Law Updates

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Summary: Setting up or expanding a manufacturing unit usually means dealing with more than one government department. Land use, building plans, pollution consent, fire approvals and other clearances may move at different speeds. For a small manufacturer, waiting for each approval before moving to the next stage can hold up the entire project. The Haryana Right to Business Bill, 2026 tries to address this problem for a specific group of businesses. Published in the Haryana Government Gazette on 31 August 2026, the Bill proposes an optional in-principle approval route for eligible manufacturing MSMEs. It also provides for a time-bound decision, deemed approval in a defined situation, and a 36-month moratorium period during which routine inspection and coercive action would generally be restricted, subject to important exceptions.  The proposed benefit is not for every business in Haryana. The Bill defines an eligible enterprise as a Udyam-registered MSME engaged in manufacturing, either setting up a new unit or expanding an existing one.  There is also an important legal distinction. The attached Gazette document is the Haryana Right to Business Bill, 2026. The provisions explained below should therefore be read as the framework proposed in the Bill unless subsequent enactment and implementation are separately confirmed. Haryana Right to Business Bill 2026 at a Glance Particular Details Document Haryana Right to Business Bill, 2026 Bill Number Bill No. 24-HLA of 2026 Publication Haryana Government Gazette, Extraordinary Publication Date 31 August 2026 State Haryana Main Target Group Eligible manufacturing MSMEs Basic Eligibility Udyam-registered new manufacturing MSME or existing manufacturing MSME undertaking expansion Main Mechanism Declaration of Intent and Certificate of In-Principle Approval Is In-Principle Approval Compulsory? No, the Bill makes it optional Initial Decision Time 15 working days Further Decision Time 10 days at the escalated stage Deemed Approval Provided for where the specified further decision is not taken within time Certificate After Deemed Approval Within 3 days Moratorium Period 36 months from issue of Certificate of In-Principle Approval Exact Application Fee Not specified; to be prescribed Detailed Forms and Procedure Not specified; to be prescribed The basic idea is fairly straightforward. Instead of requiring an eligible manufacturing MSME to wait for every listed State approval before moving forward, the Bill proposes an in-principle route. In contrast, the final statutory approvals continue to be processed. What Is the Current Legal Position of the Haryana Right to Business Bill? The Gazette dated 31 August 2026 describes the document as Bill No. 24-HLA of 2026 and says that it is being published for general information under the Rules of Procedure and Conduct of Business in the Haryana Legislative Assembly.  That wording matters. The Bill contains a proposed provision saying that the law would be called the Haryana Right to Business Act, 2026 and would come into force from the date of its publication in the Official Gazette.  However, a commencement clause inside a Bill should not be confused with proof that the Bill has already completed the legislative process and become an operational law. For businesses, the safer approach is to distinguish between three things: what the Bill proposes whether the Bill has subsequently been enacted and  whether the rules, forms, fees and filing procedure have been made operational.  Until those later stages are officially confirmed, businesses should not assume that the proposed moratorium or in-principle approval facility is already available for use. Why Has Haryana Proposed a Right to Business Framework? The reasoning given in the Bill is practical rather than abstract. Its Statement of Objects and Reasons says businesses currently have to obtain multiple approvals, licences and registrations from different authorities before commencing operations. These approvals may be processed one after another, which can lengthen the setup period and increase the administrative burden. The document specifically recognises that this can be harder for MSMEs because they generally operate with more limited financial and administrative resources.  The proposed solution is to allow eligible enterprises to obtain an in-principle pre-establishment approval while the substantive approvals are processed alongside it. The Bill is built around five broad ideas. A quicker initial decision Instead of leaving the in-principle request open for an undefined period, the Bill proposes specific decision timelines. A declaration-based starting point An eligible enterprise would begin by filing a Declaration of Intent with the District Nodal Agency. Deemed approval where a decision is delayed The Bill adds a second level of review and then provides for deemed approval if a decision is still not taken within the specified period. A limited moratorium from inspection An enterprise holding a valid Certificate of In-Principle Approval would receive a 36-month moratorium, although the protection would not apply in every situation. A formal route for appeals and grievances The Bill gives State and District Nodal Agencies defined roles in dealing with rejections and complaints. These objectives are set out in the Statement of Objects and Reasons.  