ISLAMABAD: The National Electric Power Regulatory Authority (Nepra) has been urged to undertake the proposed amendment process to NEPRA (Prosumer) Regulations, 2026 with full transparency and meaningful consideration of stakeholder submissions. Arif Bilwani and Tanveer Barry, in separate communications to the Registrar of NEPRA, argued that established regulatory practice and principles of transparency require the issuance of a comprehensive and reasoned order incorporating stakeholder feedback, along with justification for acceptance or rejection of comments. They contended that the Regulations were reportedly issued within two days of the public hearing, without adequate deliberation or incorporation of stakeholders’ views. Such an approach, they said, undermines the consultative framework and results in avoidable subsequent amendments. READ MORE: Prosumers seek reasonable transition period for net-metering regime Bilwani, identifying himself as an affected stakeholder and prosumer, submitted formal objections in response to the Authority’s invitation regarding the proposed amendments. He noted that he had earlier filed detailed written comments on January 13, 2026, in response to the draft Prosumer Regulations, 2025. The public hearing held on February 6, 2026 saw unprecedented participation, with several hundred written objections submitted from across the country and a historically large number of stakeholders attending both physically and virtually, he noted. He maintained that the objections were substantive, technical, financial and legal in nature. Despite the scale and uniformity of concerns raised, the Regulations were notified without issuance of a detailed, reasoned and speaking order addressing the specific objections. Citing principles of administrative law, he argued that when a statutory authority invites objections and conducts a public hearing, it is legally bound to apply its independent mind and issue a reasoned determination demonstrating consideration of the material on record. The absence of such reasoning, he said, raises concerns regarding compliance with natural justice, transparency and due process. The stakeholders further argued that the immediate proposal for amendment following promulgation of the Regulations constitutes implicit acknowledgment of material deficiencies in the notified framework. They noted that the lacunae now being addressed had already been highlighted during the consultation process. Bilwani added “The current amendment is insufficient and fundamental structural corrections are required to ensure legality, fairness and economic viability.” The stakeholders demanded that the Regulations clearly provide that imported and exported units be fully netted off within the billing cycle, with only net consumption — if any — subjected to billing under the NAEPP or applicable prevailing tariff. They warned that failure to incorporate a proper netting-off mechanism would render the framework arbitrary, economically punitive and legally vulnerable on grounds of unreasonableness and violation of legitimate expectations. The mandatory insurance requirement for installations up to 30–40 kW was termed disproportionate and excessive. According to the interveners, residential and small commercial prosumers do not pose systemic risks warranting such financial and procedural burdens. They further argued that imposing uniform insurance obligations without capacity-based differentiation violates the principle of proportionality, discriminates against small-scale renewable participants and creates barriers to distributed generation. At minimum, they suggested, the requirement should be exempted or significantly relaxed for lower-capacity installations. The stakeholders emphasized that Nepra, as a statutory regulator exercising quasi-judicial powers under the Nepra Act, 1997, must demonstrate independence and cannot be perceived as endorsing proposals originating from operational entities without critical scrutiny. They called for: (i) full and transparent consideration of stakeholder submissions; (ii) issuance of a detailed speaking order addressing each material objection; (iii) comprehensive revision of the Regulations to incorporate a proper netting-off mechanism and rationalized insurance requirements; and (iv) demonstrable exercise of statutory independence in finalizing the framework. The matter, they said, carries significant financial, environmental and legal implications for thousands of prosumers across Pakistan and warrants careful, independent and legally robust regulatory action. Copyright Business Recorder, 2026