Maryland Net Metering Cutoff 2027: Confirmed vs Open for EPCs

Maryland Net Metering at a Glance

Maryland's net metering law has a statewide capacity limit, and the Utility RELIEF Act changed what happens when that limit or a date is reached. The DLS fiscal note describes the Act as an emergency bill with many parts: rates, data centers, permitting and more. For solar EPCs, three parts matter. It sets up a successor to net metering, it ends entry into the existing program, and it limits how long participants in the existing program keep their eligibility.

The sequence so far:

• May 12, 2026: the Act's emergency provisions take effect on enactment, according to DLS.
• May 14, 2026: the PSC opens a proceeding, PC 78, and creates a Net Energy Metering Successor Program Working Group. Its leader is Melanie Santiago-Mosier.
• June 2026: the PSC publishes proposed regulations in rulemaking RM 56, including options for the cutoff rule.
• October 27, 2026: the working group must file its draft report and framework.
• November 2026: public hearings are expected, according to a Solar United Neighbors notice.
• December 2026: the PSC has told a legislative committee it expects to report to the General Assembly, according to a summary of that hearing.
• February 1, 2027: the PSC must approve a framework for a successor program.
• July 1, 2027: the successor program is to begin.

The PSC's notice puts the core requirement in one sentence: approve by February 1, 2027 a framework for a new net energy metering program that begins July 1, 2027.

What the Proposed Rule Says About the Cutoff

The PSC's proposed rule changes COMAR 20.50.10.01, which sets how long utilities must offer net metering. The old text tied it to a 1,500 MW limit. The proposed text says utilities provide net metering until the earlier of two events: the rated generating capacity of eligible customer-generators in the State reaching 3,000 megawatts, or July 1, 2027.

The rule then has to answer a question the law leaves open: what must a customer have done by that date to count as already in? The draft shows three versions, each with the groups that support it.

Version 3 adds a fallback. A customer who applied by July 1, 2027 but did not execute an agreement by then would take service under the successor program and would receive prioritised review of the application there.

The choice decides which projects in an EPC's pipeline keep today's terms. A project with a filed application and no permission to operate on June 30, 2027 is in under Version 1, out under Version 2, and in a middle position under Version 3. The utility's processing time becomes the EPC's risk under Version 2 and mostly the EPC's control under Version 1. The PSC has not chosen, and the draft does not say which version it favours.

Will the 3,000 MW Cap Arrive First?

The PSC's own figures put operating net-metered capacity at about half the limit. In a March 2026 fiscal note on a related bill, DLS cited the PSC's November 2025 report: operating net-metered facilities at 1,537 MW and a pipeline of community solar of about 2,911 MW. Together that is roughly 4,500 MW, well above the 3,000 MW limit if all of it were built. DLS added that the PSC expected the existing limit to be reached within about two years.

Those numbers do not say which limit binds first for a rooftop installer. The proposed rule shows why. From January 1, 2027, each electric company must file monthly capacity reports to the PSC, in kilowatts AC. The reports list operating capacity, operating community solar, capacity under active reservations that meet the grandfathering rules, and community solar queue positions. If staff project that operating capacity, or operating plus grandfathered capacity, will exceed 3,000 MW before July 1, 2027, staff may petition the Commission, which may open a proceeding to limit program capacity.

So the cap could arrive early through reserved capacity, not only through built capacity. How reserved capacity is counted is draft text. The draft also refers to a combined 6,000 MW limit across the existing and successor programs.

Who Keeps Today's Terms, and What Forfeits Them

A customer under a net metering contract or tariff on July 1, 2027 stays eligible until the earliest of four events. The proposed rule lists them:

• The system is decommissioned.
• The system is modified to add more photovoltaic modules than it had when originally placed in service, or to raise its AC output capacity above the original.
• The system enters into a new interconnection agreement.
• The system is repowered, as the statute defines the term.

When any event occurs, the customer loses eligibility under the existing program and may apply to the successor program. For an EPC, this reaches beyond new sales. An add-on that increases module count or inverter AC output, or that needs a new interconnection agreement, can move a customer to the successor program. The text read here does not say whether a battery added behind an unchanged inverter and array triggers any of the four events. It also does not list a sale of the home as a trigger.

The draft adds service-side duties. A customer with a system under 1 MW AC must notify the electric company if the system is repowered, and must keep records of module replacements except replacements that the statute exempts from the repowered definition. Systems under 100 kW AC are excused from the recordkeeping. On notice of repowering, the utility switches the customer to the current available tariff.

What the Successor Program Must Do, and What Is Not Known

The Act directs the PSC to approve a framework and gives the working group a defined brief. Beyond that, no rate exists. The working group's draft will be the first public design.

Secondary summaries of the new §7-306.4 say it requires incentives lower than today's net metering. This guide did not read the section text, so treat the direction as reported and the size as unknown.

Two design choices will decide the economics for a new customer, and the draft rules do not settle either. One is how often exports are netted against imports. The other is what an exported kilowatt-hour is worth. The proposed rules already include a time-varying credit method for community solar subscribers, which converts kilowatt-hour credits to a monetary credit using a solar generation value profile and time-of-use prices. That is a method for community solar, not for rooftop, and it signals only that time-based valuation is in the PSC's toolkit.

The Same Act Changes Permitting and Interconnection Work

The Act also rewrites rules that govern an EPC's schedule. The enrolled text amends Local Government §1-1320.