How Does the Proposed Regulatory Framework Work? The Bill does not replace Haryana's existing approval authorities with one new regulator. Instead, it creates a layer of facilitation around the existing system. The Empowered Executive Committee constituted under Section 4 of the Haryana Enterprises Promotion Act, 2016 would function as the State Nodal Agency. The District Level Clearance Committee constituted under Section 8 of the same Act would function as the District Nodal Agency. The actual approvals would still involve the relevant competent authorities, such as: Town and Country Planning Department Urban Local Bodies Department Fire Department Haryana State Pollution Control Board Haryana State Industrial and Infrastructure Development Corporation Limited Labour Department So the proposal changes the way the early approval period may be managed. It does not mean that all underlying laws or technical requirements disappear. Who Can Be Treated as an Eligible Enterprise? This is one of the most important parts of the Bill because the proposed benefit is not open-ended. An eligible enterprise must be: a Micro, Small or Medium Enterprise;  engaged in manufacturing;  either a new manufacturing unit or an existing manufacturing unit undertaking expansion; and  registered on the Government of India's Udyam portal.  Eligibility Point Requirement Enterprise Size MSME Business Activity Manufacturing Business Stage New unit or existing unit undertaking expansion Registration Udyam registration Location Establishment or expansion in Haryana Who Should Be Careful Before Assuming Eligibility? A business should not rely only on the fact that it is an MSME. For example, the definition in the Bill specifically refers to manufacturing units. It does not expressly extend the same definition to every trader, service provider, or large enterprise. Similarly, an existing manufacturing business that is simply continuing normal operations should not automatically assume that it falls within the “existing unit undertaking expansion” category. Eligibility needs to be tested against the final legal text and the rules applicable at the time of filing. What Is a Declaration of Intent? The Declaration of Intent is the proposed starting document for a business that wants to use the in-principle approval route. The Bill defines it as the submission of relevant documents and required information by an eligible enterprise for the purpose of taking benefit under the proposed law.  An eligible enterprise proposing to establish or expand its business in Haryana would furnish the declaration to the District Nodal Agency. Section 7 says the declaration would have to be filed: in the prescribed form  in the prescribed manner and  along with the prescribed fee.  The Bill itself does not provide the final form, a complete document checklist, or the amount of the fee. Those points should therefore not be filled in from assumption. What Is a Certificate of In-Principle Approval? The Certificate of In-Principle Approval is the main facilitation instrument proposed under the Bill. The District Nodal Agency would issue it after receiving and processing the Declaration of Intent. The purpose is to give an eligible enterprise a provisional regulatory route while the substantive approvals needed for the project are obtained separately. The word “provisional” is important here. The certificate should not be understood as a substitute for every final approval. For example, receiving the certificate does not automatically mean that: Consent to Establish has become unnecessary;  Consent to Operate is no longer required;  land-use rules can be ignored;  a Fire NOC is permanently waived; or  building-plan conditions no longer apply.  The Bill itself requires businesses to continue pursuing the necessary statutory approvals during the moratorium. Is the Certificate of In-Principle Approval Compulsory? No. The Bill expressly makes this route optional. An eligible enterprise may choose to obtain the Certificate of In-Principle Approval, but it may also continue through the normal approval process with the concerned competent authority.  That gives an eligible MSME two possible routes. In-Principle Approval Route The business submits a Declaration of Intent and seeks the benefit of the proposed Right to Business framework. Regular Approval Route The business follows the ordinary approval process directly with the concerned government authorities. The right option would depend on the project, approvals involved, and the final operational rules. How Would the In-Principle Approval Process Work? The Bill provides a clear sequence. Check Eligibility:  The enterprise first needs to fall within the definition of an eligible manufacturing MSME. File the Declaration of Intent:  The declaration would be submitted to the District Nodal Agency in the prescribed manner. District Nodal Agency Reviews the Declaration:  The District Nodal Agency is responsible for examining and processing the declaration. Decision Within 15 Working Day:  The District Nodal Agency would have 15 working days to issue the Certificate of In-Principle Approval or reject the Declaration of Intent. Matter Moves to the Deputy CEO if the Certificate Is Not Granted:  If the certificate is not granted within the initial period, the matter would be forwarded to the Deputy Chief Executive Officer of the Haryana Enterprises Promotion Centre. Further 10-Day Decision Period:  The Deputy CEO would then have 10 days to approve or reject the declaration. Deemed Approval:  If no decision is taken within those 10 days, the declaration would be treated as approved Certificate Following Deemed Approved:  The District Nodal Agency would then issue the Certificate of In-Principle Approval within three days from the date of deemed approval.  