FSSAI Annual Return Form D-1: Who Files When There Is No Production, an Import Business or a Midyear Closure?

Form D-1 is an activity-based annual compliance requirement. A food business does not become liable simply because it holds any FSSAI licence, and a licensed manufacturer does not become exempt merely because sales were nil. The reliable approach is to map each certificate, its activities and its operating history to the relevant financial year.

This distinction became more important in 2026. Certificates now have continuing validity, turnover eligibility has changed and some existing licensees will migrate to registration. None of those changes should be treated as permission to erase obligations arising during an earlier licensed reporting period.

For financial year 2025–26, the normal 31 May deadline was extended to 15 June 2026. That extension was specific to that return cycle. It should not be copied into every future compliance calendar.

Start with the activity matrix

The principal annual-return population comprises licensed manufacturers, including repackers and relabellers, importers and manufacturer-exporters. Relabellers are included even though another factory physically makes their products. An importer should not assume that it has no return because it does not manufacture in India.

A restaurant that also manufactures packaged sauce for distribution needs more careful treatment than a restaurant serving meals only. Similarly, a distributor importing foods under its own importer activity cannot rely on the distributor description to avoid the importer return.

Maintain one applicability decision for each licence. A group-level spreadsheet of total turnover is insufficient because different units can have different activities, certificate numbers and reporting histories. A head-office licence does not automatically replace returns associated with manufacturing or importing unit records.

Establish the reporting period before collecting figures

The return concerns the preceding financial year, ordinarily 1 April to 31 March. Write those dates on the working file. For the 2025–26 return, collect the activity and certificate history for 1 April 2025 through 31 March 2026, rather than the calendar year or the year ending on the certificate's former expiry date.

Record the licence number, legal operator, premises, activities and effective dates of grants, modifications, suspension, closure or migration. A licence granted during the year should be considered with its actual history; it is not sensible to fabricate twelve months of operations before the business existed.

Where an existing number is retained after a modification or migration, preserve the earlier certificate and annexures. The current downloaded certificate may no longer display the activities or category that applied during the reporting year. Those historical facts can still be relevant to the return decision and supporting quantities.

If a business has changed legal operators, identify which operator conducted the activity in each period. Do not combine two companies' figures merely because they used the same brand and premises. Where portal access or licence mapping does not reflect the historical position, raise the issue with the authority or helpdesk and retain the request.

Nil production is a filing fact, not an automatic exemption

A licensed manufacturer that remained inactive should examine the nil-return facility. The absence of production or imports does not by itself remove the annual-return requirement attached to the relevant licensed activity. Keep evidence supporting the nil position, such as the production register, stock ledger, purchase history and management explanation.

Distinguish no production from no sales. A factory may produce food and carry the entire output in closing stock. Another business may sell opening stock without making anything new. Both situations differ from complete inactivity, and the return must reflect the applicable fields rather than a convenient zero-turnover summary.

A relabeller may have no factory output in its own premises while a contract manufacturer makes thousands of packs for it. That is not a reason to mark the relabeller's operations nil. Reconcile the outsourced production relationship and the actual quantities handled under the brand's licensed model.

Likewise, an importer with no domestic sales may nevertheless have imports during the year. Customs clearance, inward stock and subsequent dispatch records should be examined before declaring a nil import position. Goods rejected, returned or held in stock need their correct treatment in the relevant return fields.

Reconcile quantities rather than copying turnover

Build a product-wise working schedule using consistent units. Identify products endorsed during the year, quantities produced or imported, relevant pack information, opening and closing stock, dispatches, returns and other movements needed to explain the return.

The precise return fields should guide the final entries. Do not force every inventory reconciliation item into a field that asks for a different measure. A kilogram quantity cannot be copied from a ledger recording cases without a supported conversion. Keep the conversion calculation and pack-size changes with the working papers.

For imports, reconcile the food descriptions and quantities with bills of entry, invoices and inward records. An importer buying already imported goods from an Indian distributor should distinguish that domestic purchase from an import conducted under its own licence. Do not count the same shipment once at clearance and again at a warehouse transfer.

