FSSAI Annual Return (Form D1): Who Files, When It Is Due, and the Late Fee

Since April 2026 your FSSAI licence never expires. No renewal date, no renewal application, nothing to diarise — or so the celebration goes. Then May arrives, and with it the one filing the reform left completely untouched: the annual return in Form D1. If you manufacture or import food under a licence, 31 May is still your date, the return still goes in on FoSCoS, and every day of delay still costs ₹100. Here is who files, what the return asks, and exactly how the late fee works.

Who files Form D1 — and who does not

The duty sits in Regulation 2.1.13 of the Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011. Its first line names the class precisely: every manufacturer and importer who has been issued a licence. FSSAI's own advisory of 16 April 2024 spells the working list out — manufacturers, including repackers and relabellers, importers, and manufacturer-exporters.

Notice what decides the question. It is your activity, not your turnover. Old guides still floating around online tie the return to a ₹12 lakh turnover line; that line died with the old registration threshold and it was never the test in this regulation. A small licensed manufacturer files. A large restaurant does not — unless it also manufactures or imports under its licence.

So if you run a restaurant, a retail store, a distribution or transport business and you neither manufacture nor import, this return is not addressed to you. Read your licence conditions once to be sure, because the licence is the document that binds you. And if you hold only a Basic Registration, there is no D1 at all — the regulation speaks to licensees.

FSSAI has published no general exemption list for this return, and the regulation carves out no class of manufacturer or importer. If a website tells you your kind of unit is exempt, ask it for the order. I have looked; the named classes above are the whole story.

The date, the year it covers, and the separate-return rule

The return is due on or before 31 May every year, and it reports the previous financial year — 1 April to 31 March. The return you file by 31 May 2027 will speak for FY 2026-27. It is filed online on FoSCoS; paper filing ended years ago, and online submission has been the only accepted mode since the FY 2020-21 return.

Three details catch people out:

• One return per licence. Regulation 2.1.13(2) is blunt — a separate return for every licence issued, even where one business holds several. Three licences, three returns.
• Low production is not an excuse, and neither is none. The duty follows the licence and the activity, not the output. A unit that stood idle still files, showing what actually happened — nothing.
• Extensions are gifts, not entitlements. Plan on 31 May every year and treat anything beyond it as a bonus.

Filing itself is plain work. Log in to FoSCoS, open the annual return filing for your licence, choose the financial year, and enter the figures class by class — product, packaging, quantity, value. Submit, and save the acknowledgement the portal generates; that acknowledgement is your proof if the filing is ever questioned. Most of the effort sits before the login, in pulling the year's production and dispatch numbers into one place. Businesses that close their product-wise figures every March file in an hour. Businesses that reconstruct a year from invoices in May take a week, and their numbers show it.

What the return actually asks

Think of D1 as the regulator's copy of your year's closing stock book — the bahi-khata a traditional shopkeeper balances every March, except this one is product by product and the Food Safety Commissioner reads it. For each class of food products you handled, the return takes the product name, the packaging sizes, the quantity in metric tonnes, and the value. Importers and exporters add the import and export details for what crossed the border. It is a production and movement statement, not a tax return; the figures should match your own production and dispatch records, because those records are what an officer will ask for if a number looks odd.

Milk units: Form D2, twice a year

One class files more often. The same regulation adds a proviso for licensees engaged in manufacturing milk or milk products: a half-yearly return in Form D2, for 1 April to 30 September and for 1 October to 31 March, filed within a month from the end of each period. In plain dates: the April–September return by 31 October, and the October–March return by 30 April. Some websites print 30 September and 30 March as the deadlines — those are the period ends, not the filing dates. The regulation gives you the month after.

The late fee: ₹100 a day, with a ceiling the regulation does not mention

Regulation 2.1.13(3) prescribes the penalty in one line: any delay in filing beyond 31 May attracts ₹100 per day of delay. Read the regulation alone and the meter runs without limit. It does not run without limit in practice, because FSSAI capped it by order — the Order dated 10 November 2022 fixed the maximum penalty at five times the annual licence fee, and FSSAI's April 2024 advisory repeats that ceiling.

Put numbers on it. A State Licence carries an annual fee of ₹5,000, so the late fee for one return can never cross ₹25,000. A Central Licence at ₹7,500 a year caps at ₹37,500. The cap is per return, remember — three licences filed late means three meters running. And do not budget for mercy: the same advisory states that no request for waiver of the penalty will be considered.

Filed it with an error? The correction window

Mistakes happen, and since January 2024 they are fixable. Under FSSAI's Order dated 8 January 2024, a return can be revised on FoSCoS free of charge up to 31 May, and for a fee between 1 June and 31 March of the following year. After that following 31 March, the door closes. File on time and the correction, if you need one, is cheap; file late and even the fixing costs more.

Your return is actually read

For years, D1 felt like a formality you filed into a void. That changed on 7 July 2025, when FSSAI directed every Licensing Authority to scrutinise annual returns properly — production figures, quantities, declarations — and warned that discrepancies or a false declaration can bring penal action under Section 61 of the Food Safety and Standards Act, 2006. File figures you can defend from your own records. The return takes an hour when the records are in order; explaining a guess takes much longer.

Perpetual licence, continuing duties

Keep the three post-2026 duties separate in your mind, because they fail separately. Your licence's validity is perpetual — nothing to renew. Your annual fee still falls due every year, and non-payment can leave the licence deemed suspended under Regulation 2.1.7. And your Form D1 still falls due every 31 May — the 2026 amendment regulations changed the thresholds and the validity rule and said nothing at all about Regulation 2.1.13, so the return stands exactly where it stood in 2011.

One warning, because the internet will confuse you here. A draft amendment published in January 2026 proposed replacing the ₹100-a-day penalty with graded charges — twice the annual fee up to ninety days late, five times beyond that — and deeming the licence suspended on the 181st day. It was a draft, published for comments. It is not the law today, and the ₹100-a-day rule with the five-times cap is the position your money will be judged by.

If your D1 for last year is still unfiled, or your production records need an hour of sorting before they can carry a return, our team files FSSAI returns on FoSCoS every week of the season — start with the recurring compliance section of our FSSAI service page and we will get your licence's record straight. And if the tier framework itself is still fuzzy, the 2026 Basic, State and Central guide settles it in one read.