How Does Deemed Approval Actually Work? The term “deemed approval” can easily be misunderstood. It does not mean that every licence, consent or NOC required by a manufacturing unit automatically becomes approved. Under Section 9, deemed approval is connected specifically with the decision on the Certificate of In-Principle Approval. Stage Authority Time Available Outcome First review District Nodal Agency 15 working days Certificate or rejection Further review Deputy CEO, Haryana Enterprises Promotion Centre 10 days Approval or rejection. No decision at second stage - After 10-day period Deemed approval Certificate issuance District Nodal Agency Within 3 days Certificate issued after deemed approval A manufacturer should therefore avoid reading “deemed approval” as deemed pollution consent, deemed land-use permission or deemed fire clearance. What Does the 36-Month Moratorium Mean? The proposed moratorium starts from the date on which the Certificate of In-Principle Approval is issued and lasts for 36 months.  During this period, the Bill generally restricts inspection and coercive measures against the eligible enterprise. But the moratorium has a specific purpose. It gives the enterprise time to secure the final approvals it needs. It is not a three-year holiday from regulation. The business would still have to work on: land-related approvals;  pollution-control consents;  fire requirements;  building approvals;  labour-related requirements; and  any other approval applicable to the project.  Can an Enterprise Still Be Inspected During the Moratorium? Yes. The Bill specifically allows inspection in certain cases. Inspection Based on a Complaint Where a complaint is received, an inspection may be ordered, subject to the safeguards stated in the Bill. The inspection must: be ordered by the head of the concerned competent authority;  have reasons recorded in writing;  be carried out by an officer not below the rank of Joint Director; and  be preceded by intimation to the Chairman of the District Nodal Agency.  Inspection for Land and Safety Issues The head of the competent authority may also order inspection for reasons recorded in writing in cases involving: land-use violations  unauthorised construction  public safety structural integrity or  fire safety.  The inspection report must be made available online to both the eligible enterprise and the concerned competent authority within 48 hours after the inspection. The moratorium therefore reduces routine inspection exposure, but it does not place a business outside regulatory oversight. What Must an MSME Do During the 36 months? The most important duty during the moratorium is easy to miss. The enterprise must start the process of obtaining all requisite approvals from the concerned competent authorities through the Invest Haryana Single Window Portal.  There is also a specific requirement for the end of the moratorium. Within the last six months before the 36-month period expires, the enterprise must ensure that all pending approvals have been obtained.  For a manufacturing project, that means the approval plan should begin early. Waiting until the final few months could be risky, as the project may need technical scrutiny, inspections, corrections, or approvals from more than one department. Which Government Approvals Are Listed Under the Bill? The Schedule attached to the Bill identifies the approvals intended to fall within the proposed framework.  Town and Country Planning Department The Schedule lists: Change of land use in an industrial zone;  NOC for establishment of a unit under the urban-area law referred to in the Schedule;  NOC for a unit falling outside a controlled/urban area; and  building-plan approval for low-risk industries.  Urban Local Bodies Department The listed approvals include: change of land use in an industrial area within municipal limits; and  building-plan approval for low-risk industries.  Fire Department The Schedule includes: Fire Fighting Scheme for specified White and Green category industries; and  NOC for Fire Service for specified low-risk industries.  Haryana State Pollution Control Board The pollution-control entries include: Consent to Establish; and  Consent to Operate.  These are linked to the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981. The Schedule refers to White and Green category industries and, in the stated circumstances, Orange category industries situated inside industrial areas.  Haryana State Industrial and Infrastructure Development Corporation Limited The Schedule lists: building-plan approval for low-risk industries; and  plinth-level certificate.  Labour Department It also includes shop registration under the Haryana Shops and Commercial Establishment Act, 1958 as described in the Schedule. What Should Manufacturers Know About Pollution-Control Approvals? For manufacturers, the Haryana State Pollution Control Board entries require particular care. The Schedule covers Consent to Establish (CTE) and Consent to Operate (CTO) for the industry categories expressly mentioned in the Bill.  A manufacturer should therefore check at least three points before assuming that the proposed facilitation applies: the pollution category of the unit;  whether the factory is inside or outside an industrial area; and  whether the particular CTE or CTO falls within the Schedule.  