FSSAI Registration and Licence 2026: Rs 1.5 Crore Limit and Perpetual Validity
Licences | RegisCorp Team
Checked on 23 October 2026. If you make, pack, store, sell, serve or deliver food in India, you need an FSSAI registration or licence. That has always been true. What changed this year is how you decide which one. From 1 April 2026 the turnover limit for the simplest tier, basic registration, rose from Rs 12 lakh to Rs 1.5 crore. The state licence band now runs from Rs 1.5 crore to Rs 50 crore, and the central licence starts above Rs 50 crore. New licences and registrations also no longer expire. This post explains the new rules, which tier you belong to, the fees, the documents, the annual obligations that did not go away, the penalties for getting it wrong, and what we could not confirm.
RegisCorp Consultancy LLP is a digital-first legal and compliance firm in Kota, Rajasthan, working with businesses across India. We write these guides so you can check the rules before you pay anyone, including us.
Key takeaways
- The basic registration limit is now Rs 1.5 crore of annual turnover. It was Rs 12 lakh. A business that was paying for a state licence at Rs 80 lakh turnover can now sit under the Rs 100-a-year registration, if its activity allows.
- The state licence band is Rs 1.5 crore to Rs 50 crore, and the central licence starts above Rs 50 crore. The old band was Rs 12 lakh to Rs 20 crore, with the central licence above Rs 20 crore.
- Licences and registrations are now perpetual. They remain valid unless suspended, cancelled or surrendered. There is no renewal application, but the annual fee and the returns still have to be paid and filed, or the licence can be suspended.
- Turnover is not the only test. Importers, e-commerce operators, trader-exporters, 100% export-oriented units, five-star and above hotels and some specialised manufacturing activities need a central licence whatever the turnover.
- Existing holders migrate without a fresh approval. The official FAQs say the move to the new thresholds is automatic on the basis of self-declaration, there is no migration fee, and the licence number stays the same.
- The annual fee is the new renewal. Registration is about Rs 100 a year, a state licence Rs 2,000 to Rs 5,000, and a central licence about Rs 7,500. Non-payment can lead to suspension, and operating on a suspended licence counts as operating without one.
- Operating without a licence is a criminal matter. Section 63 of the Food Safety and Standards Act is reported to allow imprisonment up to six months and a fine up to Rs 5 lakh, though one source says Rs 10 lakh.
- Dates still bite. Manufacturers, repackers and importers file Form D1 by 31 May. Milk and milk-product units file Form D2 on 31 October and 30 April, which means the next D2 date is 31 October 2026.
- Online sellers are the confusing case. Marketplaces and e-commerce operators need a central licence. Whether each individual seller also needs one, or only the licence for its own category, is stated differently by different consultancies. We explain what we could and could not confirm below.
The key numbers and dates in one place
| Item | Rule or figure | Source or status |
|---|---|---|
| Basic registration | Annual turnover up to Rs 1.5 crore (was Rs 12 lakh) | Several sources; FSSAI order dated 13 March 2026 |
| State licence | Above Rs 1.5 crore up to Rs 50 crore (was Rs 12 lakh to Rs 20 crore) | Same |
| Central licence | Above Rs 50 crore (was above Rs 20 crore), or by activity | Same |
| Amendment regulations | Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026, gazetted 10 March 2026 | Secondary sources; Gazette not read |
| Effective date | 1 April 2026 | Same |
| Validity | Perpetual for registrations and licences issued on or after 1 April 2026, unless suspended, cancelled or surrendered | FAQs reproduced by TaxGuru |
| Annual fee, registration | About Rs 100 | Consultancy articles |
| Annual fee, state licence | Rs 2,000 to Rs 5,000 depending on business type and size | Same |
| Annual fee, central licence | About Rs 7,500 | Same |
| Form D1 (annual return) | 31 May, for manufacturers, repackers, relabellers and importers; Rs 100 a day late | Consultancy articles |
| Form D2 (half-yearly return) | 31 October and 30 April, for milk and milk-product units | One consultancy checklist |
| Licensing authority timelines | Registration about 30 days; licence about 60 days from application ID | One consultancy article |
| Section 63 penalty | Imprisonment up to six months and fine up to Rs 5 lakh (one source says Rs 10 lakh) | Conflicting secondary sources |
| Closure of a business | 30 days' notice and surrender of the certificate; fee not refunded | One article; unverified |
What changed on 1 April 2026
The sequence matters, because sources mix up the documents.
