The FSSAI Annual Return (Form D1) is filed once a year by 31 May by most food manufacturers and importers holding a State or Central licence. Dairy units also file Form D2 half-yearly. Late filing attracts a government late fee of ₹100 per day, capped at five times the annual fee. Basic Registration holders and pure retailers, restaurants and canteens are exempt.
What is the FSSAI Annual Return?
The FSSAI Annual Return is a mandatory yearly declaration in which a licensed food business reports the quantity and value of food products it manufactured, handled, imported or sold during the financial year. It is filed under Regulation 2.1.13 of the FSS (Licensing and Registration) Regulations, 2011, and is submitted through the FoSCoS portal (foscos.fssai.gov.in), which replaced the older FLRS system.
There are two return forms. Form D1 is the standard annual return for food manufacturers, importers and certain other licensed businesses. Form D2 is a separate half-yearly return that applies specifically to units engaged in the manufacture of milk and milk products. The return is a compliance filing distinct from the licence itself, and it must be filed every year your licence is active.
CAREALL prepares and files both returns on your behalf as your consultant; the licence itself and the return acknowledgement are issued and recorded by the Food Safety and Standards Authority of India.
Who has to file the FSSAI Annual Return?
You must file the FSSAI Annual Return if you hold a State or Central FSSAI licence and your business involves manufacturing, importing, or handling food products of the categories the return covers. The obligation is tied to the nature of your activity and your licence type, not merely to your turnover.
In practice, food manufacturers, packers, relabellers, importers and exporters holding a valid State or Central licence are the businesses that most commonly need to file Form D1. Every food business operator (FBO) that manufactures or imports food articles is expected to report annually. A business operating across multiple premises files a return for each licensed unit.
If you are unsure whether your specific activity attracts the return, it is safer to confirm than to assume you are exempt, because a missed return carries a daily penalty. CAREALL reviews your licence category and product line and tells you precisely which return, if any, applies to your case.
- Food manufacturers holding a State or Central licence
- Importers and exporters of food articles (who also require an Import-Export Code, IEC)
- Packers, re-packers and re-labellers of food products
- Milk and milk product units (these file Form D2, see below)
What is the difference between Form D1 and Form D2?
Form D1 is the general annual return filed once a year by 31 May for the preceding financial year, while Form D2 is a half-yearly return filed only by units that manufacture milk and milk products. A dairy manufacturing unit is therefore required to file Form D2 twice in a year for the two half-yearly periods, in addition to being outside the ordinary D1 cycle.
The table below sets out the key distinctions so you can identify which return your business is required to submit.
Filing the wrong form, or filing only D1 when D2 was required, can leave you technically non-compliant. If your unit handles both dairy and non-dairy food lines, confirm your obligations rather than guessing.
| Feature | Form D1 | Form D2 |
|---|---|---|
| Who files | Food manufacturers, importers and other covered licensees | Units manufacturing milk & milk products (dairy) |
| Frequency | Once a year | Half-yearly (twice a year) |
| Deadline | By 31 May for the previous financial year | Within one month of the end of each half-year period |
| Licence level | State or Central licence holders | State or Central dairy licence holders |
| Covers | Food articles manufactured/handled/imported & value | Quantity of milk & milk products handled |
When is the FSSAI Annual Return due?
The FSSAI Annual Return in Form D1 is due on or before 31 May every year, covering the financial year that ended on the previous 31 March. For example, the return for the financial year 2025-26 (1 April 2025 to 31 March 2026) must be filed by 31 May 2026.
Form D2, the half-yearly dairy return, is due within one month of the end of each half-year period, so a dairy unit files it twice each year rather than once. Because these deadlines recur annually and the penalty accrues daily, it is prudent to prepare the return well before the cut-off rather than at the last moment.
CAREALL tracks these dates for the businesses we manage and files ahead of the deadline; we track the submission through to acknowledgement on FoSCoS so you have proof of filing on record.
| Return | Applies to | Period covered | Due date |
|---|---|---|---|
| Form D1 | Most State/Central licensees | Financial year (Apr–Mar) | 31 May each year |
| Form D2 (1st half) | Dairy units | 1 Apr – 30 Sep | Within 1 month of period end |
| Form D2 (2nd half) | Dairy units | 1 Oct – 31 Mar | Within 1 month of period end |
Who is exempt from filing the FSSAI Annual Return?
