Process
FSSAI Annual Return Filing: Who Must File and How
Complianceer Team · Sep 8, 2026 · 5 min read
FSSAI annual return guide: who files Form D-1 and D-2, the 31 May deadline, ₹100 per day penalty, data you need and how to file on FoSCoS step by step.
Quick answer: Food manufacturers (including repackers and relabellers), importers and manufacturer-exporters with an FSSAI licence must file the annual return in Form D-1 on FoSCoS by 31 May for the previous financial year. Late filing costs ₹100 per day from 1 June, up to 5 times the annual licence fee. Milk and milk product manufacturers also file half-yearly Form D-2 returns.
The annual return is how FSSAI tracks what licensed manufacturers and importers actually produced and sold. It is short, but it is strictly enforced: FSSAI's April 2024 advisory says no request to waive the late penalty will be considered, and FoSCoS links pending returns to licence actions such as renewal.
Who must file
| Business type | Form D-1 (annual) | Form D-2 (half-yearly) |
|---|---|---|
| Manufacturer with State or Central Licence | Yes | Only for milk and milk products |
| Repacker or relabeller | Yes | Only for milk and milk products |
| Importer | Yes | No |
| Manufacturer-exporter | Yes | No |
| Restaurant, caterer, retailer, distributor | Not usually | No |
| Basic Registration holder | Not usually | No |
A separate return is required for every licence, even if one company holds several. Food service, trading and storage licences generally do not file Form D-1, but check your FoSCoS dashboard because FSSAI can extend return requirements.
Deadlines
| Return | Period covered | Due date |
|---|---|---|
| Form D-1 | 1 April to 31 March (previous financial year) | 31 May |
| Form D-2, first half | 1 April to 30 September | 31 October |
| Form D-2, second half | 1 October to 31 March | 30 April |
If 31 May falls on a weekend, do not assume an extension. File early in May while the portal is less busy.
Penalty for late filing
- ₹100 for every day of delay from 1 June
- Maximum penalty of 5 times the annual licence fee
- No waiver requests are considered, per FSSAI's 2024 advisory
- Pending returns can block renewal, and missed returns can lead to suspension under the 2026 framework
For a State Licence at ₹5,000 a year, the maximum penalty is ₹25,000. For a Central Licence at ₹7,500, it is ₹37,500.
What data you need
Form D-1 asks for product-wise information for each class of food handled during the year:
- Food category and product name as licensed
- Quantity manufactured, imported or repacked
- Quantity sold or dispatched, and closing stock
- Average selling price or value where asked
- Export quantities for manufacturer-exporters
Form D-2 for dairy asks for milk procurement by source, fat and SNF content, milk products made, sales and stock. Pull figures from your production registers, purchase and sales ledgers, and GST returns so the numbers reconcile.
How to file on FoSCoS
- Log in to FoSCoS with the licence holder's credentials.
- Open Annual Return under the licence you are filing for.
- Select the financial year and Form D-1 (or D-2 for dairy).
- Enter product-wise quantities and values for every licensed product.
- Review the totals against your sales records and GST data.
- Submit and pay any late penalty shown.
- Download the acknowledgement and file it with your licence records.
FSSAI allows a revised return without fee if you correct it by 31 May, and with a fee if you revise it between 1 June and 31 March of the following year.
Annual return and the 2026 reforms
Perpetual validity removes routine renewal, but FSSAI's 2026 FAQs make clear that applicable returns remain mandatory. A licence can be treated as suspended if returns or annual fees are not filed or paid. Filing on time is now one of the main ways to keep a perpetual licence active. Our validity and renewal timeline explains the transition.
Common mistakes
- Filing one return for several licences
- Reporting zero production because the plant was idle for part of the year
- Product names that do not match the licensed categories
- Waiting for the last week of May and hitting portal slowdowns
- Missing Form D-2 for dairy units
Complianceer handles annual returns as part of annual compliance management, with reminders through renewal tracking.
Frequently asked questions
Who needs to file the FSSAI annual return?
Licensed manufacturers, including repackers and relabellers, importers and manufacturer-exporters must file Form D-1 every year. Milk and milk product manufacturers also file Form D-2 twice a year.
What is the due date for FSSAI annual return?
Form D-1 for the previous financial year is due by 31 May. Form D-2 is due by 31 October and 30 April for the two half-year periods.
What is the penalty for late FSSAI annual return?
The penalty is ₹100 per day from 1 June, capped at 5 times the annual licence fee. FSSAI does not consider waiver requests.
Do restaurants need to file the FSSAI annual return?
Generally no. Form D-1 applies to manufacturers, repackers, relabellers, importers and manufacturer-exporters. Restaurants should still check their FoSCoS dashboard for any notified return.
Do Basic Registration holders file annual returns?
Usually not. The Form D-1 requirement under Regulation 2.1.13 applies to licensees in manufacturing and import activities.
Can I file the FSSAI annual return offline?
No. FSSAI's 2024 advisory says annual returns are accepted online through FoSCoS only.
Can I revise an FSSAI annual return after filing?
Yes. Revision is free up to 31 May and allowed with a fee from 1 June until 31 March of the following year.