Registration & licensing
FSSAI Annual Return (Form D-1): Who Must File and By When
Form D1 applies to specified licensed manufacturing and importing activities, including relevant repackers, relabellers and exporter-manufacturers. It is not a universal return for every restaurant or retailer. The baseline deadline is 31 May for the preceding financial year; check year-specific directions before filing.
By the MyFoodLicense team Sources checked 3 min read
In this guide
Check applicability from the actual KoB
Official FAQs describe licensed manufacturers, including repacking and relabelling arrangements, and importers within the D1 framework. Exporter-manufacturers are also covered by the stated later extension. Compare your certificate and activity with the requirement, rather than assuming every authorisation holder files the same return. Read the annual-return FAQs.
Identify the reporting year
Reconcile production or importing records for the preceding financial year. The baseline deadline is 31 May, but any current extension or special direction must be checked for that particular year. Do not carry an extension from one year into another or use a deadline from a social-media message without its official order.
Prepare product and quantity records
Work from actual product, production, import and transaction records. Use the units and fields requested in the live FoSCoS form. Resolve mismatches with stock and accounting records before submission. A nil-activity situation needs an applicability and filing review, rather than invented quantities or an unsupported assumption that no return is required.
Review late filing under current instructions
The official baseline FAQ states ₹100 per day for late submission. Current account calculations, applicable caps or specific directions need their own check. The March 2026 validity amendment also links non-submission of an applicable return to deemed suspension. Keep the penalty calculation and status issue separate. Read the amended validity provision.
Keep proof and improve the next cycle
File through the official workflow and retain the submitted data, acknowledgement and payment evidence where relevant. Record who prepared and checked the figures. Update production and import records during the year so the next return does not become a reconstruction from invoices alone.
A worked example
Hypothetical example
A relabeller commissions snack manufacture at two factories. It gathers actual production and product records under the arrangement, checks return applicability and reconciles the reporting units before filing. The factories’ own records do not automatically establish that the brand’s separate filing obligations are complete.
Your practical checklist
- Check the licensed activities and D1 applicability.
- Confirm reporting year and any official extension.
- Reconcile quantities and requested units.
- Review nil activity and outstanding periods.
- Check late-fee and suspension implications.
- Retain submission and payment acknowledgements.
Download this preparation checklist
For help applying this review to your business, explore our FSSAI Compliance Gap Assessment service. Bring the documents described above so the consultation can focus on the decisions still unresolved.
Frequently asked questions
Must every FSSAI holder file D1?
No. Assess the specified manufacturing and importing activities and relevant directions.
What is the ordinary deadline?
31 May for the preceding financial year, subject to any applicable official extension.
Do relabellers need a return review?
Yes. The official FAQ includes relevant third-party manufacturing arrangements.
What is the baseline late charge?
The cited FAQ states ₹100 per day; verify current calculations and applicable directions for the account.
Can non-filing affect validity?
Yes. The 2026 amendment links an applicable-return default to deemed suspension.
Official sources and further reading
Checked on 2 October 2026. Gazette notifications and operative directions prevail over compilations and summaries, including this guide.
- FSSAI licensing FAQs, December 2022: D1 applicability and 31 May baseline deadline; old licensing bands and renewal passages superseded.
- Official FoSCoS application portal: Official applications, help topics, current document lists and eligibility information.
- Licensing and Registration Amendment Regulations, notification dated 10 March 2026: Regulation 2.1.7: perpetual validity, annual fees, applicable returns and suspension; regulation 2.1.17: risk-based inspections.
This guide is general information, not legal advice; the right route depends on your product and business facts. Examples marked hypothetical are illustrations, not client cases. MyFoodLicense is an independent consultancy and is not affiliated with FSSAI; applications are decided by the competent authority on the official FoSCoS portal.