Last reviewed: 1 August 2026. The biggest overhaul of India's food business licensing rules in a decade quietly took effect this year — and many MSMEs are still paying for, and renewing, licenses they no longer need. The Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026, gazetted on 10 March 2026 and operationalised by FSSAI's order dated 13 March 2026, raised the basic registration threshold from ₹12 lakh to ₹1.5 crore of annual turnover and abolished license renewals altogether. If you run a restaurant, cloud kitchen, food brand, trading business or export unit, your FSSAI category may have changed on 1 April 2026 — here is exactly where you now stand.
What changed from 1 April 2026
The amendment rewrote the turnover slabs that decide whether a food business operator (FBO) needs registration, a State license or a Central license. The revised Kind of Business matrix went live on FoSCoS (foscos.fssai.gov.in) on 1 April 2026.
| Category | Until 31 March 2026 | From 1 April 2026 | Annual fee |
|---|---|---|---|
| Basic Registration | Turnover up to ₹12 lakh | Turnover up to ₹1.5 crore | ₹100 |
| State License | ₹12 lakh – ₹20 crore | Above ₹1.5 crore, up to ₹50 crore | ₹2,000–₹5,000 by kind of business (most traders, retailers and caterers ₹2,000; manufacturers ₹3,000–₹5,000 by capacity) |
| Central License | Above ₹20 crore | Above ₹50 crore | ₹7,500 |
The practical effect: a very large share of restaurants, caterers, cloud kitchens, small manufacturers and food traders — anyone between ₹12 lakh and ₹1.5 crore of turnover — has dropped from the State license band into the ₹100-a-year registration band. Street vendors registered under the Street Vendors Act, 2014 are now deemed registered under the food safety law and need no separate FSSAI registration; registration fees already stand waived for hawkers and anganwadi (ICDS) centres.
Perpetual validity — what it actually means
- No renewal applications, ever. A license or registration granted under the regulations now remains valid unless it is suspended, cancelled or voluntarily surrendered. The 1–5 year validity cycle and the renewal window are gone.
- The annual fee survives. Perpetual does not mean free. The yearly license/registration fee must still be paid on FoSCoS — and FoSCoS allows advance payment for multiple years in one go.
- Miss the fee, lose the license. If the annual fee is not paid, the license is deemed suspended, and operating during suspension is unlawful. This replaces the old late-renewal fee mechanics with a sharper cliff — put the fee date in your compliance calendar.
- Closure has a procedure. On shutting the food business, inform the authority and surrender the license within 30 days; no fee refund is admissible on surrender.
- Existing licenses migrated automatically. Valid licenses and registrations were carried over on FoSCoS with the same 14-digit number — no fresh application, no modification fee, no approval step.
- Display rules continue. The certificate must still be displayed prominently at the place of business, and the license number declared on labels and bills as applicable.
Who needs a Central license regardless of turnover
The turnover slabs decide the default category. Certain activities and premises sit in the Central license category even at nil or tiny turnover — this is the trap that catches small exporters most often:
- Importers and exporters of food (including merchant exporters) and 100% Export Oriented Units;
- E-commerce food platforms and aggregators (the platform entity itself);
- Manufacturers of nutraceuticals, health supplements, proprietary/non-standardised foods and radiation-processed foods;
- FBOs operating in airport or seaport premises, catering for central government agencies, and five-star and above hotels (hotels up to four-star fall under the State license);
- Head office/registered office of an FBO operating in more than one state.
A food exporter therefore needs the Central license (₹7,500 a year) plus an Import Export Code with AD Code registration before the first shipment — the ₹1.5 crore relaxation does not apply.
Two worked examples
1. Cloud kitchen in Thane, food turnover ₹80 lakh. Until FY 2025-26 it sat in the State license band — roughly ₹2,000 a year plus a renewal cycle to track. From 1 April 2026 it falls within the ₹1.5 crore registration band: ₹100 a year, perpetual, applied for on FoSCoS and processed by the state food safety machinery (FDA Maharashtra for Maharashtra businesses). Direct saving is small (about ₹1,900 a year); the real gain is never facing an expired-license gap while listed on delivery platforms.
2. Spice exporter in Navi Mumbai, turnover ₹60 lakh. Turnover-wise this looks like a registration case — but as an exporter it needs the Central license irrespective of turnover: ₹7,500 a year, plus IEC, plus Form D1 every year. Choosing the category by turnover alone here is the classic error that surfaces later at customs clearance or buyer audit.
Already hold a State license but now under ₹1.5 crore?
Your license did not lapse — it migrated as-is with the same number. You have a choice: continue with the State license (paying its higher annual fee) or apply on FoSCoS to move to basic registration. Before downgrading, check three things: whether aggregator platforms, institutional buyers or tenders you serve insist on a license (not registration) in their onboarding terms; whether your growth will cross ₹1.5 crore soon anyway; and whether any activity-based Central trigger (export plans, new product categories such as supplements) applies to you.