- 10 March 2026. The Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026 were published in the Gazette. They introduced perpetual validity of licences and registrations, a revised definition for small operators, and rules on suspension and closure.
- 13 March 2026. FSSAI issued an order (file number RCD-01002/1/2021-Regulatory-FSSAI-Part(1)) directing licensing authorities to apply the revised turnover thresholds from 1 April 2026.
- 27 March 2026. FSSAI sent a covering letter with a set of FAQs. The FAQs are the clearest official guidance we found, and we rely on them for the transition rules.
- 1 April 2026. The thresholds and perpetual validity took effect for applications on or after that date. Applications pending on 1 April 2026 continued under the old rules, according to one article.
- June 2026. A second amendment reportedly added record-keeping rules for manufacturers (daily records of raw material used and output) and stock rotation rules (first-in-first-out or first-expired-first-out) at the manufacturing stage. One article says retailers and non-manufacturers are exempt. We could not confirm the date from a primary source.
There are five headline changes.
- Perpetual validity. No more one-to-five-year licences with a renewal.
- Higher thresholds. About 98% of food businesses are said to fall under state authorities now, which is the official reasoning for the move.
- Deemed registration of street vendors. Vendors registered under the Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014 are treated as registered under the food law, with no separate application or fee. They must still meet the hygiene conditions in Schedule 4.
- Suspension and closure rules. Unpaid annual fees or unfiled returns can lead to suspension. A business closing down is expected to give notice and surrender its certificate.
- Risk-based inspection. A computer-assisted system weights compliance history, testing results and audits. Businesses with good records are inspected less. High-risk categories such as dairy, meat, packaged drinking water, infant food and fishery products stay under closer watch whatever their turnover.
How to decide: registration, state licence or central licence
The decision has three steps. Do them in this order.
Step 1: is your activity on the "central regardless of turnover" list?
Whatever your turnover, the FoSCoS matrix is reported to require a central licence for:
- Importers of food.
- E-commerce operators (this refers to the platform running a food marketplace, not an ordinary seller listing on one).
- Trader or merchant exporters.
- 100% export-oriented units.
- Hotels with a five-star or higher rating.
- Certain specialised manufacturing or processing activities. One guide gives health supplements as an example.
If you are on this list, stop. You need a central licence and the turnover bands do not matter.
Step 2: is your activity a high-risk category?
High-risk categories such as dairy, meat processing, packaged drinking water, infant food and fish products stay under mandatory compliance, with possible third-party audits and targeted inspections, even if a business is small. Check the activity-specific criteria on FoSCoS before you assume the turnover rule alone decides your tier. Several guides state that "activity-specific criteria can override turnover".
Step 3: apply the turnover band
If neither step 1 nor step 2 applies, use turnover.
| Annual turnover | Tier | Form | Annual fee (reported) |
|---|---|---|---|
| Up to Rs 1.5 crore | Basic registration | Form A | About Rs 100 |
| Above Rs 1.5 crore, up to Rs 50 crore | State licence | Form B | Rs 2,000 to Rs 5,000 |
| Above Rs 50 crore | Central licence | Form B | About Rs 7,500 |
How turnover is counted
We did not find an official rule in the sources we could open on how turnover is measured when a business has several outlets, a mix of food and non-food sales, or a mix of manufacturing and trading. The licence is premises-based, so each premises or outlet generally needs its own registration or licence. Your adviser should tell you how turnover is aggregated for your structure before you choose a tier. A wrong tier is a compliance defect in its own right.
The caution about "going down" a tier
A business that has been paying for a state licence can now fall into the registration band, and the new rules allow a downgrade. That does not mean you should downgrade at once. The cheaper tier carries different conditions, and the inspection treatment differs. If your turnover is close to Rs 1.5 crore and growing, moving down and then up in a year may cost more in effort than the Rs 2,000 to Rs 5,000 it saves.
Perpetual validity: what it means and what it does not
For decades, an FSSAI licence ran for one to five years, and you renewed it, often paying a late fee if you forgot. That system is gone for anything issued on or after 1 April 2026. A licence now "remains valid unless suspended, cancelled or surrendered", in the language of the official FAQs.
What stays
- The annual fee must be paid. The FAQs say a business may pay for any number of years in one go, at any time in the year.
