Law Updates

Subject

Summary: Natural gas supply disruption has prompted CAQM to give businesses in the National Capital Region more time to use specified alternative fuels. Through its Order dated 13 August 2026, the Commission extended an existing relaxation from the Standard List of Approved Fuels under Direction No. 65 dated 23 June 2022, as amended. The arrangement relates to industries, hotels, restaurants and other enterprises in NCR, including NCT of Delhi.  The Order refers to High Speed Diesel (HSD), biomass and Refuse-Derived Fuel (RDF) pellets as alternatives that had temporarily been permitted in place of natural gas. Coal and kerosene were also covered for the temporary period where availability of those alternative fuels was limited.  The latest extension runs up to 13 September 2026, but this date should not be treated as an unconditional right to continue using alternative fuels until then. The Order links the arrangement to the restoration of normal gas supply and further orders from the Commission.  For affected businesses, the main issue is therefore not simply which fuel may be used. They also need to understand the temporary nature of the permission and how it fits with their wider environmental approvals and operating conditions. CAQM Order at a Glance Particular Details Issuing Authority Commission for Air Quality Management in National Capital Region and Adjoining Areas Document Type Order Order Date 13 August 2026 Subject Extension of relaxation in Standard List of Approved Fuels Relevant Direction Direction No. 65 Direction Date 23 June 2022 Geographic Coverage National Capital Region, including NCT of Delhi Entities Referred To Industries, hotels, restaurants and other enterprises Specified Alternative Fuels HSD, biomass and RDF pellets Other Fuels Mentioned Coal and kerosene, subject to the stated temporary condition Reason Continuing disruption in natural gas supply Previous Extension Up to 13 August 2026 Latest Extension Further period of one month Date Stated in Latest Order 13 September 2026 Nature of Relief Temporary and conditional relaxation The Order does not create a completely new fuel policy. It continues an emergency arrangement that had already been operating because of disruption to natural gas supplies.  That difference matters. A temporary relaxation gives businesses short-term flexibility. A permanent amendment would change the normal regulatory framework itself. The present Order should not be treated as proof of such a permanent change. What Is the CAQM Standard List of Approved Fuels? CAQM issued Direction No. 65 on 23 June 2022 to establish a standard list of approved fuels for different applications across NCR. CAQM explained in the Direction that fuel use contributes to air-quality conditions in the region and that fuel lists had earlier differed across NCR states. It therefore sought a more uniform framework and a move towards cleaner fuels.  The approved list was subsequently revised. The CAQM website records an addendum dated 3 April 2023 containing amendments or modifications to the approved-fuel list.  The revised list includes different fuels for different purposes rather than treating every listed fuel as approved for every establishment or application. For example, natural gas is listed for vehicular, industrial, and domestic purposes, while other fuels have specified applications.  That is why the 2026 relaxation is important. The Commission temporarily allowed specified businesses affected by the gas-supply problem to move beyond the ordinary fuel position under stated circumstances. It does not mean that every fuel mentioned in the temporary Order has become generally approved for every purpose across NCR. What Has Changed Under the CAQM Order Dated 13 August 2026? The main change is time. CAQM has given the existing temporary relaxation another month rather than creating a fresh permanent fuel category. Compliance Area Earlier Position Position Under 13 August Order Business Meaning Fuel relaxation Temporary relief already available Relief continues Eligible establishments get additional time. Validity Earlier extended to 13 August 2026 Extended further to 13 September 2026, subject to conditions Businesses have additional temporary flexibility. Natural gas disruption Supply problem had led to earlier relaxation Ministry reported disruption was continuing Reason for the relief had not ended. HSD, biomass and RDF pellets Temporarily allowed in place of natural gas Existing relaxation extended No fresh permanent approval is created Coal/kerosene Permitted for a temporary period where alternative-fuel availability was limited Underlying relaxation continues Should not be interpreted as unrestricted coal/kerosene permission. The Order dated 13 August refers back to the earlier arrangements rather than rewriting each condition from the beginning.  Businesses therefore need to read the latest extension together with the terms of the earlier relaxation. Why Has CAQM Extended the Fuel Relaxation in NCR? The reason given is the continued disruption of natural gas supplies. According to the Order, the Ministry of Petroleum and Natural Gas informed CAQM on 13 August, 2026 that the disruption, which began in early March because of geopolitical developments in the Middle East, was continuing. The Ministry also communicated that the relaxation could be extended for another month or until normal gas supply returned.  