FSSAI licence stuck? File one RTI

Short version. Every Food Business Operator needs an FSSAI Registration or licence under Section 31, Food Safety and Standards Act 2006, applied for on foscos.fssai.gov.in. Since 1 April 2026 the bands are: Basic Registration up to ₹1.5 crore turnover, State licence ₹1.5–50 crore, Central licence above ₹50 crore (or inter-state, import-export, and the other Central-category cases) — and licences/registrations are now perpetual, with no renewal clock. When the file stalls, the RTI Act is the only lever that puts a dated, signed obligation on the authority: 30 days, ₹10, first appeal if evasive.

Aakash runs a mid-size cloud kitchen in Bengaluru — ₹8 crore turnover, so squarely a State licence business even after the 2026 re-banding. His fresh licence application sat on “Pending Designated Officer inspection” for six weeks, with the portal showing nothing and the local office saying only “it is in process”.

He filed a six-point RTI to the Karnataka FDA Designated Officer for his district. Fifteen days later the reply came in writing: the inspection had been scheduled, with a date. Inspection done, licence issued eleven days after that. Nothing technical had changed — only that a delay now needed a name and a reason on departmental letterhead.

1. Designated Officer inspection not scheduled (the most common stall — the DO commissions the Food Safety Officer's inspection in licence cases).
2. Document deficiency never communicated — the file is marked “incomplete” internally while the portal still says “under process”.
3. Category/re-banding questions after the 2026 amendment — businesses migrating between Basic Registration and State licence can fall between the two desks.
4. Modification applications (new premises, new product line) waiting on a re-inspection that no one has calendared.
5. Suspension or cancellation orders not supplied in writing — ask for the order and the notings behind it.

- The 60-day deemed clock (licences). Under the Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations 2011, a licence is to be issued or refused within the regulation's outer limit from a complete application, and the applicant may commence business on deemed approval pending inspection, while meeting the Schedule 4 hygiene requirements, where the authority fails to decide in time. Ask your RTI question against that clock: “state the date my application was marked complete, and why no decision has issued within the prescribed period.” - The 30-day RTI clock. Section 7(1), RTI Act 2005. Silence for 30 days is a deemed refusal — straight to the first appeal under Section 19(1). Every question below is drafted to make evasion visible.

To, The Public Information Officer,
c/o [State FDA / FSSAI Regional Office], [Address]

Subject: Application under Section 6(1), RTI Act 2005 —
         status of FSSAI licence/registration application

  Business name     : [Name]
  FBO type          : [Manufacturer / Trader / Restaurant / Cloud kitchen]
  FOSCOS reference  : [Application ID]
  Category applied  : Basic Registration / State / Central licence
  Application date  : DD-MM-YYYY

Please provide:
1. The current status and stage of the application as recorded in the file.
2. The date on which the application was marked complete, and any
   deficiency noted, with the date it was recorded.
3. Whether a Designated Officer inspection was ordered; if yes, the date
   ordered and the date conducted, and a copy of the inspection report.
4. The reason, as recorded in writing, for the delay beyond the period
   prescribed under the FSS (Licensing and Registration) Regulations 2011.
5. The name and designation of the officer currently holding the file.
6. The date by which the licence/registration will be issued or refused.

Fee of ₹10 paid by [IPO / DD / online]. Information is sought within 30
days under Section 7(1) of the RTI Act.

[Name + signature + address + date]

Question 4 — reason as recorded in writing — is the one that moves files. Officers can ignore phone calls; a signed reply saying “no reason recorded” is a first-appeal exhibit.

1. Central licence → PIO, FSSAI (headquarters or the regional office for your state). FSSAI is also reachable through rtionline.gov.in.
2. State licence / Basic Registration → the State Food Safety Commissioner's department / Designated Officer for your district. These are public authorities of the state; where the state runs its own RTI portal, use it, else a printed application with a ₹10 IPO works everywhere.
3. Not sure which desk holds it? File at the State FDA with a line asking them to transfer to the correct public authority under Section 6(3) within five days.

Cite the deemed-commencement position in your RTI, keep operating to Schedule 4 hygiene standards, and ask (question 4) why no decision issued. Take a lawyer's view before relying on deemed approval for a Central licence with conditions attached.

Section 63, FSS Act 2006: imprisonment up to six months and fine up to ₹5 lakh, and the 2026 amendment regime tightened enforcement around it. Never let a “stuck” application put you in that slot — document the application and the chase.

From 1 April 2026 licences and registrations are perpetual until surrendered, cancelled or suspended. If a portal still demands a renewal, an RTI asking “under which rule does a renewal survive the 2026 amendment” clears it quickly.

Yes — ask for the inspection report, the sample analysis records and the notings behind the order; the same ₹10 machinery applies.

A stuck FSSAI file is rarely lost — it is parked. The deemed-approval rule protects your launch date, and the RTI converts a parked file into a question that a named officer must answer on paper within 30 days. Parked files stay parked; questioned files move.

- Food Safety and Standards Act 2006, §§31, 63. - Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations 2011 — inspection and issue timelines; Schedule 4 hygiene; FSSAI regulations page. - FSS (Licensing and Registration of Food Businesses) Amendment Regulations 2026 — new turnover bands and perpetual validity, summarised on our rule-change page. - foscos.fssai.gov.in — the application portal. - RTI Act 2005, §§6(1), 6(3), 7(1), 19(1).

• How to apply for an FSSAI food licence — complete 2026 guide
• FSSAI Basic Registration limit raised to Rs 1.5 crore
• Trade licence stuck? File one RTI
• Pollution board consent stuck? File an RTI
• Aadhaar update stuck? File one RTI to UIDAI
• The RTI Playbook book

Last reviewed: 27 August 2026. Turnover bands and perpetual validity verified against the FSS (Licensing and Registration) Amendment Regulations 2026 (notified 10 March 2026, effective 1 April 2026) as covered on our rule-change page; the 60-day issue/inspection scheme and Schedule 4 deemed-commencement position checked against the 2011 Licensing Regulations; two un-sourceable case citations from the old page removed.