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The state government of Maharashtra has modified certain clauses of the consent fee system released in August 2026. This modification is being done via Government Resolution No. ENV-2026/CR-158/TC-1, dated 24 September 2026, from the Department of Environment & Climate Change. This Government Resolution has made changes to certain clauses of the older Government Resolution dated 25 August 2026.
The changes matter because different types of establishments are now dealt with in different ways. A qualifying Micro or Small enterprise may fall under the deemed Consent to Establish route. A housing or infrastructure project may need to consider sewage-generating slabs. A diesel-generator-only establishment has a separate capacity-based fee table. Healthcare establishments have their own combined consent and Bio-Medical Waste treatment.
The same amendment also introduces a single-step procedure for consent under the Water and Air Acts along with applicable authorisations under Waste Management Rules. It further states that 5% of the consent fee is to be credited to the Central Pollution Control Board as a service fee.
For businesses, the first question should therefore be: Which amended clause applies to the establishment? Only after that should the applicable fee or consent route be worked out.
| Particular | Details |
| Issuing authority | Government of Maharashtra |
| Department | Environment and Climate Change Department |
| GR number | ENV-2026/CR-158/TC-1 |
| Date | 24 September 2026 |
| Earlier GR amended | 25 August 2026 |
| Regulatory authority concerned | Maharashtra Pollution Control Board |
| Nature of update | Amendment to selected consent-fee and consent-procedure provisions |
| Main affected categories | Micro and Small enterprises, local bodies, infrastructure projects, DG-only establishments, healthcare establishments and certain BMW-generating entities |
| Effective date | Not separately stated in the September GR |
| Main compliance issue | Correct identification of category, fee basis and consent route |
The document is best read as a correction and refinement of the August framework. It substitutes selected clauses and leaves the remaining parts of the earlier GR untouched.
The September Resolution replaces six specific parts of the earlier Government Resolution.
| Clause | Subject |
| 2(d) | Micro and Small enterprises |
| 3(a) | Local Bodies and Infrastructure projects |
| 3(e) | Diesel-generator-only establishments |
| 4 | Healthcare establishments |
| 5(a) | Single-step consent and waste authorisation |
| 5(d) | CPCB service fee |
These six amendments are not identical in nature. Some deal with fee calculation. Some deal with consent procedure. One creates a deemed CTE route for a limited class of Micro and Small enterprises, while another deals with how part of the consent fee is to be credited to CPCB.
That is why a business should not read the September GR as a single “new fee chart”.
The September amendment sits within a broader change in the consent framework.
The GR records that Section 21A was inserted in the Air Act, 1981 and Section 27A in the Water Act, 1974 through the Jan Vishwas (Amendment of Provisions) Act, 2023. After that, the Ministry of Environment, Forest and Climate Change issued the Control of Air Pollution and Control of Water Pollution (Grant, Refusal or Cancellation of Consent) Guidelines, 2025. Those guidelines were later amended in 2026 and, according to the Maharashtra Resolution, the amended guidelines were in force from 27 January 2026.
Maharashtra enacted its own GR regarding the consent fee on 25 August 2026. Proposal number AS(T)/2026/21 was forwarded by MPCB on 7 September 2026 for some modifications. This was followed up by the state government, and an amendment was enacted by the state government on 24 September 2026.
So the September document should be understood as a follow-up amendment based on MPCB's proposal, not as the starting point of the consent-fee framework.
Water (Prevention and Control of Pollution) Act, 1974
Consent under the Water Act is one part of the pollution-control approval structure addressed by the Resolution. The September GR also refers to Section 36 of the Water Act while dealing with the CPCB service-fee provision.
Air (Prevention and Control of Pollution) Act, 1981
Consent under the Air Act is dealt with alongside consent under the Water Act. The preamble refers to Section 21A, while the later CPCB service-fee clause refers to Section 33 of the Air Act.
Environment (Protection) Act, 1986
The Environment (Protection) Act becomes relevant because the amended single-step procedure also covers authorisations under applicable Waste Management Rules notified under that Act.