- Returns must be filed where they apply (Form D1 and D2).
- Hygiene and safety conditions in Schedule 4 and the licence conditions continue.
- Modifications are needed when facts change: address, product category, installed capacity, constitution, or the responsible person.
- Inspections continue, on a risk-based schedule.
What goes
- The renewal application.
- The renewal date, which for many small operators was the only reminder they had.
- For licences issued after 1 April 2026, the choice of a one-to-five-year term.
The danger nobody advertises
One law firm commentary makes the point well: perpetual validity removes the expiry date, it does not remove the regulator. Without a renewal date, a business can drift for years with an outdated address, a changed product list or an unpaid fee. The first sign is a suspension, and by then you may be operating without a valid licence. Under Section 63, that is the offence.
Licences issued before 1 April 2026
The sources are not fully consistent here. One article says licences expiring on or before 31 March 2026 follow the old renewal process. The official FAQ we read says migration to the new thresholds is automatic by self-declaration. Neither source gives a complete rule for a licence that was issued in 2024 with a three-year term. Look at your certificate and the FoSCoS dashboard. If it shows an expiry date in the future, confirm with the licensing authority whether it has been converted before you ignore that date.
Fee adjustment on migration
The official FAQs say the fee already paid for a state licence is adjusted against the annual registration fee if you become eligible for registration. One law-firm article says there are no credits when you move to a lower category. The FAQs are the better source, and we have used them, but this point deserves a check with the authority before you rely on it.
Fees: what you pay, and how it compares with the old regime
The government fee depends on the tier. It is charged per year.
| Tier | Annual fee | Comment |
|---|---|---|
| Basic registration | About Rs 100 | One article calls it a one-time perpetual fee, another says a yearly fee. Check the FoSCoS fee screen. |
| State licence | Rs 2,000 to Rs 5,000 | Depends on the nature and scale of the business. |
| Central licence | About Rs 7,500 | Some categories carry different fees. |
| Modification | Equal to a one-year licence fee, for some changes | One article. Threshold-driven migration has no modification fee. |
Private consultants charge a service fee on top. We do not quote those prices here, because they vary and we would be guessing.
A worked example: what the new bands save
Here are two businesses, and what the threshold change does to their yearly government fees.
- Business A is a wholesaler with Rs 80 lakh turnover, with no central-licence activity. Under the old bands, it needed a state licence (turnover above Rs 12 lakh) at Rs 2,000 to Rs 5,000 a year. Under the new bands, it needs only a registration at about Rs 100 a year. The saving is Rs 1,900 to Rs 4,900 a year, or Rs 9,500 to Rs 24,500 over five years.
- Business B is a manufacturer with Rs 30 crore turnover, again with no activity that forces a central licence. Under the old bands (above Rs 20 crore), it needed a central licence at about Rs 7,500 a year. Under the new bands, it needs a state licence at Rs 2,000 to Rs 5,000 a year. The saving is Rs 2,500 to Rs 5,500 a year, or Rs 12,500 to Rs 27,500 over five years.
The saving is real but modest. The bigger effect is on effort. A Rs 80 lakh wholesaler moves from a licensing process with a premises inspection to a registration issued without a pre-inspection.
Documents you need
Lists differ between sources, so use this as a working checklist and confirm on the FoSCoS screen for your category.
For every tier
- Photograph and government photo ID of the applicant or authorised signatory (Aadhaar, PAN or passport).
- Proof of the business constitution: a proprietorship declaration, partnership deed, LLP agreement, or the incorporation documents of a company. GST registration or Udyam registration is accepted as supporting proof of the business in some guides.
- Proof of premises: an ownership document, rent agreement or a no-objection letter from the owner.
- The list of food products or the menu.
- A Food Safety Management System (FSMS) plan, where the form requires it.
Additionally for a state or central licence (Form B)
- Details of directors or partners, and an authority letter naming a responsible person and an alternate (this is the "Form IX nomination" in some guides).
- A layout plan of the premises and a list of equipment and machinery for manufacturing and processing units.
- A water analysis report from a recognised laboratory for manufacturing units.
- Sources of raw material for manufacturers.
- For importers: the Import Export Code and details of countries of origin and product specifications. See our guide to the Import Export Code for how to get that first.
