FSSAI Registration vs Licence: Which One Your Food Business Actually Needs in 2026

By S&S Co. Advocates & Solicitors · Published 15 October 2026 · Informational content, not legal advice: see our disclaimer

Food business clients usually arrive asking a narrower question than the one that actually needs answering. They want to know how to get an FSSAI number, when the real question is which of the three distinct authorisations their specific business needs, since operating under the wrong one, or under none at all, carries criminal exposure under the Food Safety and Standards Act, 2006, not merely a paperwork defect.

FSSAI revised its turnover thresholds for registration, state licensing and central licensing with effect from 1 April 2026, moving away from the older figures that had stayed largely unchanged since the licensing framework was first set up. This guide sets out the current thresholds, who falls into which category, and what changes once an authorisation is actually granted.

The three tiers, and the revised thresholds now in force

Every food business operator in India needs one of three authorisations under the Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011: basic registration, a state licence, or a central licence, with the distinction turning primarily on annual turnover and, separately, on the specific kind of business being conducted. Following the Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026, gazetted on 10 March 2026 and implemented by FSSAI's order dated 13 March 2026 with effect from 1 April 2026, basic registration now covers food businesses with annual turnover up to one and a half crore rupees, a substantial rise from the earlier twelve lakh rupee threshold that had applied for well over a decade.

A state licence is now required for turnover above one and a half crore rupees and up to fifty crore rupees, while a central licence generally applies above fifty crore rupees, or earlier regardless of turnover for certain categories of business that FSSAI treats as requiring central-level oversight because of their scale or risk profile, such as importers, businesses operating across more than one state, and certain large manufacturing or processing operations. A small operator who has been registered for years on the strength of the old twelve lakh rupee threshold should specifically check whether the revised one and a half crore rupee figure now keeps them within basic registration, since many businesses that previously needed to step up to a state licence purely because of the old low threshold may no longer need to.

Why the category also depends on the kind of business

Turnover is the primary filter, but it is not the only one. The licensing regulations attach certain categories of food business to a specific tier regardless of how small the turnover figure actually is, because the nature of the activity itself is treated as carrying a different risk profile. Importers of food products, for instance, generally require a central licence irrespective of turnover, on the reasoning that imported food carries distinct traceability and safety oversight needs that a state-level authority is not best placed to handle. Similarly, certain categories such as food businesses operating in or from a Central Government agency's premises, on railways, or in airports and seaports, are treated as falling under central licensing by virtue of the location and nature of operations rather than turnover.

A business with a genuinely small turnover but a specific high-risk activity, such as manufacturing, repacking, or relabelling certain categories of food products, should accordingly check the kind-of-business schedule in the regulations before assuming the turnover threshold alone decides the answer, since getting this wrong by only looking at turnover figures is a common and avoidable mistake.

What a perpetual licence changes about renewal obligations

The 2026 amendment also introduced perpetual validity for FSSAI registrations and licences, meaning an authorisation granted under the amended framework remains valid indefinitely unless it is suspended, cancelled, or voluntarily surrendered by the operator, rather than lapsing automatically after a fixed term as under the earlier framework, which had typically required renewal every one to five years depending on the category chosen at the time of application. This is a meaningful compliance relief, since missed renewal deadlines had historically been one of the more common, avoidable ways a food business ended up technically unlicensed without realising it.

Perpetual validity does not, however, remove the operator's ongoing obligations around annual returns, inspections, and compliance with food safety standards, and it does not freeze the operator into whatever tier applied at the time of grant if the business subsequently crosses a turnover threshold that would place it in a higher tier. An operator whose turnover grows beyond the registration or state licence threshold is still required to apply for the appropriate upgraded authorisation at that point, perpetual validity notwithstanding, since the obligation to hold the correct authorisation for the business's current scale is ongoing, not fixed at the date of the original grant.

The penalty for operating without the right authorisation

Operating a food business without the required registration or licence is treated as a serious compliance failure under the Food Safety and Standards Act, 2006, not a minor administrative lapse, and the Act's penalty provisions, particularly Section 63 dealing with the consequence of operating without a licence, carry the possibility of imprisonment in addition to fine for a genuinely unlicensed operation, as distinct from the civil penalty framework that applies to lesser compliance failures such as misbranding or substandard food, which are typically dealt with through monetary penalties imposed by an adjudicating officer rather than a criminal court.

This distinction matters practically: a business that holds a registration where it should actually have a state licence, because it has grown past the applicable threshold without upgrading, is in a meaningfully worse legal position than a business dealing with a labelling defect on an otherwise properly licensed product, and the two should not be treated with the same level of urgency when advising a client on compliance priorities.

Practical steps when advising a food business on its tier

Work out the annual turnover figure first, using the actual, current financial year projection rather than a historic figure that may no longer be representative, since a business scaling quickly can cross a threshold mid-year and should apply for the upgraded authorisation proactively rather than waiting for the next renewal cycle that, under the new perpetual validity regime, may not come around on its own.

Separately check whether the specific nature of the business, such as importing, operating across states, or falling into one of the specified high-risk categories, pulls it into central licensing regardless of turnover, and do this check even for a business that otherwise looks comfortably within the registration or state licence turnover band. Where a business operates from multiple premises or states, confirm whether each location needs its own registration or licence, since FSSAI's framework generally ties the authorisation to the specific premises of operation rather than issuing a single blanket authorisation covering every location a business operates from.

Frequently Asked Questions

References & Further Reading

The provisions and rulings below were relied on for this guide. The position can change with amendments and later decisions, so check the current text and the latest case law before acting on any of it.

1. Food Safety and Standards Act, 2006, Section 63
2. Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011
3. Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026 (gazetted 10 March 2026)
4. FSSAI order dated 13 March 2026 implementing revised turnover thresholds with effect from 1 April 2026