Maharashtra Pollution Control Board
The MPCB is still the major state-level pollution control agency engaged in administering consent. The question is whether the applicant’s project type and environmental situation make him eligible for either of the new fee schemes.
| Date | Development | Why It Matters |
| 27 January 2026 | Amended Central consent guidelines stated to be in force | Forms the background framework |
| 25 August 2026 | Maharashtra issued the original consent-fee GR | Created the earlier state position |
| 7 September 2026 | MPCB sent proposal for amendments | Led to review of selected clauses |
| 24 September 2026 | Maharashtra issued the amendment GR | Replaced six specific provisions |
This timeline shows why there are two Government Resolutions with the same file reference, which appear so close together. It is because the September document amends the previous one rather than creating an entirely new scheme.
The September GR tells us which clauses have been replaced, but it does not reproduce the complete old wording of every provision.
For that reason, an exact old-vs-new comparison should only be made after referring to the official 25 August 2026 GR.
What the September document clearly confirms is this:
| Compliance Area | Revised Position Under September GR |
| Micro and Small enterprises | Deemed CTE route for qualifying enterprises in duly notified industrial areas on submission of self-certified Form-I |
| Local bodies/infrastructure | Revised sewage-based annual fee table |
| DG-only establishments | Capacity-based annual fee table |
| Healthcare establishments | Combined consent and BMW authorisation treatment |
| Waste authorisation | Single-step procedure along with Water/Air Act consent |
| CPCB service fee | 5% of consent fee to be credited to CPCB |
These revised provisions are directly stated in the September GR.
Clause 2(d) is particularly relevant for smaller industrial units.
The amended clause states that Micro and Small enterprises located in duly notified industrial estates or areas will have Consent to Establish deemed to be granted upon submission of a self-certified Form-I.
That wording contains three important conditions.
1. The enterprise must be Micro or Small
The clause does not mention Medium enterprises.
2. The unit must be in a duly notified industrial estate or area
MSME status by itself is not enough.
3. A self-certified Form-I must be submitted
The deemed CTE treatment is tied to submission of this form.
Does This Mean Every MSME Is Exempt from MPCB Consent?
No. That is not what the GR says.
| Eligibility Point | Requirement |
| Enterprise type | Micro or Small |
| Location | Duly notified industrial estate/area |
| Filing requirement | Self-certified Form-I |
| Result stated by GR | CTE deemed granted |
The clause creates a deemed Consent to Establish route for a defined category. It does not remove every environmental approval or compliance duty that may apply to an enterprise.
A unit may still have to check other environmental permissions, waste authorisations or operational requirements depending on the activity it carries out.
For businesses using MPCB consent services, this distinction is important because eligibility should be checked before treating the unit as covered by the deemed route.
Clause 3(a) deals with Local Bodies and Infrastructure projects. The per-year fee is linked to the quantity of sewage generated.
The GR keeps separate rates for:
Sewage-Based MPCB Fee Slabs
| Quantum of Sewage Generated | Local Body / Housing | Other than Housing |
| Up to 10 KLD | 5,000 rupees | 7,500 rupees |
| Above 10 up to 50 KLD | 15,000 rupees | 22,500 rupees |
| Above 50 up to 100 KLD | 25,000 rupees | 37,500 rupees |
| Above 100 up to 300 KLD | 35,000 rupees | 52,500 rupees |
| Above 300 up to 500 KLD | 55,000 rupees | 82,500 rupees |
| Above 500 KLD up to 1 MLD | 65,000 rupees | 97,500 rupees |
| Above 1 up to 5 MLD | 75,000 rupees | 1,12,500 rupees |
| Above 5 up to 10 MLD | 1,00,000 rupees | 1,50,000 rupees |
| Above 10 up to 25 MLD | 2,00,000 rupees | 3,00,000 rupees |
| Above 25 MLD | 4,00,000 rupees | 6,00,000 rupees |
These figures come directly from substituted Clause 3(a).
KLD means kilolitres per day. MLD means million litres per day.
The rate therefore depends on both the quantity of sewage and the correct project category.
The table itself shows that the two categories are treated separately.
For example, a project cannot simply identify that it generates a certain amount of sewage and stop there. It must also know whether the relevant column is:
That distinction directly changes the annual fee.
For developers, infrastructure companies and project consultants, this makes project classification an important part of fee calculation.
The GR adds another layer for infrastructure projects.
It specifically says that Consent to Establish for these projects will be based on the capital-investment formula in Part 2(a).
This means the document uses more than one basis.
These two should not be mixed.
The September amendment does not reproduce the complete Part 2(a) formula, so the earlier GR remains important where an exact CTE fee calculation is required.
An MPCB Consent to Establish consultant reviewing an infrastructure application should therefore check both the project category and the correct fee base, rather than applying only the sewage table.
