Last reviewed: 25 September 2026. From 1 April 2026, FSSAI licences and registrations are perpetual and inspections are risk-based — driven by your compliance history, testing results and audit outcomes instead of a fixed calendar. The change comes from the Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026, published in the Gazette on 10 March 2026 and put into operation by FSSAI’s implementation order of 13 March 2026, with effect from 1 April 2026. That is a genuine relief and a quiet trap: there is no renewal date to force an annual clean-up any more, so a food business that drifts accumulates defaults silently until an inspection, a buyer audit or a bank appraisal surfaces them all at once. This is the complete post-licence obligation stack for FY 2026-27, with the dates that still matter.
The obligation stack, in one table
| Obligation | Who | When |
|---|---|---|
| Annual licence/registration fee on FoSCoS | Every FBO | Every year, in advance — calendar it against your licence anniversary; missing it triggers deemed suspension |
| Form D1 annual return | Manufacturers (incl. repackers/relabellers), importers | 31 May for the preceding FY |
| Form D2 half-yearly return | Milk and milk-product units | 31 October and 30 April |
| Schedule 4 hygiene conditions | Every FBO (part varies by category) | Continuous; inspector's checklist |
| Product testing at an accredited lab | Manufacturers | At least once every six months |
| FoSTaC-certified supervisors | Licensed FBOs | One per 25 food handlers; certificates refresh two-yearly |
| Licence + Food Safety Display Board at premises | Every FBO | Continuous |
| FoSCoS modification for changes (premises, products, layout, responsible persons) | Every FBO | Before/promptly on change — operating outside the licensed scope is a violation |
| Labelling per the Labelling & Display Regulations | Manufacturers, packers, e-commerce sellers | Every SKU, every revision |
Annual fee by tier
| Tier | Turnover band (from 1 April 2026) | Annual fee |
|---|---|---|
| Basic Registration | Up to ₹1.5 crore | ₹100 a year |
| State Licence | Above ₹1.5 crore up to ₹50 crore | ₹2,000 to ₹5,000 a year, depending on the kind of business and capacity |
| Central Licence | Above ₹50 crore, and specified categories such as importers regardless of turnover | ₹7,500 a year |
Fees are payable on FoSCoS; confirm the figure shown against your own licence before paying, as the category-wise State fee depends on the kind of business recorded.
The annual-fee cliff deserves its own paragraph
Under the renewal regime, forgetting attracted a late fee. Under the perpetual regime, non-payment leads to the licence being treated as suspended — and a business operating on a suspended licence is, for enforcement purposes, operating without one, which is the FSS Act's most serious everyday exposure (prosecution territory, not penalty territory — see our guide to FSSAI notices and penalties). The fix costs nothing: put the fee on the same compliance calendar as your GST and TDS dates. We build exactly that calendar for clients.
Penalties for common defaults
| Default | Provision | Maximum consequence |
|---|---|---|
| Carrying on business without a valid licence (including a suspended one) | Section 63, FSS Act | Imprisonment up to six months and fine up to ₹5 lakh |
| Late filing of Form D1 / D2 | Licensing and Registration Regulations | ₹100 per day of delay |
| Sub-standard food | Section 51 | Penalty up to ₹5 lakh |
| Misbranded food (including labelling defects) | Section 52 | Penalty up to ₹3 lakh |
| Unhygienic or unsanitary processing or manufacture | Section 56 | Penalty up to ₹1 lakh |
| Failure to comply with a Food Safety Officer’s directions | Section 55 | Penalty up to ₹2 lakh |
| Other contraventions with no specific penalty | Section 58 | Penalty up to ₹2 lakh |
Crossing a threshold mid-year
Worked example. A Thane cloud-kitchen company starts FY 2026-27 with ₹1.2 crore trailing turnover on Basic Registration (₹100 a year). By November the run-rate crosses ₹1.5 crore. The band is turnover-linked: it must move to a State licence on FoSCoS — new conditions (Schedule 4 Part V for catering, FoSTaC coverage, display boards) attach from the upgrade. Migration at the April 2026 switchover was automatic and free; crossing a band afterwards is the operator's job to catch. A quarterly turnover-vs-band check is the simplest insurance there is. The papers needed for the upgrade are listed in our FSSAI documents checklist.
Food importers entering India
A business importing food into India needs a Central Licence whatever its turnover, alongside an Importer-Exporter Code (IEC) from DGFT; it also files the annual Form D1 as an importer. Foreign food brands setting up an Indian subsidiary to import and distribute should plan the licence, IEC and GST registration together — our foreign subsidiary accounting and FEMA compliance service covers the entity-side filings.
What risk-based inspection means for you
Since April 2026 the regulator prioritises inspections using compliance history, lab results and third-party audit outcomes. In practice: filed returns, paid fees, six-monthly test reports on file and a satisfactory audit push you down the priority list; arrears and failed samples pull inspectors in. Your compliance file is now, quite literally, your inspection schedule.
Common gaps we find in the first review
- Annual fee unpaid because "the licence is permanent now".
- Menu, products or premises changed years ago — FoSCoS never updated.
- No test reports on file, or reports older than six months.
- FoSTaC certificates expired, or headcount grew past the 1-per-25 ratio.
- New outlets running on the head-office licence instead of their own registration.
Frequently asked questions
Is FSSAI licence renewal really abolished?
Yes — licences and registrations issued or migrated from 1 April 2026 are perpetual, so there is no renewal application or renewal fee. The annual licence/registration fee itself continues, and non-payment leads to the licence being treated as suspended until regularised.
What happens if I miss the annual fee?
The licence is treated as suspended. Trading on a suspended licence is treated like trading without one — which under the FSS Act carries prosecution exposure, not just a monetary penalty. Pay on FoSCoS, keep the receipt, and calendar the next one.
Does a restaurant need six-monthly lab testing?
The six-monthly product-testing condition is aimed at manufacturers. Food-service businesses carry their own Schedule 4 Part V obligations — water potability testing, hygiene records, medical fitness of handlers — so a restaurant is not test-free, it is tested differently.
When must I modify my FSSAI licence?
Whenever the facts on the licence stop matching reality — address or layout changes, new product categories or kinds of business, changes in partners/directors/authorised persons, added outlets or units. Each outlet or unit needs its own registration or licence; modifications go through FoSCoS.
How does FSSAI decide whom to inspect now?
Under the risk-based framework operational from April 2026, inspection priority follows your compliance history, testing results and audit outcomes. Clean returns, paid fees and satisfactory audits reduce inspection frequency; defaults and failed samples increase it.
What does a CA firm do in FSSAI compliance?
We run the licence-wise compliance calendar (fees, D1/D2, testing, FoSTaC refresh), reconcile FSSAI filings with GST and books, keep FoSCoS records matching the business as it actually operates, and prepare the response file when a notice or inspection arrives.
We set up the FSSAI compliance calendar alongside your GST and TDS dates, keep FoSCoS current, and review the record before inspectors or buyers do.
FSSAI Registration & Compliance Virtual CFO Services Talk to usThis article is general information as on 25 September 2026, based on the FSS Act, 2006 and the Licensing and Registration Amendment Regulations, 2026 (effective 1 April 2026). Obligations vary by category and state practice; confirm the current position on FoSCoS or take advice before acting.