What to prepare in advance
Rental premises are the single largest cause of delay in our experience. A rent agreement that does not allow commercial use, or a landlord who refuses to sign a no-objection letter, will stall the application. Settle that before you pay for anything.
The application, step by step
All applications go through the Food Licensing and Registration System, FoSCoS, run by FSSAI.
- Choose the category. On the portal, pick "Apply for licence or registration", then the state, the kind of business and the turnover.
- Select the form. Form A for registration, Form B for a state or central licence.
- Fill in the application with the business details, product categories and the proposed premises.
- Upload the documents listed above.
- Pay the fee. The sources disagree on whether you choose a term of years or a single payment. Under the new rules, you may pay for any number of years in one go.
- Note the application number and track it from your login.
- Answer queries quickly. If the authority asks for more information and you do not reply within the stated time, the application can be rejected.
- Inspection, where ordered. A registration is issued without pre-inspection in most cases, but the authority can order one. Licence applications may involve a premises inspection for hygiene.
- Download the certificate from the issued licences section after approval.
How long it takes
The only timeline figures we found come from two consultancy articles and are not from the regulator.
| Stage | Reported time |
|---|---|
| Registration, if inspection is ordered | About 30 days |
| Licence application | About 60 days from the application ID |
| Authority to ask for more information | Within about 15 days |
| Applicant to reply | About 30 days |
| Inspection for registration, when ordered | Within about 7 days |
Treat these as typical and plan for slippage. If you are launching a product on a fixed date, start the application at least three months before.
Why applications fail
- The wrong category. A manufacturer who selects "trader" will be asked to start again.
- Missing documents. The commonest are the rent agreement and the water analysis report.
- A premises that is not ready. The hygiene inspection checks conditions in Schedule 4, such as clean water supply, drainage, pest control and separate storage.
- A responsible person who is not named. A licence application without a nominated person is incomplete.
After the licence: the compliance calendar
Perpetual validity has made many small food businesses relax. These are the obligations that remain.
| Item | Who | When |
|---|---|---|
| Annual fee on FoSCoS | Every licence or registration holder | Each year, in advance, or pay for several years together |
| Form D1 annual return | Manufacturers, repackers, relabellers and importers | By 31 May for the previous financial year; Rs 100 per day late |
| Form D2 half-yearly return | Milk and milk-product units | 31 October and 30 April |
| Schedule 4 hygiene conditions | All holders (part varies by category) | Continuous |
| Product testing at an accredited lab | Manufacturers | At least once every six months, per one checklist |
| Trained food safety supervisor (FoSTaC) | Licensed businesses | One per 25 food handlers; certificate refresh every two years, per one checklist |
| Display of licence and Food Safety Display Board | Every holder | Continuous |
| Changes on FoSCoS | Every holder | Promptly, when address, products, layout or responsible person change |
| Labelling under the labelling and display regulations | Manufacturers, packers, e-commerce sellers | Every product and every revision |
| Daily raw-material and output records; stock rotation | Manufacturers | Continuous, reported June 2026 rule |
The date that is coming up
If you run a dairy or a milk-product unit, Form D2 for the half-year April to September 2026 is due on 31 October 2026. Do not rely on a reminder from the portal. Check your FoSCoS dashboard this week.
The Form D1 late fee
One guide says the late fee of Rs 100 per day is capped at five times the annual licence fee. We could not confirm the cap in a primary source. The practical advice is simple: file by 31 May and attach no late-fee risk to it.
Penalties and consequences
The Food Safety and Standards Act, 2006 spreads penalties across several sections. One consultancy checklist summarises them as follows. We have not read the sections themselves.
| Default | Section | Maximum consequence (as reported) |
|---|---|---|
| Operating without a valid licence, including a suspended one | 63 | Imprisonment up to six months and fine up to Rs 5 lakh (one source says Rs 10 lakh) |
| Sub-standard food | 51 | Up to Rs 5 lakh |
| Misbranded food, including labelling defects | 52 | Up to Rs 3 lakh |
| Unhygienic processing or manufacture | 56 | Up to Rs 1 lakh |
| Non-compliance with a Food Safety Officer's directions | 55 | Up to Rs 2 lakh |
| Other contraventions with no specific penalty | 58 | Up to Rs 2 lakh |
| Late Form D1 or D2 | Licensing regulations | Rs 100 per day |
Wrong tier is also a default
One article gives the example of a Rs 65 crore business holding only a state licence. Operating in the wrong category counts as non-compliance. With the new bands, a business that grows from Rs 45 crore to Rs 55 crore must remember to move up.
