NERSA & Solar Wheeling — questions
Frequently asked questions about NERSA registration and solar wheeling
Since the 2021 amendment to Schedule 2 of the Electricity Regulation Act, most embedded generation no longer needs a generation licence, but registration with NERSA is still required, and wheeling always needs a use-of-system agreement with the network operator carrying the electricity.
Do I need a NERSA licence for rooftop solar?
Most rooftop and embedded solar installations no longer need a generation licence because of the 2021 amendment to Schedule 2 of the Electricity Regulation Act. Registration with NERSA is still required in almost all cases.
Is there still a capacity limit for licence-free generation?
No fixed capacity threshold applies any longer for the licensing exemption itself, but the exemption conditions in Schedule 2, including how the electricity is sold, must still be met regardless of size.
What is the difference between registration and a generation licence?
Registration is a lighter administrative process for generators that meet the Schedule 2 exemption conditions. A generation licence is a formal NERSA authorisation required for projects selling to multiple customers outside a trading licence structure.
Can I wheel electricity to a site in a different municipality?
Yes, provided you conclude use-of-system agreements with every network operator whose infrastructure carries the electricity, which may include both Eskom and one or more municipalities.
Do municipalities all charge the same wheeling tariff?
No. Each licensed municipal distributor sets its own wheeling tariff and connection rules, approved through its own tariff process, so rates and conditions differ between metros.
Do I need a trading licence to sell solar power to my tenants?
If you are selling to a single customer or supplying your own site, registration is normally enough. Selling to multiple separate customers directly, without a licensed trader, generally requires a trading licence.
What happens if I generate and wheel without registering?
Operating without the required registration or licence is a contravention of the Electricity Regulation Act and can result in enforcement action by NERSA, and it also makes the network operator unlikely to conclude a connection or use-of-system agreement.
Does an environmental authorisation apply to solar projects?
Certain solar facilities trigger environmental authorisation requirements under the National Environmental Management Act depending on size and location, and this should be confirmed before finalising the NERSA submission.
What is wheeling, in practice?
Wheeling is using the existing Eskom or municipal network to move power from your plant to an offtaker somewhere else. Commercially it needs three things to line up: the generator's registration or licence, a use-of-system or wheeling agreement with the network owner, and a power purchase agreement with the offtaker. Projects stall when these are done in the wrong order — the PPA is signed before the network position is confirmed.
Does a solar plant need environmental authorisation?
It depends on the footprint, the capacity and the site. Rooftop plants generally do not trigger a listed activity; ground-mount plants, substations and transmission lines frequently do. We screen the NEMA triggers as part of the readiness review so it does not surface after design is locked.
Related pages
Last reviewed: 2026-09-17
Written and reviewed by Dynamic Legal Services (Pty) Ltd, registration 2016/074955/07. Registered with the Department of Water and Sanitation, EAPASA applicant. Offices in Faerie Glen, Pretoria and Sandown, Sandton. Telephone 087 153 6207, support@dlegal.co.za. General information on South African regulatory practice, not advice on a specific matter — the first consultation is free.