For businesses dependent on natural gas, a prolonged supply problem can affect normal operations. CAQM's response has been to continue the temporary flexibility rather than requiring affected establishments to rely only on gas during the disruption. This is therefore best understood as an exceptional supply-related arrangement, not a general move away from the approved-fuel policy. Who Is Covered Under the CAQM Fuel Relaxation? The Order expressly refers to four broad categories in the National Capital Region. Entity Expressly Mentioned? Relevance Industries Yes Industrial establishments affected by natural gas availability Hotels Yes Covered within the temporary arrangement Restaurants Yes Covered within the temporary arrangement Other enterprises Yes Coverage depends on the scope and conditions of the relaxation Industries- Industrial units are one of the main affected groups because many manufacturing or process operations may rely on natural gas for heat or other operational purposes.     Where gas availability has been disrupted, the temporary arrangement may provide fuel flexibility. That does not remove the need to check whether the proposed fuel is suitable for the establishment and consistent with other applicable conditions. Hotels- Hotels are expressly named in the CAQM Order. This is relevant where their operations are also affected by the gas-supply disruption and fall within the temporary arrangement. Restaurants- Restaurants are also specifically included. The practical relevance may vary according to the establishment's fuel use and operating systems.     The Order should not be interpreted to mean that every fuel choice by every restaurant in NCR is automatically permitted. Other Enterprises- The expression "other enterprises" is broad, but the two-page Order does not provide a detailed definition of all establishments falling within it. Businesses should therefore avoid assuming coverage solely because they operate in NCR. Applicability should be considered against the terms of the Order and the establishment's actual fuel use.  Which Fuels Are Temporarily Allowed Under the CAQM Relaxation? The Order describes three principal alternatives temporarily permitted in place of natural gas: High Speed Diesel, biomass, and RDF pellets.  High Speed Diesel (HSD) High Speed Diesel is one of the alternatives named in the temporary arrangement. Its inclusion in the emergency relaxation should not be confused with a permanent general approval of HSD for all industrial or commercial applications in NCR. Under CAQM's revised standard fuel list, diesel already has specified permitted uses. The emergency Order deals separately with temporary use arising from the natural gas disruption.  Biomass Biomass is also named as an alternative under the temporary arrangement. CAQM's wider approved-fuel framework already contains biomass-related provisions for certain applications. The temporary relaxation is relevant because it allows it use in the particular gas-supply situation described by the 2026 Orders.  The August Order does not itself set out technical specifications, emission limits or fuel-quality parameters for biomass. Such conditions should therefore not be invented from this Order. RDF (Refuse-Derived Fuel) Pellets RDF stands for Refuse-Derived Fuel. RDF pellets are expressly mentioned in the temporary fuel arrangement. Again, the temporary permission should be read in context. The standard approved-fuel list contains application-specific provisions for RDF, while the emergency relaxation arose because of the disruption in natural gas supply.  Can Industries Use Coal and Kerosene Under the CAQM Relaxation? The relaxation does not create unrestricted permission to use coal or kerosene across NCR. The August Order records that when the temporary arrangement was introduced, coal and kerosene could also be used where there was a limitation in the availability of the specified alternative fuels.  That condition is important. The correct reading is not: "Coal is now an approved industrial fuel throughout NCR." Rather, coal and kerosene form part of a limited, temporary response to an exceptional supply situation. CAQM's normal approved-fuel framework is considerably narrower regarding coal. The revised Direction No. 65 material states, for example, that low-sulphur coal is permitted as fuel only in thermal power plants in NCR under the standard framework.  The March relaxation also expressly stated that other provisions of Direction No. 65, as amended, would continue to remain in force.  Businesses should therefore avoid treating the temporary coal/kerosene concession as a permanent entitlement. CAQM Fuel Relaxation Timeline: March to September 2026 Date Development Practical Meaning 13 March 2026 Temporary alternative-fuel arrangement introduced Businesses affected by natural gas disruption received temporary flexibility 12 June 2026 Relaxation extended Relief was continued up to 13 August 2026 13 August 2026 Latest Order issued CAQM approved another extension 13 September 2026 Date specified in latest extension Current outer date under the Order, subject to earlier restoration/further orders The latest Order itself records both the earlier temporary arrangement and the subsequent extension up to 13 August.  The repeated extensions should not be treated as evidence that CAQM has permanently liberalised its fuel policy. Each extension has remained tied to the abnormal natural gas supply situation. How Long Will the Latest CAQM Fuel Relaxation Remain Valid? The 13 August 2026 Order extends the relaxation for a further month, up to 13 September 2026, subject to the conditions stated in the Order. The language also links the arrangement to restoration of normal gas supplies and any further orders from CAQM.  