The draft "rules for registration of small-scale embedded generation" (PDF) leave no room for exceptions. Any form of power generator of any size will have to formally registered, "eg PV/wind/biogas/diesel/fuel cell, generation".
The rules apply both to off-grid systems, with no connection to the national electricity system, and systems connected to the grid in any way – whether or not they are intended to feed electricity back into the grid.
Failure to register may be unlawful all by itself, but will also preclude the user from being connected to "the distribution system" of electricity, or a municipal grid.
To complicate matters, it is only possible to register by way of an electricity distributor – either Eskom or a municipality – even for generators that are not due to be connected to such a distributor's system.
The rules apply to all generators of less than 1MW; above that level, the law requires the same sort of licensing as for a full-blown power station.
The rules also appear to specifically include the kind of co-generation many companies rushed to install during and after the electricity blackouts that started in 2008.
"You need to register no matter what," says specialist energy law consultant Sue Röhrs of Rohrslaw. "If you are not grid-connected at all, if you are rich and have your own facility up on a hill, if you are connected to the grid, whether you are wheeling through the grid or not," she says, referring to the process where one a private electricity supplier sends power to a customer using the public grid.
It is simpler to say that the only people who do not need to register are those who only buy electricity from a municipality or directly from Eskom, says Röhrs.
"Even if you have a backup generator connected up, you need to register."
The rules are open for public comment until the end of May. They are likely to change before they go into force, says Röhrs.
Whether or not the registration requirement will be removed is unclear.