By S&S Co. Advocates & Solicitors · Published 27 October 2026 · Informational content, not legal advice: see our disclaimer
Ten-minute delivery built an entire retail category around a type of outlet that barely existed in food safety regulation when the Food Safety and Standards Act was drafted: a dark store, a small warehouse with no customer footfall, stocking packaged and sometimes fresh food purely for fulfilment of online orders placed minutes earlier. Operators running dozens of these across a city have discovered through 2025 and 2026 that state food safety authorities are treating each dark store as a site that needs its own scrutiny, not merely an extension of a head-office licence.
The regulatory question has two layers that often get collapsed into one in casual compliance advice: what licence the platform itself needs as an e-commerce food business operator, and what licence or registration each individual dark store needs as a physical site storing and dispatching food. Getting the first right does not automatically get the second right.
The Platform-Level Rule: A Central Licence for E-Commerce FBOs
FSSAI has long treated e-commerce food business operators as falling within the category that must hold a Central Licence under Schedule I of the Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011, regardless of the operator's annual turnover. This was clarified through an FSSAI order dated 15 April 2019, which addressed how e-commerce FBOs with operations across multiple states and cities should be licensed, and platforms such as Zepto and Blinkit operate on the footing that their core e-commerce food business requires this Central Licence.
The practical reason turnover is irrelevant here is that the 2011 Regulations carve out certain categories, large manufacturers, importers and, specifically, e-commerce operators, for Central Licensing on the basis of the nature of the business rather than its size, on the view that a platform operating across state lines needs a single licensing authority overseeing it rather than a patchwork of separate state licences for an operation that is functionally one business.
Why a Dark Store Still Needs Its Own Attention
Holding a valid Central Licence at the platform level does not mean every warehouse and dark store the platform operates is automatically covered without more. FSSAI has told platforms directly, in communications through 2025, that every warehouse associated with e-commerce food operations should itself be registered or licensed, and has asked platforms to share data on their warehouses and food handlers so the regulator can actually verify this site by site rather than relying on the platform's own assurance that everything is in order.
What exact category of licence or registration a given dark store needs, whether that sits as an addition under the platform's existing Central Licence, a separate site-specific licence, or a state-level registration depending on the dark store's scale, is treated differently across commentary, and the regulation's own text on this specific point was not something this guide's research confirmed with the certainty it would need to state a single firm rule. What is clear from enforcement, not just commentary, is that state regulators are not accepting the platform's head-office Central Licence as sufficient cover for a dark store operating without its own site-level compliance in order.
What Enforcement Through 2025 and 2026 Actually Looked Like
Maharashtra's Food and Drug Administration suspended the food licence of a Zepto dark store in Dharavi in June 2025 over hygiene and compliance concerns, though the suspension was later revoked following a re-inspection, and separately suspended a Blinkit dark store in Pune reportedly for operating without a valid licence at that specific site. Maharashtra has since directed e-commerce food delivery companies to obtain state approval before opening new dark stores, rather than opening first and regularising later.
FSSAI itself issued nine separate notices to Swiggy Instamart in July 2026, continuing a pattern of site-level and operational scrutiny well past the initial 2025 wave of enforcement, The Swiggy Instamart notices themselves concerned expired and contaminated food reaching customers and invalid or mismatched licence details, but the broader 2025-2026 enforcement wave has separately turned up food handlers working without protective gear at Blinkit, Zepto and Instamart sites inspected by the Maharashtra FDA, and, in an earlier 2024 Telangana raid on a Blinkit warehouse, food stored alongside non-food items such as cosmetic products in the same space. None of this suggests a one-time compliance exercise; it reads as a live, continuing enforcement programme aimed specifically at the dark store format rather than at food e-commerce generally.
Hygiene Training and Storage Practice, Not Just Paperwork
Food handlers at a dark store are expected to complete FSSAI's FoSTaC hygiene training, the same baseline training requirement that applies to food handlers in more conventional retail and food service settings, and enforcement reports from Maharashtra specifically called out protective gear and basic hygiene practice as live issues inspectors were finding, not abstract risks. A dark store operator treating hygiene training as a formality to be completed once and forgotten is running the same risk a restaurant would run with the same attitude, except the dark store format gives regulators an easy, visible target precisely because these sites have proliferated so fast.
Shelf-life rules for products dispatched from a dark store came up in commentary with two different figures, one source describing a requirement that delivered products carry a minimum 30 percent of shelf life or 45 days before expiry, another describing a 70 percent threshold, and this guide did not find a way to resolve that conflict against the primary regulatory text with confidence. An operator should treat the exact percentage as something to confirm directly against current FSSAI guidance for its specific product categories, rather than relying on either secondary figure.
Where a Quick Commerce Operator Should Actually Focus
Confirm the platform's Central Licence is current and correctly scoped to the categories of food it actually sells, since a licence drafted for a narrower product range than the business has since grown into is itself a compliance gap waiting to surface during an inspection. Then work through every individual dark store, confirming what site-level registration or licence step each one needs given its state and scale, rather than assuming the head-office licence travels automatically with every new site opened.
Build FoSTaC training completion and renewal into onboarding for every dark store's staff as a tracked, auditable step rather than a one-off box ticked at launch, and separate food storage physically from non-food inventory at every site, since co-storage has already drawn specific regulatory criticism. Finally, treat a state regulator's pre-opening approval requirement, where one state imposes it, as a real precondition rather than a formality to be sorted out after the store has already started taking orders, since Maharashtra's own enforcement record shows exactly that sequence being punished.
Frequently Asked Questions
Does a quick commerce platform need a Central FSSAI Licence regardless of its turnover?
Yes. FSSAI's 2019 order treats e-commerce food business operators as requiring a Central Licence under Schedule I of the 2011 Licensing Regulations because of the nature of the business, not its turnover, since it typically operates across multiple states and cities rather than a single location.
If the platform already holds a Central Licence, does every dark store need anything further?
Regulators are treating each dark store as needing its own site-level compliance, and FSSAI has asked platforms to share warehouse and food handler data for verification. The exact licensing category for each dark store should be confirmed state by state rather than assumed to be covered by the head-office licence alone.
What has actually triggered dark store suspensions so far?
Hygiene lapses, food handlers without protective gear, improper co-storage of food with non-food items such as cosmetics, and operating without a valid licence at that specific site. Maharashtra has suspended both a Zepto dark store and a Blinkit dark store on these kinds of grounds in 2025.
Can a state require approval before a new dark store opens?
Yes. Maharashtra has directed e-commerce food delivery companies to obtain state approval before opening new dark stores rather than seeking compliance after the fact, following its enforcement actions against existing stores in 2025, and an operator expanding into that state should budget time for this step before committing to a launch date.
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.
- Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011, Schedule I
- FSSAI order dated 15 April 2019 on licensing of e-commerce food business operators
- Maharashtra Food and Drug Administration enforcement actions against dark stores, 2025
- FSSAI notices to Swiggy Instamart, July 2026