Who has to file Form D-1
Regulation 2.1.13(1) of the Licensing Regulations says every manufacturer and importer who has been issued a licence must file Form D-1 for each class of food products handled in the previous financial year. FSSAI's FAQ adds that repackers and relabellers count as manufacturers here.
- Registration holders (numbers starting with 2) are outside 2.1.13. FSSAI's FAQ confirms they don't file.
- Other licensed businesses, such as restaurants, retailers or warehouses that neither make nor import, aren't named in 2.1.13 as written.
You'll often read that returns only apply above ₹12 lakh turnover, or that restaurants and grocers are exempt. We searched FSSAI's orders and found no instrument carrying either rule. We apply 2.1.13 as written: if you hold a licence and you manufacture or import, you file.
The last date: 31 May
The return is due on or before 31 May each year, for the financial year that ended on 31 March. So the return for 2025-26 was due by 31 May 2026, and the return for 2026-27 is due by 31 May 2027.
FSSAI has at times issued orders extending a year's deadline. They're published on fssai.gov.in under advisories and orders. Don't rely on an extension you've only seen reported; read the order, or file on time.
One return per licence
Regulation 2.1.13(2) requires a separate return for every licence, even when one business holds several. A company with three factories on three licences files three returns. Within each, you report by class of food product.
Keep your production, purchase and import records up to date through the year. Daily production and raw-material records are a condition of every manufacturer's licence (condition 8, as substituted in 2026), and they're what the return is built from.
The penalty, and the bigger risk
Delay beyond 31 May attracts ₹100 per day (regulation 2.1.13(3)). FSSAI's FAQ says the late fee runs until the date you file. FSSAI issued an order on the annual-return penalty on 10 November 2022; we haven't read its text, so we don't quote a cap.
The larger risk is new. Since the amendment of 10 March 2026, failing to file a required return by its due date puts the licence under deemed suspension (regulation 2.1.7(2)). No notice is issued, and you may not trade until it's put right. See what changed in 2026.
How to file on FoSCoS
FSSAI made annual returns online only from financial year 2020-21, through FoSCoS. There's no offline submission, so a Word or PDF copy of Form D-1 is for preparing your figures, not for filing.
- Log in to your FoSCoS account for the licence concerned.
- Open the annual return for that licence and the financial year.
- Enter the details for each class of food product you made or imported.
- Submit, and keep a copy of what you filed with your records.
Repeat for every licence you hold. If a menu doesn't match what you expect, the FoSCoS home page carries FSSAI's own guidance. FSSAI's regulation sets no fee for filing on time. The only money in 2.1.13 is the ₹100-a-day late fee.
Form D-2 for dairy: check before you rely on it
The proviso to 2.1.13(1) says a licensee manufacturing milk or milk products files Form D-2 half-yearly (1 April to 30 September, and 1 October to 31 March), within a month of each period ending. The Conditions of Licence give a different date. And FSSAI's FAQ of July 2022 says half-yearly D-2 returns were discontinued from financial year 2020-21.
Those three don't agree. If you make dairy products, confirm the position with your licensing authority in writing, and file D-1 by 31 May either way.
Getting it done
We file returns on your own FoSCoS login and keep a copy of every filing in your file. See annual returns. Under Compliance Care the 31 May date, the annual fee and your six-monthly tests sit on one calendar, so nothing goes quiet.