For relabellers, obtain manufacturer statements that identify the brand's products and quantities. Compare them with purchases, job-work arrangements and batch receipts. A factory's entire production cannot be reported as the relabeller's quantity simply because the brand uses that factory.

For multiple sites, reconcile inter-unit transfers so that group records do not become duplicate reporting without understanding the form's requirements. Keep a separate explanation of goods made at one site and dispatched from another. This is a recommended reconciliation control, not a licence to alter the statutory form.

Midyear closure and category migration

A business closing in September should preserve the return information for the part of the financial year when it operated. Closure does not automatically cancel the reporting history. Complete the applicable closure and surrender process and retain the acknowledgement alongside the last operating date and stock-disposal records.

Do not wait for a former expiry date where continuing validity now applies. The 2026 framework requires written information about closure and surrender within 30 days of closure. The closure record and annual-return record serve different purposes: one ends the operating permission, while the other reports the relevant year's activity.

Migration from licence to registration needs the same date discipline. A business may qualify for registration after the revised turnover limits but have operated as a licensed manufacturer during the year being reported. A later lower category should not be used to assume that an earlier D-1 obligation disappeared.

The general 2026 migration guidance does not provide a universal answer to every split-year return scenario. Where the retained number or portal screen prevents reporting the licensed period correctly, obtain a case-specific written direction. Provide the old and new certificates, effective dates and activity record. Avoid filing invented full-year figures or silently omitting the return because a button is missing.

File through FoSCoS and preserve the result

Annual returns must be submitted online through FoSCoS. A spreadsheet emailed to an officer, a physical Form D-1 delivered to an office or an adviser saying the work is finished is not the same as completed online submission.

Use the relevant business login and licence record, select the reporting year and complete the applicable annual-return information. Review the operator, premises, product descriptions, units and quantities before the final declaration. Where nil filing is appropriate, use the available nil-return route rather than entering misleading product movements.

Save the submitted return, acknowledgement or status evidence and any payment record. Preserve the underlying working schedule and the person approving the declaration. If an adviser prepares the entries, the operator should still understand and approve the figures being declared.

Resolve credentials before the deadline. A former employee's mobile number, inaccessible email account or consultant-controlled password can turn an otherwise simple return into a late filing. Update authorised contact arrangements through the prescribed process; do not create a second licence merely to obtain easier account access.

Deadlines, late fees and 2026 consequences

The standing annual deadline is 31 May following the reporting financial year unless an applicable extension changes it. For 2025–26, the announced extension was to 15 June 2026. The next ordinary deadline for 2026–27 is therefore 31 May 2027 unless a later applicable order changes it.

The daily late-filing amount is ₹100, subject to the prescribed cap of five times the annual licence fee for the relevant return regime from financial year 2021–22 onwards. It is inaccurate to describe the charge as unlimited. It is equally inaccurate to describe the cap as permission to ignore the return once the maximum has accrued.

For an extended filing cycle, reconcile the portal's late-fee start with the applicable extension rather than mechanically calculating from the usual 1 June date. Preserve the extension evidence if the calculation appears inconsistent and raise a documented query.

The 2026 continuing-validity rules also provide for deemed suspension when the annual fee or applicable return is not completed by its due date, with restoration through compliance and the required penalty. Do not assume that paying the monetary late fee alone authorises business while the certificate remains suspended. Check and resolve the status before continuing operations.

Correct an error through the proper facility

The revised-return facility allows errors in an already filed return to be addressed. Under the standing framework, updates before 31 May can be made without a revision fee. One revised or updated filing after that date is permitted within the prescribed period ending 31 March of the following year, with the relevant fee.

The 2024 order sets the post-deadline revision fee by timing: one year's licence fee plus GST for revision within three months after 31 May, and two years' licence fee plus GST for the later period up to 31 March. A late original return and a revised return are different events; the revision fee should not be confused with the daily charge for failure to file the original return.

For a year with an extension, confirm the revision window and displayed fee against the applicable order rather than assuming that every revision deadline moved automatically. Preserve the first return, corrected return, explanation and fee receipt. The limited revision facility is a reason to review the original carefully, especially when several factories supply figures.

