Renewal has gone. Four things replaced it
Your registration or licence stays valid until it is suspended, cancelled or surrendered. There is no one-year, three-year or five-year expiry to chase.
Four obligations took the place of renewal, and they are easy to mix up.
| What it is | When it applies | Where it is done |
|---|---|---|
| Annual fee | Every year, for every credential | FoSCoS, and FSSAI allows several years to be paid at once |
| Modification | When a particular printed on your licence changes, or you add a product or category | FoSCoS, with the original licence and a fee |
| Migration | When the 1 April 2026 turnover thresholds moved you between categories | FoSCoS, system based, no fee |
| Annual return | Licensed manufacturers and importers, and milk licensees | Form D-1 or Form D-2 on FoSCoS |
If a consultant is still selling you a five-year renewal, ask which of these four they are actually filing.
What counts as a modification
A modification is needed when something changes that is recorded in your licence or that formed the basis on which it was granted. The rule that matters most is the timing: the change has to be approved before you start operating on it.
Under the Licensing and Registration Regulations, a food business operator must keep the authority informed of any change or expansion, and any alteration to the information in the licence certificate needs approval or endorsement before the modified business begins.
Changes that alter the licence certificate
- Name of the business, or the trade name shown on the licence
- Address of the premises, where the licence is being carried to a new address
- Constitution of the business: proprietorship to partnership, firm to LLP, firm or LLP to company
- Kind of business, for example a trader that starts manufacturing
- Food products or categories: adding, and in some cases removing, a product line
- The person nominated as responsible for the business
- Directors, partners or the authorised signatory
- Layout of the premises, or an expansion of the processing or storage area
Changes that do not need a modification
- A change in your contact number or email, which is a profile update on FoSCoS
- A change in turnover within the same category band
- A category change caused only by the revised 2026 thresholds, which is a migration rather than a modification and carries no fee
If you are not sure which bucket you are in, send us the licence and the change. Filing a modification you did not need costs a fee; missing one you did need means operating outside the licence.
Adding a product or a food category: endorsement
Adding a product is the most common reason a licence holder comes to this page, and the sequence is the part people get wrong.
The endorsement has to be approved before you make or sell the new product. A new food category is not something you declare at the next annual fee payment or explain at inspection. If the product is not on your licence and it is on your shelf, that is a contravention rather than a paperwork gap.
Where the new product moves you into a different kind of business, the tier may change too. A trader that begins manufacturing, or a manufacturer that begins making nutraceuticals or proprietary food, can move from a registration or a State licence into Central licensing, and then the answer is a new application rather than an endorsement. See FSSAI Central licence.
Changing the address on an FSSAI licence
FSSAI licensing is premises based, so the address is not an ordinary detail.
- Moving to a new premises usually means an application for the new address rather than an edit to the old licence, because the layout, the equipment and the inspection all attach to the address. Plan it as a fresh file with the old credential surrendered once the new one is granted.
- A correction to the same address, such as a spelling or a pin code error, is a modification.
- Adding a second premises is a separate credential for that premises, not a modification of the first.
We look at the licence and the two addresses before advising, because the cost and the timeline are very different between a correction and a fresh application.
Change of constitution, and change of ownership
A change of constitution is treated as a change in the particulars of the licence, and it needs approval before the new entity trades.
In practice the question is whether the PAN has changed. A conversion from a proprietorship to a private limited company creates a new entity with a new PAN, and an FSSAI credential is held by an entity, so a new application in the new entity's name is the normal route. A change in the partners of a continuing firm, or a change in a company's directors, is a modification of the existing licence.
If you are converting, sequence the FSSAI file with the rest of it: private limited company registration, GST amendment or fresh GST registration and your trade licence all move at the same time, and a mismatch between them is what delays bank and marketplace onboarding.
Death of the licensee
The regulations provide for continuity. A certificate or licence stays valid for the legal representative or a family member of the deceased licensee for a period from the date of death, and within that period the person must apply for transfer of the licence in their favour. The licensing authority makes an inquiry and the licence continues while the transfer application is pending.
This is a case to act on quickly rather than at leisure. Send us the death certificate, the licence and the successor's identity documents and we will file the transfer application.
Migration between categories after 1 April 2026
The 2026 thresholds moved many businesses between categories: registration now covers turnover up to ₹1.5 crore, a State licence up to ₹50 crore and a Central licence above that.
FSSAI has confirmed how migration on account of the revised thresholds works, and it is better news than most licence holders expect:
- The migration is system based and needs no approval from the licensing authority.