In practical terms, a business should not assume that: the relaxation will definitely continue after 13 September  another extension will automatically be issued or  temporary fuel use can become part of its permanent operating arrangement merely because several extensions have already been granted.  The safest approach is to follow the latest official CAQM communication rather than working from an old extension order. Is This a Permanent Change to CAQM Direction No. 65? No permanent change should be inferred from the 13 August Order. The document repeatedly deals with an extension of relaxation, not permanent substitution of Direction No. 65. This distinction becomes even clearer when the original relaxation is read with CAQM's published material. The initial relaxation said that other provisions of Direction No. 65, as amended, would remain unchanged and continue in force.  A permanent change would normally alter the approved list or modify the underlying Direction itself. Here, businesses have instead been given time-bound flexibility because the normal natural gas supply situation has been disturbed. That means a company planning its long-term energy strategy should not treat HSD, biomass, RDF, coal, or kerosene availability under this emergency arrangement as proof that the same position will continue once the relaxation ends. What Does the CAQM Extension Mean for Industries in NCR? For affected industrial units, the main benefit is short-term operating flexibility. A unit that would otherwise depend on natural gas may have an alternative during the supply disruption. This can help reduce the risk of an immediate operational interruption where the relaxation legitimately applies. There are, however, practical questions that need attention. Fuel Procurement:  A business may need to source a fuel it does not normally purchase. Supplier availability, delivery arrangements and short-term contracts can therefore become relevant. Equipment Compatibility:  A fuel being legally available does not automatically mean that every furnace, boiler or other unit can safely and efficiently use it. Equipment suitability is an operational and technical question separate from the CAQM permission. Pollution-Control Systems:  Different fuels may create different operating conditions. Businesses should assess whether their existing pollution-control arrangements remain suitable for the fuel being considered. Temporary Planning:  The greatest commercial limitation is uncertainty over duration. A business should be cautious about making a long-term investment purely on the expectation that the temporary concession will continue. What Does the CAQM Order Mean for Hotels and Restaurants? Hotels and restaurants are expressly included in the temporary arrangement.  For these businesses, the Order may matter where gas-dependent equipment or operations have been affected by the natural gas supply situation. The relief should still be read carefully. It does not say that every hotel or restaurant may use every alternative fuel for every purpose. Nor does it remove application-specific conditions contained elsewhere in CAQM's normal approved-fuel framework. For instance, CAQM's revised approved-fuel list contains specific provisions for charcoal and biomass-related fuels for certain hotel, restaurant, banquet-hall, tandoor and grill applications.  The emergency Order and the normal fuel list therefore need to be distinguished rather than mixed. Role of DPCC and State Pollution Control Boards The Order was addressed to senior officials of the relevant pollution-control authorities in NCR. These include: Delhi Pollution Control Committee (DPCC)  Haryana State Pollution Control Board  Uttar Pradesh State Pollution Control Board  Rajasthan State Pollution Control Board  The Order was also copied to the Ministry of Environment, Forest and Climate Change, the Chief Secretaries of the concerned governments, and the Chairman of the Central Pollution Control Board.  This administrative circulation reflects the regional nature of the CAQM framework. However, the August Order does not expressly state that every business using the relaxation must submit a fresh application to these boards. Such a requirement should not be created without checking the establishment's other applicable approvals and conditions. Does the CAQM Relaxation Automatically Change Existing Pollution Control Approvals? The Order should not automatically be read as changing every Consent to Establish, Consent to Operate, authorisation or site-specific environmental approval held by an individual business. The relief comes from CAQM's approved-fuel framework. A separate approval held by an industrial unit may contain its own operating or fuel-related conditions. Businesses may therefore need to review, as applicable: Consent to Establish (CTE)  Consent to Operate (CTO)  conditions mentioning approved fuel  boiler or furnace-related conditions  air-pollution-control requirements  other site-specific environmental approval conditions.  