What an inspection looks for
Food safety officers check the licence on display, the condition of the premises, water and drainage, pest control, personal hygiene of handlers, temperature records, labels, expiry dates and supplier invoices. The first three are the ones that fail most often in small premises.
Who needs what: five common business types
A home baker or home kitchen
A home baker with Rs 30 lakh turnover generally falls into basic registration. The registration is for the premises where food is made, so a home kitchen used commercially needs it. Some marketplaces ask for packaged, labelled products, which means labels that meet the rules (name, ingredients, net quantity, date, licence number, vegetarian or non-vegetarian mark and a few other items). Selling home-made food through delivery apps and social media is more common than through large marketplaces.
A restaurant, cafe or cloud kitchen
Turnover decides the tier: registration up to Rs 1.5 crore, a state licence above, a central licence for very large caterers. A cloud kitchen is a separate food business and needs its own registration or licence. If a restaurant is a five-star or higher hotel, a central licence applies whatever the turnover.
A trader, wholesaler or retailer
The trade tier follows turnover, subject to the central list. Repacking into new sizes with your own labels counts as manufacturing. A kirana store with Rs 90 lakh turnover now needs only a registration.
A manufacturer, repacker or relabeller
The turnover bands apply, but activity-specific rules can push you into a state or central licence. Repackers and relabellers are treated as manufacturers. A brand owner using a contract manufacturer needs its own registration or licence in addition to the manufacturer's.
An online seller
This is the area where articles disagree, so we set out what we found.
- The platform that runs a food marketplace is an e-commerce operator and needs a central licence. We found that stated consistently.
- It must verify and display each seller's FSSAI number before listing, and remove sellers whose licence has lapsed.
- One consultancy states that every online seller needs a central licence "regardless of turnover". Another says each seller needs its own licence of the right category and that a listing-only platform may not need one. A third says sellers should check separately whether their activity needs registration, a state licence or a central licence.
- We could not find a primary source that settles whether an ordinary seller on a marketplace needs a central licence. Until you have a written answer from the licensing authority or FoSCoS, do not assume either way.
- Delivered food is reported to need at least 30% of its shelf life remaining, or at least 45 days before expiry, whichever is greater, per one consultancy citing an FSSAI advisory.
- Fulfilment centres matter because licences are premises-based. If your stock sits in a marketplace warehouse, ask the marketplace and your licensing authority whether that address needs to appear on your licence.
If you plan to sell packaged food on Amazon, Flipkart or Meesho, read our post on how to sell on Amazon India, Flipkart and Meesho for the account side, and our GST registration decision guide for the tax side.
How FSSAI fits with the rest of your registrations
FSSAI is a licence for food safety. It is not a business registration, a tax registration or an MSME registration. Its relationship to the others is simple:
- GST is a tax registration. Many food items are exempt or low-rated, but your GST need depends on turnover and on whether you sell across states or through e-commerce. See the GST guide linked above.
- Udyam is an MSME classification. It is accepted as supporting proof of a business in some FSSAI guides, and it matters for payment terms, as we explain in the Udyam and 45-day payment rule post.
- Trade mark protects your brand name. A food brand with an FSSAI licence and no trade mark is exposed. See Trademark Registration in India.
- Shop and establishment, local body and fire permissions vary by state and city and are separate from FSSAI.
- Import Export Code is needed for food imports and exports, as the next post in this series explains.
A worked example: a home baker who grows
Here is how the rules apply across three years. The numbers are illustrative.
- Year 1. Meera bakes cakes at home and sells through social media and local orders. Turnover Rs 12 lakh. She applies for basic registration on FoSCoS (Form A), pays about Rs 100, uploads her photo, ID, address proof and product list, and receives her registration number. She prints it on her labels.
- Year 2. She starts supplying two cafes. Turnover Rs 48 lakh. She stays under the Rs 1.5 crore limit, so she remains on registration. Under the old rules, she would have crossed Rs 12 lakh in Year 1 and needed a state licence at Rs 2,000 to Rs 5,000 a year.
