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FSSAI

FSSAI Registration vs Licence: Differences Explained (2026)

The registration versus licence question turns on Section 31(2) against 31(1), Form A against Form B, and a penalty gap of Rs 2 lakh against Rs 10 lakh.

Rahul Jangra - Reviewed by Rahul Jangra - 10 Sept 2026 - Updated 10 Sept 2026 - 5 min read - 3 views

FSSAI Registration vs License

FSSAI registration and an FSSAI licence are two different approvals under the same Act. Registration covers petty Food Business Operators with turnover up to ₹1.5 crore, filed in Form A at ₹100 a year. A licence covers everyone above that ceiling, and every licence-only category, filed in Form B.

Most comparisons stop at turnover. The differences that actually cost money sit elsewhere: the enabling sub-section, the penalty if you get caught without one, and a list of business types that can never use registration however small they are.

FSSAI registration vs licence at a glance

Parameter

Registration

Licence

Enabling provision

Section 31(2), FSS Act, 2006

Section 31(1), FSS Act, 2006

Who it covers

Petty Food Business Operators

Everyone else, plus licence-only categories

Turnover band

Up to ₹1.5 crore

Above ₹1.5 crore (State), above ₹50 crore (Central)

Application form

Form A

Form B

Government fee

₹100 per year

₹2,000 to ₹5,000 (State); ₹7,500 (Central)

Physical inspection

Normally none

Usually required

Penalty if operating without it

Up to ₹2 lakh (Sections 55 and 58)

Up to ₹10 lakh (Section 63)

Certificate

14-digit registration number

14-digit licence number

Section 31(1) of the FSS Act, 2006 states the general rule: no person shall carry on a food business except under a licence. Section 31(2) then creates the exception, allowing petty Food Business Operators to register instead. Registration is not a smaller licence. It is a separate route out of the licensing requirement.

That structure explains everything downstream. Registration uses a lighter form and a smaller document set, and the FSSAI document checklist for Form A runs to three items where Form B runs to a dozen or more.

The penalty difference most comparisons miss

Operating without a required licence attracts a penalty of up to ₹10 lakh under Section 63, as amended by the Jan Vishwas (Amendment of Provisions) Act, 2023, which came into force for the FSS Act on 8 November 2023 and removed the earlier six-month imprisonment term.

Section 63 does not reach petty operators. It applies except to persons exempted from licensing under Section 31(2), which is exactly the provision registrants use. A business that should have registered and did not falls under the residual provisions, Sections 55 and 58, at up to ₹2 lakh. The FSSAI penalty position is set out in full separately.

[VERIFY: confirm the Sections 55, 58 and 63 ceilings against the bare FSS Act, 2006 as amended, and have a CA or advocate sign off on the registration-versus-licence reading before publishing.]

Which businesses can never use FSSAI registration?

Some kinds of business must hold a licence at any turnover. Being under ₹1.5 crore does not help if you fall in one of these groups, and this is where wrongly filed Form A applications come from.

Kind of business

Minimum approval

Caterers, including event and mid-day-meal caterers

State Licence

Hotels below 5-star serving food

State Licence

Importers of any food product

Central Licence

E-commerce food businesses and online food platforms

Central Licence

Nutraceuticals, health supplements, proprietary foods

Central Licence

Businesses operating in more than one state

Central Licence

Caterers are the sharpest case. The 2026 amendment rewrote the definition of a petty Food Business Operator and carved them out in three words, "except a caterer", so a home cook taking event orders is outside registration on definition rather than on revenue.

Does the instant route work for both?

The Tatkal route covers registrations and licences, but its eligibility list is drawn on kind of business rather than on tier. Food manufacturers and processors are excluded from instant issuance whether they would be registering or licensing.

What changes when you move from registration to licence?

Crossing ₹1.5 crore means applying afresh in Form B rather than amending Form A. Expect a larger document set, a likely physical inspection, and a fee that moves from ₹100 to at least ₹2,000 a year. Our guide to the FSSAI turnover thresholds covers the bands and the effective dates. For the tier itself, see State FSSAI Licence filing.

Mistakes people make between the two

  • Calling registration a "basic licence". It is legally a different instrument, and the penalty exposure differs by ₹8 lakh.

  • Assuming turnover alone decides it. Kind of business overrides turnover in several categories.

  • Trying to amend a Form A registration upward instead of filing Form B.

  • Quoting the Section 63 penalty for a missing registration. Wrong section, wrong tier, wrong number.

  • Waiting for a notice before upgrading after crossing the ceiling. The duty to move up is yours.

What we see on tier decisions at Complylocal

[EXPERT INPUT NEEDED: Keshav Sehgal to add one real, anonymised observation. Strongest options: (a) how often clients arrive holding a registration when their kind of business required a licence, as a proportion of FSSAI files we take on; (b) a client who crossed ₹1.5 crore and what the Form A to Form B transition actually took in days and fees; (c) the most common tier misjudgement we correct before filing. One real number required.]

Not sure which tier applies to you? Talk to Keshav’s team at Complylocal for FSSAI registration support.

Official sources

  • Food Safety and Standards Act, 2006, Section 31(1) and Section 31(2), and Sections 55, 58 and 63.

  • FSS (Licensing and Registration of Food Businesses) Regulations, 2011, Form A and Form B under Schedule 2, and fees under Schedule 3.

  • FSS (Licensing and Registration of Food Businesses) Amendment Regulations, 2026, notified 10 March 2026 and published in the Gazette of India on 11 March 2026.

  • FSSAI order dated 13 March 2026, revised turnover thresholds effective 1 April 2026.

  • Jan Vishwas (Amendment of Provisions) Act, 2023, amending Sections 59, 61 and 63 of the FSS Act.

Frequently Asked Questions

  • Registration is granted under Section 31(2) to petty operators up to ₹1.5 crore turnover, in Form A at ₹100 a year. A licence is granted under Section 31(1) in Form B, costs ₹2,000 or more, and usually involves a physical inspection.

  • No. Registration is a separate route created by Section 31(2) as an exception to the licensing requirement in Section 31(1). The distinction matters because the penalty for operating without each is different.

  • Neither is a choice. Your turnover and kind of business decide it. Registration applies up to ₹1.5 crore unless you fall in a licence-only category such as catering, import or e-commerce, where a licence applies at any turnover.

  • Operating without a required licence attracts up to ₹10 lakh under Section 63. A petty operator without registration falls under Sections 55 and 58, at up to ₹2 lakh, because Section 63 excludes persons exempted under Section 31(2).

  • You file a fresh application in Form B rather than amending the registration. Budget for a larger document set, a likely inspection, and a fee of at least ₹2,000 a year in place of ₹100.

  • Form A for registration and Form B for both State and Central licences. Both are filed on FoSCoS at foscos.fssai.gov.in, and both are set out in Schedule 2 of the Licensing and Registration Regulations, 2011.

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Written by

Rahul Jangra

Senior SEO SpecialistComplylocal Consultants

Rahul Jangra is the Senior SEO & Digital Marketing Specialist at ComplyLocal Consultants. He specializes in SEO, AI search optimization, content strategy, and digital growth for taxation, GST, accounting, ROC compliance, and business registration services in India.

Reviewed for accuracy by

Rahul Jangra

Senior SEO Specialist - Complylocal Consultants

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