supply codes, standards of performance guidelines and in very few cases dedicated practice directions/regulations exist. Introducing a comprehensive performance driven and consumer centric smart metering regulation would bring in more clarity. The Forum of Regulators can develop such a comprehensive guideline for Smart Metering Regulations that can be adopted by States. The guidelines should provide clear guidance on strict testing protocols, transparent reporting frameworks to ensure performance-based cost recovery, robust consumer data access standards, detailed SoPs for meter operation and network failures, disconnection and reconnection protocols, institutionalization of cybersecurity audits, advance consumer engagement measures and compliance on data privacy and cybersecurity.

Looking at the larger picture, once India moves towards its vision of 250 million smart meters, discoms could potentially benefit from higher billing efficiency and a reduced ACS-ARR gap. However, the true success of smart metering will rest on consumer-centric implementation and transparent disclosure of performance benefits. With timely interventions, India can potentially accelerate adoption, like the rapid uptake of UPI or prepaid mobile phones.

The authors thank Shantanu Dixit and Aditya Chunekar for their valuable inputs and review of this document.   Comments and suggestions on the series are welcome and can be addressed to This email address is being protected from spambots. You need JavaScript enabled to view it.