Cancellation of obtaining Sanad certificates for non-agricultural use of land for renewable energy projects: a targeted policy revolution
Sushant Shetty
Fox Mandal & Associates, Mumbai
sushant.shetty@foxmandal.in
Fox Mandal & Associates, Mumbai
arati.sawant@foxmandal.in
The Government of Maharashtra’s circular dated 7 August 2025 ('the Circular') provides a comprehensive solution to the bureaucratic hurdles that have long constrained solar and wind energy project development. The notification abolishes two specific requirements that previously added months to project commencement, delaying timelines and imposing substantial costs on renewable energy ventures.
The twin exemptions explained
The Circular eliminates the requirement for Sanad certificates, ie the formal permissions needed to convert agricultural land for non-agricultural use under the Maharashtra Land Revenue Code 1966. Simultaneously, it cancels non-agricultural taxes that landowners traditionally paid when converting agricultural land for industrial purposes. These twin exemptions target the most time-consuming and expensive aspects of renewable energy project development on agricultural land.
Previously, obtaining Sanad certificates involved multiple revenue department approvals, extensive documentation and conversion charges calculated as percentages of market value. For large solar or wind installations spanning hundreds of acres, these costs could reach crores of rupees while approval processes stretched for six to 12 months.
Precise eligibility criteria
The exemptions apply exclusively to projects established under three specific government schemes:
- Electricity generation projects under the Mukhyamantri Saur Krishi Vahini Yojana, which covers agricultural solar installations aimed at providing reliable power to farming communities.
- Solar and wind energy projects under the Non-Conventional Energy Generation Policy 2020, encompassing broader renewable energy initiatives targeting grid-scale development.
- Solar and wind energy projects under the Maharashtra Green Hydrogen Policy 2023, covering emerging hydrogen production facilities powered by renewable sources.
Streamlined procedural framework
The Circular replaces the complex collector approval system with a simplified two-step process: (i) project developers must first obtain development permissions from competent planning authorities or secure construction plan approvals; and (ii) project developers must submit copies of these permissions to Taluka revenue officers for land record updates. The Circular specifically directs district collectors to ensure subordinate offices promptly update records, addressing historical delays that created legal uncertainties.
Legal foundation and interim nature
The Circular operates within a broader policy framework where Maharashtra’s Cabinet has decided to eliminate non-agricultural taxes on all industrial and commercial land use. Revenue and Forest Department amendments to the Maharashtra Land Revenue Code 1966 are underway to formalise these changes through legislation.
The renewable energy exemptions function as interim measures while these legislative amendments proceed through the state assembly. This approach positions clean energy projects as pioneers for broader industrial development reforms that will eventually apply across all sectors.
Economic impact and strategic alignment
The financial implications extend beyond simple cost elimination. Traditional non-agricultural conversion charges represented significant upfront costs, while ongoing non-agricultural taxes created permanent operational expenses. By removing both components, Maharashtra has fundamentally altered project economics for renewable energy developers.
These exemptions align with ambitious state targets under the Mukhyamantri Saur Krishi Vahini Yojana 2.0, which aims for 16,000 MW of decentralised solar capacity. The financial relief directly supports the project viability needed to achieve these goals while complementing existing benefits such as stamp duty waivers for private land acquisitions.
Implementation considerations
The Circular creates new compliance requirements despite eliminating traditional barriers. Developers must demonstrate that their projects qualify under one of the three specified government schemes, shifting focus from land conversion approvals to scheme eligibility verification. This requires careful project structuring and documentation to ensure continued exemption benefits.
The temporary nature of these exemptions, valid until formal legislative amendments are enacted, creates planning considerations for long-term projects. Developers may need to structure agreements anticipating potential future changes if legislative amendments differ from current circular provisions.
Takeaway
Maharashtra’s comprehensive approach represents the most extensive land-related exemptions for renewable energy implemented by any Indian state. While other states offer partial relief through stamp duty reductions or modified conversion charges, Maharashtra’s complete elimination of Sanad requirements and non-agricultural taxes establishes a new benchmark.
The success of this model will likely influence policy development across India as states compete to attract renewable energy investment. The integration with existing agricultural schemes demonstrates that renewable energy can complement rather than compete with farming activities, potentially influencing rural development policies nationwide.
As India pursues 500 GW renewable energy capacity by 2030, regulatory innovations like Maharashtra’s targeted exemptions may prove as significant as technological advances in determining deployment speed and scale. The Circular demonstrates that creative policy solutions can eliminate traditional barriers while maintaining appropriate oversight, potentially providing a template for accelerating India’s clean energy transition.