An Orange-category unit outside the circumstances mentioned in the Schedule should not assume that it receives the same treatment merely because another Orange-category unit does. Businesses that need help identifying CTE, CTO and related requirements may use a pollution control consent consultant or other competent environmental compliance professional before filing. What Does the In-Principle Certificate Not Allow? The Bill contains an express restriction concerning land. A Certificate of In-Principle Approval would not give an enterprise the right to use land in a way that conflicts with land-use requirements under State law.  The inspection provisions reinforce the same point. Land-use violations and unauthorised construction can still trigger inspection during the moratorium. The same practical caution applies to fire safety, structural integrity and public safety. A manufacturer should therefore see the proposed certificate as a temporary facilitation tool, not as permission to ignore the conditions attached to the project site. What Are the Roles of the State and District Nodal Agencies? The Bill divides responsibility between State-level and District-level bodies. State Nodal Agency The State Nodal Agency would: monitor and supervise the District Nodal Agency;  coordinate with competent authorities;  decide the appeal assigned to it under Section 13;  support time-bound grievance redressal; and  perform other functions assigned by the Government.  District Nodal Agency The District Nodal Agency would handle much of the day-to-day operation of the proposed system. Its functions include: examining the Declaration of Intent;  processing applications irrespective of investment size;  issuing the Certificate of In-Principle Approval;  maintaining records;  dealing with grievances;  coordinating with other authorities; and  monitoring eligible enterprises that receive certificates.  What Happens if the Declaration of Intent Is Rejected? The Bill does not leave an applicant without a remedy. If the District Nodal Agency rejects the declaration under Section 9(1), the eligible enterprise may appeal to the State Nodal Agency within 30 days from the date of rejection. Where rejection takes place at the later stage referred to in Section 9(3), the appeal lies before the Chief Executive Officer of the Haryana Enterprises Promotion Centre, again within 30 days.  A delayed appeal may also be considered if the concerned appellate authority is satisfied that there was sufficient reason for not filing it within the normal period. How Will Grievances During the Moratorium Be Handled? A grievance is different from an appeal against rejection. Where an enterprise holding a valid Certificate of In-Principle Approval is aggrieved by an action initiated during the moratorium, it may approach the District Nodal Agency for redressal in the manner to be prescribed. The District Nodal Agency would have 30 days to resolve the grievance. If it cannot resolve the matter within that period, the grievance would be forwarded to the State Nodal Agency, which would have 15 days to decide it.  This creates a defined escalation route rather than leaving the enterprise to deal with the issue informally. When Can the Certificate Be Revoked? The proposed certificate comes with responsibility. The District Nodal Agency may revoke it where the enterprise: submits false information;  provides fraudulent information;  misrepresents facts; or  violates the provisions of the proposed law or rules.  The enterprise must be given an opportunity of being heard before revocation.  If a business breaches another law connected with an approval, the concerned competent authority may impose the penalty available under that applicable law.  The Bill itself does not create one common monetary fine for every possible breach. What Happens if the Business Fails to Obtain Final Approvals? This is where the temporary nature of the framework becomes most visible. If an eligible enterprise does not obtain the requisite approvals within the moratorium period, the concerned competent authority can take action after the moratorium expires. The Bill specifically says that such action may include coercive measures, but those measures must be taken according to the applicable law.  That means the exact consequence will depend on the approval that remains missing and the law governing it. Businesses should therefore avoid treating the 36 months as the final objective. The real objective is to finish the required approvals before that period ends. What Is the Fee for the Declaration of Intent? The Bill does not state a rupee amount. Section 7 says that the Declaration of Intent would be submitted with such fee as may be prescribed. The Financial Memorandum repeats this point.  Until a fee is officially prescribed, any figure quoted elsewhere should be checked against the latest government notification. Which Details Still Depend on Future Rules? The broad structure is contained in the Bill, but several practical details are still left for rules. Matter Position in the Bill Declaration of Intent format To be prescribed Filing method To be prescribed Fee To be prescribed Certificate procedure Certain timelines fixed; manner still to be prescribed. Forwarding/escalation process Manner to be prescribed Complaint-based inspection procedure To be prescribed Grievance application procedure To be prescribed Section 21 authorises the State Government to make rules for carrying out the purposes of the proposed legislation.  