The GR expressly states that there will be no rebate on Consent to Establish for Building and Construction projects falling under Categories 10.0 and 10.1.
This is not a general statement that applies to every type of infrastructure project.
It applies to the categories specifically mentioned in the Resolution.
Builders and developers falling under these categories should therefore avoid assuming that a CTE rebate available elsewhere in the framework can automatically be used for their project.
Clause 3(e) provides a separate per-year fee for establishments where a diesel generator is the only source.
The words “only source” matter.
DG Capacity-Wise Annual Fee
| DG Rating | Annual Fee |
| ≤ 250 KVA | Nil |
| 250 KVA to ≤ 500 KVA | 1,000 rupees |
| 500 KVA to ≤ 1 MVA | 2,000 rupees |
| ≥ 1 MVA | 5,000 rupees |
The rates are taken from the amended clause.
KVA means kilovolt-amperes. MVA means megavolt-amperes.
Does This Table Apply to Every Business With a DG Set?
The Resolution does not say that.
It specifically refers to establishments where the diesel generator is the only source.
A factory or commercial unit that has a DG set as backup should therefore not automatically use this table without checking whether the clause actually covers its situation.
Similarly, a Nil fee for DG capacity up to 250 KVA should not be treated as proof that no other pollution-control requirement applies.
Healthcare establishments are dealt with separately in Clause 4.
The amended clause is titled:
Healthcare Establishments – Combined consent and BMW Authorization.
It states that the fee structure for healthcare establishments will be the same as that for industries referred to in Clause 2 of the earlier GR.
BMW means Bio-Medical Waste.
For hospitals, clinics and other healthcare establishments, the September amendment therefore needs to be read along with the relevant industry fee structure in the August GR.
The wording of Clause 4 brings consent and Bio-Medical Waste authorisation into one combined framework for healthcare establishments.
This does not mean BMW obligations disappear.
Healthcare establishments still need to determine:
A Bio-Medical Waste authorisation consultant or environmental compliance professional should therefore examine the establishment's actual category rather than treating all hospitals in the same way.
The September GR gives a clear exemption to certain public healthcare establishments.
It states that no fees will be charged to health-service establishments owned and operated by:
The words owned and operated are important.
A healthcare facility should not assume that being connected with a public authority automatically exempts it.
The GR does not expressly extend this fee exemption to:
Those cases require separate examination.
The amended clause also creates a separate treatment for:
For these categories, the GR says Consolidated Consent and Authorization will be on a capital-investment basis.
This is different from simply applying the general healthcare establishment rule.
A medical college or industrial unit generating BMW should therefore first determine whether this specific proviso applies.
Clause 5(a) introduces a procedural change that is relevant beyond healthcare.
The GR states that a single-step procedure will be followed for:
The clause ends with an important qualification: “as per applicability.”
| Regulatory Area | Position Under Amended Clause |
| Water Act consent | Included |
| Air Act consent | Included |
| Waste Management Rule authorisation | Included where applicable |
| Applicability of each waste rule | Must still be checked separately |
What Does “As Per Applicability” Mean?
Not every business is governed by every Waste Management Rule.
The establishment must first identify which waste stream or environmental rule applies to its operations.
The single-step procedure appears to integrate processing. It should not be read as a blanket authorisation covering every environmental law.
No such removal is stated in the GR.
A combined process is not the same thing as removal of substantive obligations.
Businesses may still need to comply with applicable requirements relating to:
The September GR only states that consent and applicable authorisation are to be dealt with through a single-step procedure.
Clause 5(d) states that 5% of the consent fee shall be credited to the Central Pollution Control Board as a service fee.
The clause refers to Section 36 of the Water Act and Section 33 of the Air Act/the relevant guidelines.
This point needs careful wording.
The Resolution says that 5% of the consent fee is to be credited to CPCB.
It does not expressly say that an applicant must pay:
Consent fee + an additional 5% surcharge.