- Year 3. She rents a small kitchen unit and hires four staff. Turnover Rs 2.1 crore. She has crossed Rs 1.5 crore, so she applies on FoSCoS for a state licence (Form B) for the new premises. She submits a layout plan, an equipment list, a water analysis report, a nomination of a responsible person and a FSMS plan, and pays the fee shown, within the Rs 2,000 to Rs 5,000 range. She trains a supervisor under FoSTaC.
Total government fees over three years, using the reported figures, are about Rs 100 in Year 1, about Rs 100 in Year 2 and between Rs 2,000 and Rs 5,000 in Year 3. A key point in this story: nothing expires. If Meera forgets the annual fee in Year 4, the licence can be suspended, and from that day she is exposed under Section 63.
A second worked example: the cost of waiting
A small food business sells packed snacks across two states and has been operating without a registration for 14 months. The owner reasons that the penalty is "only" up to Rs 5 lakh and no officer has called. Consider what the owner faces:
- The registration fee is about Rs 100. Even a state licence is Rs 2,000 to Rs 5,000.
- A single inspection can find the missing licence, and Section 63 allows imprisonment as well as a fine.
- A marketplace or retailer will ask for the licence number. Without it, the listing or supply order can disappear.
- Insurers and lenders also ask. A claim after a food-poisoning complaint is much harder if the business has no licence.
The expected cost of registering is a few hundred rupees and a few hours. The expected cost of not registering is unbounded. We have not seen a case where a business regretted registering early.
Mistakes that cost money
- Staying on the old tier out of habit. If your turnover is under Rs 1.5 crore and your activity allows it, check whether you are overpaying.
- Forgetting the annual fee because nothing expires. Diarise a date.
- Moving to a lower tier without a plan. If you are growing, you may be back in a year.
- Ignoring the activity list. Importers, e-commerce operators and some manufacturers need a central licence regardless of turnover.
- One licence for several premises. The licence is premises-based.
- Putting a wrong or expired licence number on a label. That is a labelling defect.
- Not filing Form D1 or D2. Late returns cost Rs 100 a day and can lead to suspension.
- Closing the business and leaving the licence. Surrender it, because the annual fee and return obligations can continue.
- Paying an agent without getting the application number. Always ask for it, and check it on FoSCoS yourself.
Frequently asked questions
What is the FSSAI registration limit in 2026?
From 1 April 2026, basic registration applies to food businesses with annual turnover up to Rs 1.5 crore. The previous limit was Rs 12 lakh. Importers, e-commerce operators and some other activities need a higher tier whatever the turnover.
What is the turnover limit for a state FSSAI licence?
Above Rs 1.5 crore and up to Rs 50 crore, from 1 April 2026. Before that date the band was Rs 12 lakh to Rs 20 crore.
When do I need a central FSSAI licence?
When annual turnover is above Rs 50 crore, or when your activity is on the central list: importers, e-commerce operators, trader-exporters, 100% export-oriented units, five-star and above hotels and some specialised manufacturing activities.
Does an FSSAI licence still expire?
Not if it was issued on or after 1 April 2026. It stays valid unless suspended, cancelled or surrendered. Older licences with an expiry date should be checked on FoSCoS, because the sources do not fully agree on how they convert.
Do I still pay every year?
Yes. The annual fee is due, and you may pay several years in advance. Non-payment can lead to suspension, and operating on a suspended licence is treated as operating without a licence.
What is the FSSAI fee in 2026?
Reported figures are about Rs 100 a year for registration, Rs 2,000 to Rs 5,000 for a state licence and about Rs 7,500 for a central licence. Check the fee screen on FoSCoS, because one article calls the registration fee a one-time payment.
Can a home-based food business get an FSSAI registration?
Yes. A home kitchen used to make food for sale needs a registration if its turnover is within the basic limit. It still has to meet the hygiene conditions that apply.
Do I need an FSSAI licence to sell food on Amazon or Flipkart?
You need a valid registration or licence to sell food online. The marketplace itself needs a central licence as an e-commerce operator. Whether you, as a seller, need a central licence or only the licence for your own category is stated differently by different consultancies, so ask the licensing authority in writing.
What is the penalty for running a food business without a licence?
Section 63 of the Food Safety and Standards Act is reported to allow imprisonment up to six months and a fine up to Rs 5 lakh. One source says the fine may extend to Rs 10 lakh. We did not read the section.
What is Form D1?