This does not mean the August Order itself requires every business to obtain a revised consent. That requirement is not expressly stated in the supplied Order. The correct approach is to check whether another approval independently needs attention before making the operational change. Operational and Cost Impact of Temporary Fuel Switching The Order itself does not give any cost figures. The financial effect will differ from one business to another. Fuel Procurement Cost Prices, transport arrangements, and availability may differ from natural gas. A business that changes fuel for only a short period also has less certainty over how long the new supply arrangement will be required. Equipment Adjustment Some establishments may already have equipment capable of using another fuel. Others may face technical adjustments or may find that a particular alternative is unsuitable. Storage and Handling Moving from piped gas to a physical fuel may change storage, receiving and handling requirements. This should be assessed at site level rather than assumed from the CAQM Order. Environmental Controls A change in fuel can affect how existing air-pollution-control equipment is operated. Businesses should review whether their controls remain appropriate. Return to the Normal Regime Temporary switching can create a second adjustment later. Once the relaxation ends or normal supply returns, an establishment may need to move back to its regular fuel arrangement. For this reason, the lowest immediate fuel price should not be the only consideration. Duration, equipment suitability, approvals, and the ability to reverse the change also matter. Benefits and Challenges of the Temporary CAQM Fuel Relaxation Potential Benefit Possible Challenge Helps affected units continue operations during gas disruption Relief is temporary. Gives access to specified alternative fuels Alternative fuel availability may vary Reduces immediate dependence on disrupted natural gas supplies Equipment may not support every alternative Gives businesses short-term procurement flexibility Storage and handling arrangements can change Reduces immediate supply vulnerability Environmental approval conditions still need review Allows time to manage the disruption Future extension cannot be assumed The policy offers breathing space to establishments facing a genuine fuel-supply problem. At the same time, the temporary nature of the arrangement limits how far businesses can rely on it for long-term planning. What Should Businesses Do During the Relaxation Period? Businesses considering a temporary fuel change should focus on a few practical checks rather than assuming the Order by itself answers every compliance question. 1. Confirm Whether the Relaxation Applies Check whether the establishment falls within the category and geographical scope referred to by the CAQM. An NCR location alone should not replace a proper applicability check. 2. Identify the Fuel Being Proposed HSD, biomass, and RDF pellets are directly named as alternatives. Coal and kerosene are subject to the additional condition linked to the limited availability of those alternative fuels.  That difference should be recorded internally. 3. Review Existing Approval Conditions Check whether an existing environmental consent or site-specific approval also contains a fuel condition that may also need consideration. 4. Check Technical Suitability A legal relaxation does not establish that a particular machine or process is technically suited to a fuel. Plant, safety, and engineering teams should assess the proposed change. 5. Keep a Clear Regulatory Record As an internal control, businesses may keep: the applicable CAQM Order  the earlier relaxation referred to in it  records explaining the reason for the temporary fuel switch  relevant internal approvals  fuel procurement records.  These are practical record-keeping measures. The August Order itself does not prescribe such a document list. 6. Monitor New CAQM Orders This is especially important because the relief is time-bound. Teams should work from the latest Order rather than relying on an older copy obtained when the relaxation was first introduced. 7. Plan for Reversal Businesses should know how they will return to their normal approved fuel arrangement if gas supplies are restored or the relaxation ends. What Happens After 13 September 2026? The present Order does not guarantee what will happen after 13 September 2026. There are broadly three matters to watch. First, normal gas supplies could be restored. Since the relaxation was introduced because of the supply disruption, restoration affects the reason for the concession. Second, CAQM could issue another Order before or around the end of the current period. Third, if no further relief applies, businesses cannot simply assume the temporary position continues. Another extension is therefore possible but not confirmed. Businesses should avoid presenting it in budgets, compliance planning, or long-term fuel contracts as a certainty. Is the CAQM Fuel Relaxation a Right Decision or an Additional Burden? The Order can be seen as practical relief during an abnormal energy-supply problem, but it also creates planning questions because businesses cannot treat the relaxation as permanent. Assessment Area Positive Side Possible Burden or Concern Energy availability Gives businesses alternatives during gas disruption Availability of alternative fuel can also be uncertain Industrial continuity May help plants avoid immediate interruption Switching fuel may require operational adjustments Hotels and restaurants Provides temporary flexibility to covered establishments Not every alternative will suit every operation Fuel procurement Expands short-term sourcing options New suppliers and logistics may need to be arranged MSMEs Can provide relief where gas disruption threatens operations Smaller businesses may have limited technical or compliance resources Environmental management Relief remains controlled and time-bound Different fuel use may need closer operational review Compliance planning The Order provides a defined temporary route Other approval conditions still need to be considered Long-term certainty Businesses receive immediate relief Future extensions cannot be assumed Air-quality policy