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DLC will delist V5.1 products on December 15, 2026. Manufacturers and distributors are asking us the same question they asked in 2022: which utilities will switch to V6.0 right away, which will give a grace period, and which won't say anything at all?
We've been here before. When DLC delisted V5.0 products on June 30, 2022, our team contacted utility programs one by one to find out how each would handle it. Here's what that showed, and what it suggests about the V6.0 transition.
What changed in V5.1
V5.1 was the second phase of DLC's V5 SSL Technical Requirements. V5.0 dealt with the traditional measures, efficacy and basic controllability reporting. V5.1 added light-quality requirements (spectral quality, light distribution, discomfort glare) and, most consequentially, required general dimming capability for almost every product.
The timeline was long, but the drop-off was sudden:
- February 14, 2020: DLC released V5.1.
- April 15, 2022: deadline for manufacturers to update V5.0 listings to V5.1 and stay continuously listed.
- June 30, 2022: V5.0 products that hadn't been requalified were delisted.
The dimming requirement drew the most pushback, since the added cost was hard to justify for some products and uses, especially industrial ones. Replacement products like LED tubes and HID replacement lamps were of most concern. Distributors were left holding stock that was no longer rebate-eligible. Contractors had projects quoted with rebates that the products no longer qualified for.
How utilities responded
Of 120 programs we reviewed, 54 (45%) offered some kind of extension, 41 (34%) did not, and 25 (21%) never gave us a clear answer. We focused on the larger investor-owned utility programs.
"Extension" and "no extension" hide a wide range of policies. In practice, responses fell into five patterns:
| Response | What it meant | Examples |
|---|---|---|
| Strict cutover | Only V5.1 products eligible for submittals or purchases after June 30 | Mass Save, Eversource NH, Liberty, Unitil, Duquesne Light, Dominion Energy (NC, VA), DC SEU |
| Grandfathering by date | V5.0 products allowed if the application, purchase, permit or install predated the delisting | ConEd, TVA, the California midstream program (PG&E, SCE, SDG&E), SWEPCO, MidAmerican, El Paso Electric, Xcel Energy Texas |
| Fixed grace period | V5.0 products accepted for a set window, usually to year-end | Xcel Energy (CO, MN), Rocky Mountain Power, Idaho Power, Georgia Power, NYSEG and RG&E, Efficiency Vermont (one month) |
| Open-ended | V5.0 accepted indefinitely, or any DLC version within a range | Duke Energy (Carolinas, Indiana, Kentucky), FirstEnergy PA (current or prior DLC version), JCP&L, AEP Texas and CenterPoint Houston (DLC 3.0 or later under the Texas TRM) |
| Not tied to DLC | DLC listing not required, so the delisting changed nothing | Puget Sound Energy, NIPSCO, Evergy, Ameren Missouri, Tampa Electric, NV Energy |
In the counts above, grandfathering and "not tied to DLC" responses were recorded as no extension, because those programs didn't extend V5.0 eligibility. For a contractor with V5.0 product already on a job, though, several of them were far more forgiving than a strict cutover.
Patterns worth remembering
| Region | Programs | No extension | No clear answer | Extension |
|---|---|---|---|---|
| South | 35 | 40% | 17% | 43% |
| West | 29 | 38% | 14% | 48% |
| Northeast | 23 | 30% | 35% | 35% |
| Midwest | 28 | 29% | 25% | 46% |
| Canada | 5 | 20% | 0% | 80% |
Responses from 120 utility programs contacted by Encentiv Energy in 2022. US regions follow US Census regions.
Refusals were most common in the South and West. About 40% of Southern programs and 38% of Western programs said no extension, compared with about 30% in the Northeast and Midwest. The Northeast stands out differently: a third of its programs never gave a clear answer. Counting those as no extension, as a contractor would have to, the Northeast had the lowest odds of a grace period.
Program years set the end dates. Of the 54 extensions, 25 ended on December 31, 2022. Entergy Texas ended its grace period on November 30, the last day of its program year. PECO and PPL, whose program year runs June through May, kept V5.0 eligible through May 31, 2023, because the delisting landed after their year had already started.
Some extensions ran much longer than announced. Alliant and Black Hills said they'd reevaluate at year-end. Others kept V5.0 well into 2023: Energy Trust of Oregon to January, Ameren Illinois to October 31, and DTE and Focus on Energy through December 31, 2023.
Many policies were never published. A lot of what we learned came from one-on-one emails with program staff, not from program websites. That made the policies hard to verify and easy to miss.
What to expect for V6.0
Since July 1, 2026, DLC has listed all new and updated products under V6.0. V5.1 products that haven't been requalified will be delisted on December 15, 2026.
If 2022 is a guide, here's what to plan for:
- Some programs are moving early. BGE, Pepco, Delmarva Power and SMECO have told us they'll require V6.0 starting December 1, 2026, two weeks before the delisting. Don't assume every program will wait for DLC's date.
- Some programs may keep paying on V5.1 into 2027. Last time, nearly half of the programs we reached offered an extension, most of them running to the end of the program year. That doesn't mean they'll do the same this time.
- Fiscal years may shape the timing. Many programs run on a fiscal year that doesn't end in December. Some may line their switch up with their own year end, and others may not. Pennsylvania programs' fiscal years end in May, for example. In 2022, PECO and PPL kept V5.0 eligible through May 31, 2023.
- Watch the new program documents in January and February. Programs whose fiscal year ends in December publish their new program designs early in the year. Those documents may spell out a V6.0 policy, or may not address it at all, so check each one as it comes out.
- Silence isn't a grace period. In 2022, one in five programs never gave a clear answer. In the Northeast it was a third. Without a published policy, plan on V6.0 being required.
For manufacturers, the practical advice is the same as 2022: requalify the products that matter before December 15, and check eligibility program by program rather than assuming a grace period.
How we're tracking it
We're doing what we did in 2022: contacting programs directly, recording each one's DLC version policy, and keeping track of which products each program will pay on.
- Every product's DLC version. UtilityGenius records the QPL version each product is listed under, so you can see which of your products are still on V5.1 and need requalifying.
- Program by program. In 2022, products under both V5.0 and V5.1 stayed in our rebate tools for each program until that program's grace period ended. Programs without an extension showed V5.0 products as not eligible. We'll handle V5.1 and V6.0 the same way.
- Available in our tools. As programs publish or confirm their V6.0 policies, we'll make that information available in UtilityGenius and our rebate tools, so you can see which DLC versions each program accepts.
If you're hearing something different from a program in the field, tell us. Some of the most useful policy details in 2022 came from customers.
