Ohio’s Senate Bill 103, which cleared the Senate 31 to 0 last October, has been signed by Governor DeWine and took effect March 20, 2026. Industrial energy and procurement teams in Ohio now have a concrete legal framework to reference when negotiating natural gas service agreements.
The final version of SB 103 does what the Senate-passed version promised but adds specific thresholds and procedural guardrails that procurement and legal teams need to understand before approaching a utility about an alternative arrangement. The law is not self-executing. It requires a natural gas company to apply to the Public Utilities Commission of Ohio for an approved alternative rate plan before any commercial agreement with a large load customer can take effect.
What the Final Bill Requires: Eligibility, Process, and Customer Protections
Under SB 103, a “large load customer” is defined in statute as any customer consuming more than 1,200,000 Mcf of natural gas in a prior, current, or projected twelve-month period. That threshold is higher than many industrial users reach, positioning the framework primarily for data centers, large-scale manufacturing, and other high-consumption facilities. The natural gas company must already hold an approved infrastructure development rider before it can apply to PUCO for an alternative rate plan.
The customer protections written into the final bill are explicit. Any costs associated with the alternative rate plan or related commercial agreements cannot be recovered, directly or indirectly, from other customers. The law also requires a monthly cost credit mechanism to compensate existing ratepayers for the large load customer’s use of shared gas infrastructure. A commercial agreement filed with PUCO is automatically approved within ninety days unless the commission affirmatively acts to suspend it. The same ninety-day deemed-approval window applies to the alternative rate plan application itself.
Ohio’s Mandatory Rate Case Filing Requirement: What It Means for Utilities and Industrial Buyers
The signed bill includes a provision that received less attention during the legislative debate: natural gas companies serving 250,000 or more customers must file a rate case with PUCO by December 31, 2029, and at least every three years after that. That mandatory cadence is a meaningful change for industrial buyers who have historically operated under rate structures that went years without formal review. More frequent rate cases create both risk and opportunity for large energy consumers negotiating long-term supply arrangements.
Ohio remains among the top ten natural gas-consuming states in the country, according to the U.S. Energy Information Administration (EIA), driven by its manufacturing base and a growing number of high-demand facilities tied to logistics and AI data operations. SB 103 gives Ohio utilities a legal pathway to compete for that industrial load with contract structures that neighboring states, including Pennsylvania and Indiana, have explored through separate mechanisms. For procurement teams evaluating Ohio facility siting or energy contract renewals, the law is now operative and worth reviewing against existing agreements.