Until such treatment is expressly established from the applicable framework, the safer reading is to describe it as allocation of 5% of the consent fee to CPCB.
| Stakeholder | Clause | Main Change | Main Check |
| Micro enterprise | 2(d) | Deemed CTE route | Enterprise status, location, Form-I |
| Small enterprise | 2(d) | Deemed CTE route | Enterprise status, location, Form-I |
| Local Body/Housing project | 3(a) | Sewage-based annual fee | Sewage quantity |
| Other infrastructure project | 3(a) | Separate sewage-based rate | Project category |
| Building/construction project | 3(a) | No CTE rebate for Categories 10.0/10.1 | Category |
| DG-only establishment | 3(e) | DG-rating-based fee | Capacity and only-source condition |
| Healthcare establishment | 4 | Combined consent/BMW treatment | Applicable fee structure |
| Government healthcare establishment | 4 | Fee exemption | Ownership and operation |
| Medical College/R&D/BMW industry | 4 | Capital-investment basis | Correct category |
| Other regulated industry | 5(a) | Single-step process | Applicable waste rules |
There is no one formula for every applicant.
The fee basis varies depending on the nature of the establishment.
| Category | Main Basis |
| Local Body/Housing annual fee | Sewage generation |
| Other infrastructure annual fee | Sewage generation |
| Infrastructure Consent to Establish | Capital investment |
| DG-only establishment | DG capacity |
| Healthcare establishment | Industry fee structure referred to in Clause 2 |
| Medical College/R&D/BMW-generating category | Capital investment |
This is why getting the classification right is more important than simply searching online for an MPCB fee amount.
Businesses should first identify the basis attached to their category.
Capital Investment
Relevant where the GR specifically refers to the capital-investment formula or capital-investment basis.
Sewage Quantity
Relevant to annual fees for:
Local Body/Housing projects; and
Other than Housing infrastructure projects.
DG Capacity
Relevant to establishments where the diesel generator is the only source.
Using the wrong basis can result in the wrong fee being calculated even if the arithmetic itself is correct.
For the Qualifying MSMEs, the Clause 2(d) could make the process of CTE easier as the GR provides deemed grant after submission of a self-certified Form I.
But there is a clear boundary.
The unit must be located in a duly notified industrial estate or area.
For a Micro or Small enterprise planning to use this route, the practical checks are:
An MPCB consent consultant can assist where the unit is unsure whether it falls within the deemed-CTE provision or needs to follow another consent route.
Local bodies and housing projects now have a clear table of sewage-linked per-year fees.
The main work for these applicants is likely to be around:
For large projects, even a small classification error can place the project in a different fee category.
Infrastructure projects need to pay attention to two separate concepts.
First, the annual fee under Clause 3(a) depends on the amount of sewage generated.
Second, Consent to Establish for these projects is tied to the capital-investment formula in Part 2(a).
Building and Construction projects falling under Categories 10.0 and 10.1 also do not receive the CTE rebate referred to in the GR.
For developers, this means environmental budgeting should not be based solely on sewage quantity.
Healthcare establishments need to identify which part of Clause 4 applies to them.
A hospital or healthcare facility may need to check:
Treating all healthcare establishments as one category can lead to incorrect fee treatment.
For industries requiring waste-related authorisations, Clause 5(a) can affect the way the application is processed.
The single-step mechanism may bring together:
But the industry must still know which Waste Management Rule applies to its operations.
A business seeking environmental compliance services should therefore ask for an applicability assessment, not merely application filing.
1. Assuming MSME Status Alone Is Enough
It is not. Clause 2(d) also requires the location to be in a duly notified industrial estate or area and the submission of self-certified Form-I.
2. Application of the Sewage Charge without Considering the Category of the Project
For the same sewage amount, the rate will vary based on whether the project comes under Local Body/Housing or Other than Housing category.
3. Use of DG Table for a Standalone Generator
The clause is stated for establishments which have the DG as the only generator.
4. Treatment of nil Fee as Nil Compliance
Nil charge from any one slab cannot mean nil compliance.
5. Assuming Every Government-Associated Hospital Is Exempt
The Resolution says the health-service establishment must be owned and operated by the specified public authority.
6. Ignoring the Capital-Investment Basis
Infrastructure CTE and certain medical/R&D/BMW cases use capital investment rather than sewage or DG capacity.
7. Treating Single-Step Approval as a Blanket Environmental Approval
Applicable waste rules still have to be identified.
8. Adding 5% to the Applicant's Fee Without Checking
The GR says 5% of the consent fee is to be credited to CPCB. It does not expressly call it an extra applicant surcharge.
Existing consent holders do not need to assume that every consent must be changed immediately.
Instead, they should check whether any of the substituted clauses affect their next filing, renewal, or approval.
Useful review points include:
A fresh applicant can reduce classification problems by completing a pre-filing review.