The annual return that manufacturers, repackers, relabellers and importers file by 31 May for the previous financial year. A late return is reported to cost Rs 100 per day.
What is Form D2?
A half-yearly return for milk and milk-product units, due on 31 October and 30 April.
Do street vendors need an FSSAI registration now?
Vendors registered under the Street Vendors Act, 2014 are treated as registered under the food law without a separate application or fee. They must still meet the hygiene conditions that apply.
What happens if my turnover crosses the limit?
You move up a tier. Apply on FoSCoS for the new category and update your documents. The licence number is reported to stay the same when a business changes category because of the new thresholds.
Can I downgrade from a state licence to registration?
The new rules allow movement to the registration tier if your turnover and activity fit. The official FAQs say the migration is automatic on the basis of a self-declaration, with no fee. Check that your activity does not carry a condition that keeps you on a licence.
What if I close the business?
Reports say you must give 30 days' notice and surrender the certificate, and that the fee is not refunded. We could not confirm this from the regulation text, so ask the licensing authority before you close.
Is an FSSAI licence the same as GST registration?
No. FSSAI is a food-safety licence and GST is a tax registration. You may need both, either or neither depending on your turnover and the way you sell.
What to do next
- Open your certificate on FoSCoS and note the tier, the validity shown and the date of the last annual fee.
- Work out your turnover and activity against the three steps above. If you are overpaying for a licence you could replace with a registration, discuss it with your licensing authority or adviser.
- Put the annual fee date in your calendar, along with 31 May (Form D1) and, for dairy units, 31 October and 30 April (Form D2).
- If your address, products or responsible person have changed, update FoSCoS now.
- If you sell online, ask the platform and the licensing authority which licence your category needs, and keep the answer in writing.
If you want help with an FSSAI registration, a licence upgrade, or the other registrations your food business needs, contact RegisCorp.
This post is general information, not legal advice. Rules change, so check your facts with a qualified professional before you act.
Sources and what we could not verify
Sources used
- TaxGuru, FAQs on the Food Safety Licensing and Registration Amendment Regulations, 2026: reproduces the official FAQs, the order of 13 March 2026 and the letter of 27 March 2026. This is the closest we got to a primary source.
- Absolute Veritas, FSSAI new turnover threshold 2026: the order number and date, the thresholds and indicative fees. Published 4 August 2026.
- Just Start, FSSAI updates 2026: the six headline changes, perpetual validity, the Gazette date of 10 March 2026. Published 8 July 2026.
- Somesh Chandak and Associates, FSSAI compliance checklist after licence 2026: post-licence obligations, Form D1 and D2 dates and the penalty table. Reviewed 25 September 2026.
- SetIndiBiz, FSSAI 2026 reforms: the central-licence-regardless list and ONDC seller notes. Updated 8 September 2026.
- Legal500, The FSSAI revolution 2026: the amendment regulation title, perpetual validity and the June 2026 second amendment.
- IndiaLaw, FSSAI 2026 perpetual food licence regime: transition commentary. Published 31 March 2026.
- Tally Solutions, FSSAI licence requirements and Cashfree, FSSAI licence and registration 2026: documents, process steps, timelines. The Cashfree article is dated 19 October 2026.
- Seyecs, FSSAI licence for e-commerce food sellers: the e-commerce position and the shelf-life advisory.
All of these are secondary sources. We did not open the FSSAI site, the Gazette or FoSCoS.
What we could not verify
- The text of the Amendment Regulations, 2026 and the order of 13 March 2026. We relied on commentary and on the FAQs as reproduced by TaxGuru.
- The fee schedule. Registration is called both a yearly fee and a one-time fee in different places, and one article describes a choice of one to five years that conflicts with perpetual validity.
- The amount of the Section 63 fine (Rs 5 lakh in most sources, Rs 10 lakh in one) and the other penalty figures.
- Whether an ordinary seller on an online marketplace needs a central licence. The sources conflict.
- How licences issued before 1 April 2026 with a future expiry date are treated, and the timeline for FoSCoS migration.
- The cap on the Form D1 late fee, the suspension grace period and the closure procedure.
- The June 2026 second amendment on record keeping and stock rotation, which we read about in one article.
- The definition of a petty food business operator in the new regulations.
- How turnover is counted for businesses with several outlets or mixed activities.
- The processing timelines, which come from consultancy articles.
- Any change made by FSSAI after 20 October 2026.