Businesses holding only an FSSAI Basic Registration (turnover below ₹1.5 crore) are exempt from filing the Annual Return, as are several categories of retail and service food businesses even where they hold a licence. The return is essentially aimed at manufacturers and importers, not at pure retailers or caterers.
The FSS Regulations specifically exempt fast-food joints, restaurants, canteens, grocery stores and certain retailers from the annual return requirement. If your business is only selling or serving food rather than manufacturing, packing or importing it, you are generally not required to file Form D1.
However, exemption from the return does not exempt you from holding a valid FSSAI licence or registration and keeping its annual fee paid so it stays active. If you are uncertain whether your activity is manufacturing or pure retail, CAREALL will assess your category before any deadline is missed.
- Holders of FSSAI Basic Registration (turnover under ₹1.5 crore)
- Restaurants, hotels and canteens
- Fast-food outlets and food service establishments
- Grocery stores, kirana shops and general retailers
What is the penalty for late filing of the FSSAI Annual Return?
If the Annual Return is not filed by the due date, a government late fee of ₹100 per day of delay is levied, capped at a maximum of five times the annual fee, and this amount continues to accumulate until the cap is reached or the return is filed. The late fee runs from the day after the deadline until the return is actually submitted.
Because the charge is calculated per day, a delay of a few months can grow into a substantial figure, up to the five-times-annual-fee cap, as it keeps accumulating for every day the return stays unfiled. Continued non-compliance can also invite further action against the licence itself.
This annual-return late fee is separate from the recurring annual fee you pay to keep the licence itself active. To avoid it, treat the return deadline as a fixed obligation. CAREALL files ahead of time so the late fee never starts.
| Days late | How it adds up |
|---|---|
| 10 days | Grows each day |
| 30 days | Three times the 10-day total |
| 100 days | Ten times the 10-day total |
| 1 year (365 days) | A full year of daily charges |
How do I file the FSSAI Annual Return on FoSCoS?
The FSSAI Annual Return is filed online by logging in to the FoSCoS portal (foscos.fssai.gov.in), selecting the relevant licence, opening the Annual Return section and submitting Form D1 (or Form D2 for dairy) with the product quantities and values for the period. The system generates an acknowledgement once the return is accepted.
You will need details of each food product handled during the year, including the quantity manufactured or imported and its value, along with any import or export figures where applicable. Accuracy matters, because the declared figures should reconcile with your books and licence category.
Rather than navigate the portal and reconcile the data yourself, most manufacturers hand the filing to a consultant. CAREALL collects your figures, prepares the return, files it on FoSCoS and tracks it to acknowledgement; our professional fee is separate from any government charge.
Frequently asked questions
Is the FSSAI Annual Return the same as keeping my licence active?
No. They are two separate obligations. The Annual Return (Form D1) is a yearly declaration of the food you manufactured or handled, due by 31 May, with its own ₹100-per-day late fee (capped at five times the annual fee) if missed. Keeping the licence active is separate: an FSSAI licence is now valid indefinitely and you simply pay a recurring annual fee to keep it from being suspended. You may need to attend to both.
Do restaurants and cloud kitchens have to file the Annual Return?
Generally no. Restaurants, hotels, canteens and fast-food outlets are specifically exempt from the FSSAI Annual Return because they serve rather than manufacture food. A pure delivery-only cloud kitchen usually falls in the same category. However, if the same business also manufactures or packs food products for wider sale, that activity may attract Form D1. Confirm your exact category before assuming exemption.
What happens if I never file the FSSAI Annual Return?
The daily penalty keeps accumulating for every day the return remains unfiled, so the amount can become large over time. Persistent non-compliance can also jeopardise your licence and complicate future modifications. If you have missed past returns, file the pending ones promptly to stop the penalty from growing further.
When exactly is Form D2 due for a dairy business?
Form D2 is a half-yearly return, so a dairy unit files it twice a year. Each return is due within one month of the end of its half-year period. This is in addition to, not instead of, the general compliance a State or Central dairy licensee must maintain. Because it is filed twice annually, dairy operators should diarise both deadlines carefully.
Can CAREALL file the FSSAI Annual Return for me?
Yes. CAREALL prepares and files both Form D1 and Form D2 on the FoSCoS portal as your consultant. We collect your yearly product quantities and values, submit the correct form before the deadline, and track it through to acknowledgement. The licence and return are recorded by the FSSAI; our professional fee is separate from any government charge.
This guide is kept current for 2026. It is general information, not legal advice — for your specific case, talk to a CAREALL consultant.