- No fee is charged for a migration caused by the revised turnover thresholds.
- Your licence number does not change.
- Licence fees already paid are adjusted against the annual fee of the category you move into.
What you should not do is stop paying on the existing credential on the assumption that a migration has happened. Check what FoSCoS shows against your number, and if it has not moved, ask us to look at it.
The annual fee, and what deemed suspension means
Perpetual validity is about the term of the licence, not about the money. The annual registration or licence fee continues, and FSSAI allows a licensee to pay the fee for any number of years at one time, which is the simplest way to stop this becoming an annual scramble.
If the annual fee is not paid, the licence is treated as suspended. A suspended licence is not a lapsed reminder: trading on it is trading without a valid licence, with the consequences set out on FSSAI registration.
FSSAI modification fees
Professional fee: fee on quote after a free review. A modification is priced after we read the licence and the change, because a pin code correction and a constitution change with a new layout plan are different jobs. The confirmed professional fee for a Basic registration application is from ₹1,999 on FSSAI registration.
Government fee: the regulations provide that an application to modify the licence is accompanied by the original licence and a fee equal to one year's licence fee for your category. A migration caused only by the revised turnover thresholds carries no fee. We confirm the exact amount from FoSCoS for your kind of business before filing.
Professional fees exclude GST at 18%. Government fees, where they apply, are paid at actuals to the department and are shown separately. Fees verified on 27 September 2026.
How a modification is filed on FoSCoS
- Classify the change. A CA reads the licence and decides between a profile update, a modification, a migration and a fresh application. This is the whole value of the exercise.
- Assemble the evidence for the change. A revised layout plan for an expansion, product specifications for an endorsement, the amended deed or incorporation certificate for a constitution change, the board resolution for a signatory change.
- File the modification on FoSCoS with the original licence and the fee.
- Answer the query, and the inspection if one is ordered. The authority may inspect the premises before approving a modification, particularly where the layout or the kind of business has changed.
- Collect the amended licence. An amended licence incorporating the changes is issued. No fresh licence number is created for a modification, and the regulations give the authority 30 days to approve and issue it.
Annual return: Form D-1 and Form D-2
The annual return is separate from both the annual fee and any modification, and it applies only to some licensees.
- Form D-1 is filed on FoSCoS by licensed food manufacturers and importers, by 31 May for the previous financial year.
- Form D-2 is the half-yearly return for a licensee handling milk or milk products, due by 30 November and 31 March.
- A late return attracts ₹100 for each day of delay.
- Basic registration holders who are not manufacturers or importers do not file Form D-1.
If your product list changed during the year, the return and the licence should tell the same story, which is another reason to get an endorsement filed when the product launches and not at year end.
Surrender, suspension and cancellation
Perpetual validity means the licence ends only in one of three ways, and each has a different consequence.
- Surrender is the clean exit when a premises closes or a business is wound up. Surrender the credential instead of letting the annual fee lapse, and keep the acknowledgement with your closure papers.
- Suspension follows non-payment of the annual fee, or an improvement notice that is not complied with. It is reversible, and the sooner it is addressed the less it costs.
- Cancellation is the serious end, and it is a case for advice rather than a portal form.
If you are closing the business rather than the premises, sequence FSSAI with the rest: closing a private limited company and cancelling the GST registration belong in the same checklist.
Common mistakes we are asked to fix
- Paying a "renewal" fee to an agent when the licence is perpetual and only the annual fee was due.
- Launching a new product first and applying for the endorsement later, after a label or an invoice has already gone out.
- Treating a new premises as an address change, which leaves the business trading at an address no credential covers.
- Converting the entity and continuing on the old proprietorship licence with a new company PAN.
- Assuming migration happened because the thresholds changed, without checking what FoSCoS shows.
- Letting the annual fee lapse and discovering the deemed suspension only when a marketplace or a buyer checks the number.
- Ignoring Form D-1 in the year the licence was granted.
Why Regikart for FSSAI modification
Regikart is a CA and CS firm serving 250+ clients from offices in Kolkata (head office), Delhi and Bengaluru, working with clients across India online.
- We classify before we file. Most of the money lost in this area is spent on filings that were never needed, or not spent on the one that was.
- Current law. The page and our advice follow FSSAI's 2026 position: no renewal cycle, annual fee continuing, free system based migration on the revised thresholds.
- Change management across registrations. FSSAI with GST, trade licence, shop and establishment registration and, where the entity itself is changing, company registration.