By S&S Co. Advocates & Solicitors · Published 2 June 2026 · Informational content, not legal advice: see our disclaimer
Who Counts as a Food Business Operator
The Food Safety and Standards Act, 2006 defines a Food Business Operator (FBO) broadly, covering any person carrying on a food business, whether manufacturing, processing, packaging, storing, transporting, distributing, or selling food, including online. This means the compliance obligations discussed here apply not only to manufacturers and restaurants, but also to wholesalers, cloud kitchens, caterers, and e-commerce food platforms, each attracting the obligations applicable to its specific role in the supply chain.
Recurring Compliance, Not a One-Time Filing
A common misconception is that FSSAI compliance ends once a licence or registration is obtained. In practice, the licence is the starting point of a continuing set of obligations: maintaining hygiene and sanitary conditions consistent with the applicable Schedule 4 requirements for the FBO's category, keeping prescribed records, using only permitted additives and ingredients within permissible limits, ensuring accurate labelling, and cooperating with periodic inspections and, where applicable, food safety audits.
Since the 2026 licensing amendment introduced perpetual validity for licences and registrations issued on or after 1 April 2026, the discipline required has shifted from a renewal reminder to an annual fee-payment calendar. A missed annual payment now triggers automatic suspension without further notice, which is arguably a stricter consequence than a lapsed renewal used to carry.
A Practical Compliance Checklist
At a minimum, an FBO's internal compliance checklist should cover: (1) displaying the FSSAI licence number and logo as required on premises and packaging; (2) maintaining the specific hygiene and sanitary standards applicable to its category under Schedule 4; (3) verifying that raw materials and ingredients are sourced from FSSAI-compliant suppliers; (4) keeping batch and traceability records sufficient to support a recall if one becomes necessary; (5) ensuring label content, including nutritional information, allergen declarations, and any claims made. Is current against the applicable Labelling and Display Regulations; (6) timely payment of the annual licence fee; and (7) designating a person responsible for tracking FSSAI circulars and regulatory updates relevant to the business's product category.
Where Compliance Gaps Typically Surface
In practice, inspection findings and show-cause notices tend to cluster around a small number of recurring gaps: outdated labels that have not kept pace with a regulatory amendment, missing or incomplete traceability records when a recall or investigation is triggered, and hygiene deficiencies at the physical premises level that are often correctable quickly once flagged. Building a periodic self-audit into the business's calendar, rather than treating an FSSAI inspection as the first occasion compliance is reviewed. Is generally the more defensible posture if a dispute later arises.
Frequently Asked Questions
Does an FSSAI licence, once obtained, require ongoing compliance work?
Yes. The licence is the starting point, not the end, of an FBO's obligations. Ongoing compliance includes hygiene standards, labelling accuracy, permitted-ingredient use, record-keeping, and, since the 2026 amendment, timely annual fee payment to avoid automatic suspension.
What records should a food business operator maintain for FSSAI purposes?
At minimum, batch and lot traceability records, supplier compliance documentation, and records sufficient to support a recall if one becomes necessary, in addition to any category-specific records required under Schedule 4.
Do e-commerce food platforms have the same compliance obligations as manufacturers?
They qualify as Food Business Operators in their own right under Section 3(1)(o) of the FSS Act, and bear obligations specific to their role, including verifying that sellers on the platform hold valid FSSAI licences.
What is the most common source of an FSSAI show-cause notice?
In practice, labelling non-compliance and hygiene deficiencies identified on inspection are among the most common triggers, alongside sample test failures for adulteration or additive-limit violations.
References & Further Reading
This article references the following statutory provisions. Readers should always verify current rules, fees and timelines against the applicable statute and rules as amended, since these are revised from time to time.
- Food Safety and Standards Act, 2006, and the Schedule 4 hygiene and sanitary requirements under the Licensing and Registration Regulations.
- Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026.