• Permitting software. Each county and municipality must implement solar permitting software on or before August 1, 2027. The statute's earlier date was August 1, 2025. The software must automate plan review against the Maryland Building Performance Standards, the National Electrical Code with legally adopted local amendments, and local building codes, and issue a code-compliant permit.
• Instant permits. The software must accept online payment and issue permits or permit revisions immediately on receipt of the fee.
• Inspection time. A county or municipality must complete inspections for projects permitted through the software within an average of five business days after a properly completed request, and must publish its annual average inspection time.
• Scope of review. Review of a software-submitted application is limited to whether it meets health and safety requirements under State and local law. A manual review of a software-approved permit must be done within five business days.
• Fee cap. From August 1, 2027, a county or municipality may not set a permitting fee above $500 for a residential rooftop system under 20 kW AC (measured at the inverter) permitted through the software. A third-party payment processing charge may be added.
• Meter work. An electric company, other than a municipal electric utility, must perform meter disconnection and reconnection needed to interconnect a residential solar or storage system within five business days after a properly completed request. It may authorise qualified outside personnel to do the work. The text does not change the PSC's small generator interconnection standards.
• Enforcement and exceptions. The Attorney General may seek court enforcement against a county or municipality. A jurisdiction that requires no permit is excused, and the Maryland Energy Administration may delay or suspend the requirements if funding is insufficient.

Where Design Software Fits

Automated permit review works from the plan set, and a faster permit moves the bottleneck to the application and the utility. Design software like Reslink produces layouts, single-line diagrams and a bill of materials from one 3D design, so a revised system updates every document together. A proposal tool can also hold two cases side by side, today's net metering and a placeholder for the successor, so quotes can be re-run when the PSC publishes rates. It cannot know those rates or decide whether a project qualifies. The utility and the PSC do.

See the full workflow → Book a demo

Frequently Asked Questions

Q1. What is PC 78 and how can an EPC take part?

PC 78 is the PSC proceeding for the net energy metering successor program. The PSC created a working group of utilities, owners and developers of net-metered projects, solar industry representatives, consumer advocates and others. Parties who want to take part can contact NEMSuccessor.PSC@maryland.gov to join the participation roster.

Q2. Is there a limit on system size for net metering?

Yes. The proposed rule says a proposed system may not exceed 200 percent of the customer-generator's baseline annual usage to qualify initially. The statute also caps an individual system's generating capacity at 2 MW, with community solar and meter-aggregated facilities allowed up to 5 MW, according to the DLS description of current law.

Q3. How are leftover credits paid today?

Net excess generation carries forward to later months. The remaining value is paid around the end of April each year, at the generation or commodity portion of the customer's rate averaged over the prior 12 months, unless the customer chooses an alternative. The proposed rules would let a customer elect a 12-month accrual with an April payout or an indefinite accrual. Municipal electric utilities and cooperatives would not have to offer indefinite accrual. Whether the successor program keeps this design is not known.

Q4. What counts as repowering?

The proposed rule points to the statute's definition of repowered in §7-306, which this guide did not read. The rule's recordkeeping text excepts some module replacements from that definition, so not every replacement counts. Until the definition is confirmed, ask the utility in writing before a replacement or upgrade on a net-metered system.

Q5. Does community solar keep net metering after July 1, 2027?

Under the proposed rule, a community solar system placed in service after July 1, 2027 can still qualify if the 3,000 MW cap has not been met and three conditions hold. It received a queue position by July 1, 2027. It paid a deposit of at least 50 percent of the utility's estimate of interconnection fees by that date. And it is placed in service by July 1, 2030. The Commission may extend the deadlines for force majeure, government or utility delay, or a system waiting only for permission to operate.

Q6. Does selling a home end grandfathered status?

The proposed text read here does not list a sale as one of the four events that end eligibility. Those events are decommissioning, adding modules or AC capacity, a new interconnection agreement and repowering. The draft is not final, so confirm with the utility before relying on it.

Final takeaway

Maryland's net metering cutoff is confirmed in its outline and open on the two details that matter to an EPC's pipeline: the milestone that counts as being in, and how reserved capacity is counted against the 3,000 MW limit. Both sit in draft rule text. Neither has a published decision.

The working group's October 27 draft is the next test. Until the PSC chooses, the safest reading for Maryland net metering is to treat a signed interconnection agreement as the strongest milestone and a utility permission to operate as the one outside the installer's control. Keep every project's dates documented.

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Sources

• Maryland Public Service Commission, "Notice Convening a Public Conference, PC 78," Utility RELIEF Act of 2026 Net Energy Metering Successor Program, May 14, 2026
• Maryland Public Service Commission, Proposed Regulations, Rulemaking RM 56 (COMAR 20.50.10 and 20.62), June 2026
• Maryland General Assembly, House Bill 1532, Utility RELIEF Act, enrolled bill (Local Government §1-1320 on solar permitting and interconnection)
• Department of Legislative Services, Fiscal and Policy Note, HB 1532 (Enrolled - Revised, May 21, 2026), and Fiscal and Policy Note, HB 1476 (First Reader, March 2026), citing the PSC's November 2025 net energy metering report
• Solar United Neighbors, event notice on Maryland's proposed net energy metering changes (October 13, 2026), for the November hearings

This guide summarises Maryland PSC and legislative documents as of October 15, 2026. Rules are proposed and may change. It is not legal advice. Check the PSC docket and your utility before relying on any date or milestone.