A CA's year-end process can place this working file alongside financial records managed with assureOffice. The return remains a specialist food-compliance submission, and assureoffice.in should not be understood as providing a verified direct Form D-1 filing feature.

Frequently asked questions

1. Does every FSSAI licensee file Form D-1?

No. Applicability follows activities. Licensed manufacturing, repacking, relabelling, importing and manufacturer-exporting are central examples; a restaurant or retailer does not become liable solely by holding a licence.

2. Must an inactive licensed manufacturer consider a nil return?

Yes. Nil operations should be reported through the appropriate facility where the return applies. Preserve evidence that no relevant activity occurred rather than treating the absence of invoices as an exemption.

3. Are zero sales and zero production the same?

No. Production may remain in closing stock, and sales may come from opening stock. Reconcile the quantity fields separately instead of copying a nil turnover figure into every part of the return.

4. Does an importer file without an Indian factory?

The importer activity is itself within annual-return applicability. Review its imports and supporting records; not owning manufacturing machinery does not remove the relevant reporting requirement.

5. Does a relabeller report only its own physical production?

No. Its outsourced manufacturing model must be considered. Obtain the relevant product and quantity information from the contract manufacturers and reconcile it with the brand operator's records.

6. Which period does the 2025–26 return cover?

It covers the financial year from 1 April 2025 to 31 March 2026, with the actual operating and certificate history relevant to the business. It is not a calendar-year return.

7. What was the 2025–26 filing deadline?

The normal deadline was extended to 15 June 2026. Retain the applicable extension evidence and avoid relying on older website banners referring to unrelated financial years.

8. Is 15 June now the permanent annual deadline?

No. The standing date remains 31 May unless an applicable extension changes it. Do not roll a one-year concession into the next reporting year without a fresh legal basis.

9. Is a physical return accepted?

The required route is online through FoSCoS. Retain evidence of actual online submission, rather than relying on an emailed spreadsheet or a physical acknowledgement for documents delivered separately.

10. What is the daily late amount?

It is ₹100 per day under the annual-return framework, subject to the applicable five-times-annual-licence-fee cap. For an extended year, confirm the applicable start date rather than using a generic calculation.

11. Does reaching the penalty cap remove the duty?

No. The cap limits the monetary amount under that framework. It does not make the missing return complete or resolve the separate consequences of default under the 2026 validity provisions.

12. Does perpetual validity remove annual returns?

No. Continuing certificate validity does not abolish activity-based returns or annual fees. The 2026 framework expressly links default in applicable obligations to deemed suspension.

13. What if the business closed halfway through the year?

Preserve and report the relevant operating-period information, and complete closure and surrender separately. Closure is not a reason to delete the earlier activity or discard its production and stock records.

14. Does migration to registration cancel the previous year's duty?

Do not assume so. Examine the licensed activity and dates during the reporting year. Seek a written direction if the retained-number or portal migration record prevents the appropriate historical filing.

15. Can a missing portal button be treated as an exemption?

No. Raise a documented mapping or technical issue with the supporting certificate history. A software display is evidence to investigate, not a substitute for determining legal applicability.

16. Can an already submitted return be corrected?

Yes, through the prescribed revised-return facility and within its limits. Keep the original and correction explanation; do not submit an unrelated new licence application to escape an erroneous return.

17. Is a revised return always free?

No. The standing framework permits free revision up to 31 May, with a prescribed fee for the limited later revision window. Review the applicable year-specific directions and displayed calculation before payment.

18. Can the same figures be used for every group company?

No. Match each declaration to the legal operator, licence and activity. Shared brands, factories or accountants do not justify combining separate companies' figures without analysing the form's requirements.

19. What if units use different quantity measures?

Create supported conversions before filing. Retain pack sizes and calculations so that cases, pieces, litres and kilograms are not confused or double-counted in product-wise reporting.

20. What should the completed return file contain?

Keep the applicability decision, certificate history, product reconciliation, approved figures, submitted return and payment or status evidence. Add any extension, correction or authority direction needed to explain unusual closure or migration facts.