For businesses, this means the Bill explains what the framework is intended to do, while the rules would be expected to explain much of how it will actually work. Can Haryana Add More Approvals Later? Yes. Sections 15 and 16 allow the Government to change the Schedule through notification. It may add to, alter, or amend the list of approvals.  Manufacturers should therefore refer to the latest notified Schedule rather than treating the list attached to the 31 August 2026 Bill as permanently fixed. How Is the Proposed System Different From the Existing Approval Process? The Bill's own Statement of Objects and Reasons describes the existing setup as a multi-agency system where approvals may be processed sequentially. The proposed framework tries to reduce that initial waiting period. Area Position Described in the Bill Proposed Approach Government approvals Multiple approvals from different authorities In-principle facilitation while final approvals continue Processing Often sequential Parallel processing envisaged Initial entry Approvals before establishment described as a barrier Declaration of Intent route Decision timeline Delays identified Specific time limits proposed Delayed decision No comparable mechanism described Deemed approval at specified stage Inspection Normal applicable regime 36-month moratorium with exceptions Final approvals Required Still need to be obtained So, the Bill is better understood as an attempt to change the sequence and timing of approvals, not as a proposal to abolish the approval system. What Could This Mean for Manufacturing MSMEs in Haryana? For a new manufacturing MSME, the proposed framework could make the early stage of project execution more predictable. A defined decision timeline allows promoters to know when the in-principle request should move to the next stage. For an existing MSME expanding its facility, the benefit may lie in managing the expansion project while different approvals are being processed. The bigger shift, however, may be internal. A business using this route would need stronger approval tracking. It would need to know: which authority handles each clearance;  when an application was filed;  what remains pending;  when the moratorium expires; and  whether all outstanding approvals are likely to be completed before the final six-month period ends.  This is where structured manufacturer compliance services can become useful, particularly for projects involving pollution, fire, land and building approvals at the same time. What Are the Main Benefits Proposed for MSMEs? If the Bill becomes operational in substantially the same form, eligible manufacturing MSMEs may gain from: a defined initial decision timeline;  a second-level decision mechanism;  deemed approval where the specified authority does not decide within time;  36 months for securing final approvals;  limited protection from routine inspections during that period;  formal grievance redressal;  coordination through State and District Nodal Agencies; and  clearer identification of approvals covered by the Schedule.  The benefit is therefore mainly procedural breathing room. It should not be confused with an exemption from the laws governing the factory. Where Could Businesses Still Face Difficulty? The Bill may reduce one kind of burden while leaving several practical jobs in place. Final Approvals Still Have to Be Completed Pollution, building, fire, land and other requirements do not simply disappear once the in-principle certificate is issued. The Business Still Deals With Several Departments The nodal mechanism can help with coordination, but the Schedule itself shows that several competent authorities remain involved. The Rules Will Decide Much of the Actual Filing Experience Until the form, fee, filing procedure, and other details are prescribed, businesses do not have the complete operational picture. Incorrect Information Can Put the Certificate at Risk The declaration needs to be prepared carefully because false information or misrepresentation can lead to revocation. The 36-Month Period Needs Active Monitoring. A long moratorium can create a false sense that there is plenty of time. For a project with several technical approvals, losing the first two years to inactivity could make the closing period difficult. Is the Haryana Right to Business Bill a Relief or Another Compliance Layer? For eligible manufacturing MSMEs, the proposal is more likely to be useful where the real problem is waiting for several approvals to move through different departments before the project can progress. The 15-working-day initial timeline, additional 10-day decision period, deemed approval mechanism and 36-month moratorium are designed to reduce that early bottleneck. But there is a trade-off. The enterprise still carries responsibility for final approvals. It must track the moratorium period, pursue applications through the relevant authorities, maintain accurate declarations and deal with land, safety and pollution requirements. So the proposal does not remove compliance. It changes when some of that compliance can be completed. Whether this works well in practice will depend on the final law, the rules issued under it, the functioning of Invest Haryana and coordination between the nodal agencies and approval-granting departments. What Should Manufacturing MSMEs Do Now? Businesses planning a new manufacturing unit or