Step 1: Identify the Activity
Check the actual industrial, healthcare, infrastructure, or service activity.
Step 2: Confirm the MPCB Category
The appropriate category influences the manner of dealing with consent and fee calculation.
Step 3: Micro or Small Enterprise Status Confirmation
In the case of Clause 2(d), check enterprise size and its location.
Step 4: Confirmation of Fee Base
It should be determined that the appropriate basis for the fee is:
Step 5: Waste Management Rules' Applicability
Check applicability of any Waste Management Rule.
Step 6: Reconciliation of Information Prior to Filing
The activity, category, fee calculation, and information must match.
| Check | Relevant Entity | Why It Matters |
| Micro/Small classification | MSMEs | Determines Clause 2(d) eligibility |
| Notified industrial area status | MSMEs | Required for deemed CTE |
| Self-certified Form-I | Eligible MSMEs | Condition for deemed CTE |
| Sewage quantity | Local bodies/infrastructure | Determines annual fee slab |
| Housing vs non-housing status | Infrastructure | Determines correct rate column |
| Capital investment | Infrastructure/certain HCE categories | Relevant fee basis |
| DG capacity | DG-only establishments | Determines applicable fee |
| “Only source” condition | DG-only establishments | Determines whether Clause 3(e) fits |
| Government ownership and operation | Healthcare | Determines fee exemption |
| BMW applicability | Healthcare/medical/R&D/industry | Affects consolidated authorisation |
| Waste Rule applicability | Industries | Determines single-step authorisation scope |
The September amendment provides more specific treatment for several categories.
Clearer MSME Route
Eligible Micro and Small enterprises now have a clearly stated deemed CTE provision tied to Form-I and notified industrial areas.
Defined Infrastructure Fee Slabs
The sewage-based fee table gives local bodies and infrastructure applicants a clearer reference point.
Separate DG-Only Fee Structure
The amendment provides capacity-based rates instead of leaving the DG-only category unclear.
More Specific Healthcare Treatment
Healthcare establishments, public healthcare institutions and certain BMW-generating categories are addressed separately.
Integrated Consent Procedure
Consent under Water and Air laws can be processed, along with applicable waste authorisations, through a single-step procedure.
These are procedural and administrative benefits visible from the structure of the amendment. The GR does not promise faster processing, lower compliance costs, or automatic approval.
The cost impact will not be identical across sectors.
A housing project may primarily base its annual fee on sewage quantity.
An infrastructure project may additionally need the capital-investment formula for Consent to Establish.
A DG-only establishment looks at generator rating.
A healthcare establishment may need the industry-linked fee structure or the capital-investment route, depending on its category.
This makes one point clear: classification comes before calculation.
Businesses using MPCB compliance services should therefore ensure that any consultant or internal team first identifies the correct legal and fee category rather than merely applying a standard fee chart.
Businesses which are affected may consider the following steps:
These are practical compliance steps. The September GR does not itself provide a complete application procedure for every category.
MPCB applications often become difficult not because of the form itself, but because the business starts with the wrong category, fee basis, or environmental approval requirement.
Corpseed can assist businesses with MPCB consent services and related environmental compliance work, including:
1. MPCB Consent to Establish Support
Corpseed can help you with applicability checks, classification, documentation, and filing for establishing your business under Consent to Establish.
2. MPCB Consent to Operate Support
Businesses moving into the operational stage can obtain assistance with the applicable Consent to Operate requirements and supporting records.
3. Deemed CTE Eligibility Review for MSMEs
For Micro and Small enterprises, Corpseed can review whether the unit falls within the notified area and Form-I conditions referred to in the September GR.
4. MPCB Consent Fee Review
MPCB consent consultant is able to verify if the appropriate fee basis may be:
5. Support for Healthcare & BMW Compliance
Healthcare facilities are eligible to seek help for:
6. Rule for Waste Management Applicability
Where Clause 5(a) is relevant, Corpseed can help identify which waste authorisations apply to the business before the integrated filing is prepared.
7. Environmental Compliance Gap Review
Existing businesses can also review whether their current consent, authorisations and operating conditions match their present activity.
8. Ongoing MPCB Compliance Support
Where periodic consent, renewal or related environmental filings are required, Corpseed can assist with document review and ongoing compliance coordination.
Businesses unsure about their revised fee category or the correct consent route should consider an applicability review before submitting the application. That can help avoid filing under the wrong category or using the wrong fee basis.
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