Documents checklist
- Basic registration (Form A): photo of the FBO, photo ID (Aadhaar/PAN/Voter ID), proof of business premises/address, nature of business and list of food products handled.
- State/Central license (Form B): all of the above, plus proof of possession of premises (rent agreement/utility bill), constitution documents (partnership deed or certificate of incorporation), Form IX nominee for companies, and for manufacturers — layout plan, equipment list and water test report. Importers/exporters add the IEC certificate.
- Alongside FSSAI, a food business typically also needs GST registration once over the GST threshold and, in Maharashtra, Shop & Establishment registration — FSSAI does not substitute for either.
Registration applications are typically decided in about 7 days; license applications can take 30–60 days including inspection, so sequence FSSAI early when launching or pivoting into food.
Annual return Form D1 — unchanged and still missed
The amendment did not touch the annual return. Licensed manufacturers (including repacking and relabelling units) and importers/exporters must file Form D1 on FoSCoS by 31 May each year for the preceding financial year; delay attracts ₹100 per day. Restaurants, retailers, distributors, storage and transport operators, and registration-only FBOs are exempt. Milk and milk-product units additionally file the half-yearly Form D2.
Penalties if you get this wrong
| Default | Exposure |
|---|---|
| Carrying on a licensable food business without a license | Section 63, FSS Act 2006 — imprisonment up to 6 months and fine up to ₹5 lakh |
| Operating without basic registration (registration-category FBO) | Penalty generally levied up to ₹25,000 |
| Non-payment of annual fee | License/registration deemed suspended; operations during suspension are unlawful |
| Late Form D1 | ₹100 per day of delay |
Common mistakes to avoid in FY 2026-27
- Reading "perpetual validity" as "nothing to pay" — the annual fee is alive, and skipping it suspends the license automatically.
- Exporters and importers picking their category by turnover — Central license applies to them at any turnover.
- Running multiple premises on one license — each premises needs its own; a multi-state operation also needs a Central license for the head office.
- Leaving the license in old particulars — changes in name, address, products or kind of business need a modification application, not silence.
- Licensed manufacturers and importers forgetting Form D1 by 31 May — ₹100 a day adds up quietly.
- Assuming GST, Udyam or Shop Act registration covers food law — FSSAI is a separate, independent requirement.
Frequently asked questions
My food business turnover is ₹40 lakh. Do I need an FSSAI license or registration in 2026?
From 1 April 2026, basic FSSAI registration covers food businesses with annual turnover up to ₹1.5 crore, so at ₹40 lakh you generally need only registration, not a license. The exception is activity-based categories — importers, exporters, e-commerce platforms and certain other operators need a Central license irrespective of turnover.
Do I still need to renew my FSSAI license every year or every five years?
No. The Amendment Regulations gazetted on 10 March 2026 made licenses and registrations perpetual — they continue unless suspended, cancelled or surrendered. You must, however, keep paying the annual fee on FoSCoS; renewal as a process stands abolished.
What happens if I miss paying the FSSAI annual fee?
The license or registration is deemed suspended until the fee is paid, and the food business cannot lawfully operate during suspension. Treat the annual fee date as a hard compliance-calendar item, or prepay the fee for multiple years in advance on FoSCoS.
Do food exporters need a Central license even with small turnover?
Yes. Importers and exporters of food fall in the Central license category irrespective of turnover — the ₹1.5 crore and ₹50 crore thresholds do not apply to them. An Import Export Code (IEC) is required alongside the FSSAI Central license before export shipments.
I hold a State license but my turnover is below ₹1.5 crore. Should I switch to registration?
Your existing license continues automatically on FoSCoS with the same 14-digit number — no fresh application and no migration fee. You may apply to move to the registration category, but first check whether buyers, aggregator platforms, tenders or lenders insist on a license in their terms before downgrading.
Who must file the FSSAI annual return Form D1, and by when?
Licensed manufacturers (including repackers and relabellers) and importers/exporters file Form D1 online on FoSCoS by 31 May for the preceding financial year; late filing attracts ₹100 per day. Restaurants, retailers, distributors and registration-only businesses are exempt, while milk and milk-product units also file the half-yearly Form D2.
Somesh Chandak & Associates, Thane, assists food businesses, cloud kitchens, manufacturers and exporters with FoSCoS registration and license applications, category review after the 2026 amendment, annual fee and Form D1 compliance, and the surrounding GST, IEC and Shop Act registrations.
FSSAI Registration & License IEC & AD Code for Exporters Talk to usThis article summarises the Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026 and related FSSAI orders as on 1 August 2026 for general information. Fees and category criteria depend on the exact kind of business on FoSCoS; verify your specific position or take professional advice before acting.