expansion in Haryana should avoid making project decisions solely on the basis of the Bill's proposed benefits. A more practical approach is to prepare the compliance side of the project now. Priority Action 1 Check whether the enterprise fits the proposed eligibility definition 2 Verify Udyam registration details 3 Confirm land-use position before committing to the site 4 Identify building plan and local authority requirements 5 Check pollution category and CTE/CTO requirements 6 Review applicable fire approvals 7 Prepare a department-wise approval map 8 Monitor enactment and rules issued under the Bill 9 Check the latest Invest Haryana process before filing 10 Maintain a live tracker for approvals and regulatory dates An industrial compliance consultant can also help where the project involves several approvals and the business does not have an in-house team familiar with the State process. How Corpseed Can Help Manufacturing MSMEs in Haryana A manufacturing project rarely has just one approval issue. The exact requirement changes with the product, location, pollution category, building, land position, and nature of the proposed activity. Corpseed's regulatory compliance services in Haryana can support manufacturers in identifying these requirements and organising the approval process around the actual project. Eligibility and Applicability Review Corpseed can assess whether a proposed manufacturing unit or expansion fits the relevant MSME, manufacturing, and Udyam-related conditions once the framework becomes operational. This helps businesses avoid starting with the wrong regulatory assumption. Udyam Registration Support Where Udyam registration is relevant, Corpseed can assist with the registration process and review whether basic enterprise details are correctly reflected. Industrial Approval Mapping Before filing applications, the business needs to know which approvals are actually relevant. As an industrial approval consultant in Haryana, Corpseed can assist with mapping requirements related to: land and location;  building plans;  fire approvals;  pollution consent;  local authorities;  labour-related registrations; and  other project-specific permissions.  Haryana State Pollution Control Board Compliance Manufacturing units may require Consent to Establish, Consent to Operate, or other environmental approvals depending on their category and activity. Corpseed can provide support as a pollution control consent consultant, including assistance with applicable HSPCB filings and supporting compliance documentation. Building, Land and Fire Approval Support Where project conditions require building-plan approval, land-related clearance or fire approval, Corpseed can help businesses understand the applicable process and prepare the required filing. Approval remains with the concerned government authority. Regulatory Documentation Review Incorrect or inconsistent information can create avoidable problems, particularly where the business is filing declarations with a government body. Corpseed can review application information and available supporting records before submission so that obvious inconsistencies can be identified early. Compliance Gap Assessment A factory expansion may already have several approvals in place while others require amendment, renewal, or fresh filing. A compliance gap assessment can help separate: approvals already available;  approvals that may need updating;  new approvals;  location-specific requirements; and  pending actions.  Ongoing Approval Tracking If the proposed 36-month framework becomes operational, simply receiving an in-principle certificate will not finish the compliance work. Businesses may need to track individual applications, departmental responses, pending approvals, and the expiry of the moratorium. Corpseed can support this through structured manufacturer compliance services and ongoing regulatory tracking. Manufacturing MSMEs looking for a business compliance consultant in Haryana can approach Corpseed for project-specific approval mapping, regulatory filings, pollution-control compliance, and related support. The objective is to identify the approvals that genuinely apply to the business and build the compliance work around those requirements rather than relying on a generic checklist. Key Takeaways The Haryana Right to Business Bill 2026 proposes a different approach to the early approval stage for eligible manufacturing MSMEs. Its central idea is to provide in-principle facilitation while the enterprise continues to obtain final statutory approvals. The main points businesses should keep in mind are: The Gazette document is titled the Haryana Right to Business Bill, 2026.  The proposed framework is limited to specified Udyam-registered manufacturing MSMEs.  A Certificate of In-Principle Approval would be optional.  The initial District Nodal Agency decision period is 15 working days.  A further 10-day decision stage is proposed before deemed approval can arise.  The certificate would be issued within three days following deemed approval.  The moratorium would run for 36 months from the date of certificate issuance.  Certain inspections can still take place during the moratorium.  Final statutory approvals still have to be obtained.  The Schedule currently covers specified approvals involving planning, local bodies, fire, pollution control, HSIIDC, and labour authorities.  Several filing details, including the fee and form of Declaration of Intent, are still to be prescribed.