Basic Direction No. 65 framework remains in place Exceptional fuels have to be managed carefully Temporary nature Prevents emergency relief from automatically becoming permanent policy Businesses may have to switch again when relief ends Where the Decision Helps Without temporary flexibility, establishments facing a genuine natural gas shortage could be placed in a difficult position: comply with a normal fuel rule while lacking reliable access to the fuel on which their operations depend. The extension addresses that immediate conflict. It also avoids rewriting the entire approved-fuel framework merely because of a temporary supply disturbance. Where the Burden Remains Fuel switching is not necessarily as simple as buying a different fuel. Businesses may need to consider technical compatibility, procurement, storage, operating procedures, pollution-control systems and existing approvals. A change that lasts only a few weeks can also be difficult to justify if expensive physical modifications are required. Assessment On balance, the extension appears to function as short-term operational relief rather than permanent deregulation. That makes sense in an exceptional supply situation, provided businesses maintain a clear distinction between temporary permission and their normal fuel position. The greater risk would arise if an enterprise treats the relaxation as a permanent right and continues with an alternative fuel after the legal basis for the concession has ended. Business and Regulatory Perspective Regulatory Perspective CAQM's approach keeps two ideas separate. The first is its broader policy of regulating approved fuels across NCR in the interest of air-quality management. The second is recognition that an exceptional energy-supply problem can make temporary flexibility necessary. Direction No. 65 remains the underlying framework, while the 2026 Orders operate as time-limited relief. CAQM's original relaxation also stated that the other provisions of Direction No. 65 would continue unchanged.  Business Perspective For a business, the immediate concern is continuity. A temporary alternative can be useful where the regular fuel supply is unreliable. But procurement teams should coordinate with EHS, engineering, and compliance teams rather than treating the issue as a simple purchasing decision. The question is not just: "Can this fuel be purchased?" It is also: "Can this establishment use it under the temporary relaxation, can its equipment handle it, and are there any other applicable approval conditions?" That combined review gives businesses a safer basis for action. Risks Businesses Should Avoid During the Relaxation Period Several practical risks deserve attention. Treating temporary permission as permanent: Repeated extensions do not automatically convert an interim arrangement into a permanent approved-fuel rule.  Assuming every fuel is unrestricted: HSD, biomass and RDF are specifically referred to, while coal and kerosene come with an additional availability-related condition.  Ignoring other approval conditions: The CAQM relief should not automatically be treated as changing every environmental consent held by a business.  Using an outdated Order: The dates have changed more than once since the arrangement began. Compliance teams should rely on the latest applicable document.  Assuming another extension is certain: The present Order gives no guarantee of relief beyond the period it states.  Making long-term investments around temporary relief: Any capital decision based on alternative fuel use should consider the possibility that the normal regime may return.  Confusing legal permission with technical suitability: An alternative fuel may still be unsuitable for a particular unit or process.  What Should Businesses Watch Next? The next development will depend largely on the natural gas supply position and any further CAQM action. Businesses should monitor: fresh CAQM Orders on the temporary relaxation  communication regarding restoration of natural gas supply  any formal amendment to Direction No. 65  changes in the Standard List of Approved Fuels  relevant communication from DPCC or the concerned State Pollution Control Board.  A future extension should be treated as confirmed only after it is officially issued. Likewise, a permanent change in the approved-fuel framework should not be inferred from continued emergency relief. How Corpseed Can Help with Environmental Compliance Temporary fuel switching can touch more than one area of environmental compliance. The correct position may depend on the type of establishment, location, existing consent conditions, equipment and fuel being considered. Corpseed's environmental compliance services can support businesses with the following areas: CAQM Applicability Assessment Corpseed can review the relevant CAQM Order and help identify whether the relaxation applies to the establishment and proposed fuel use. Environmental Compliance Review Existing environmental conditions can be reviewed alongside the temporary CAQM relaxation to identify possible compliance gaps before an operational change is made. CTE and CTO Support Where a Consent to Establish, Consent to Operate or modification is independently required under the applicable regulatory framework, Corpseed can assist with the review and filing process. This does not mean the 13 August Order itself requires every business to amend its consent. Fuel-Related Compliance Assessment Businesses can seek support in understanding whether their proposed fuel change is consistent with the applicable CAQM framework and relevant pollution-control conditions. Regulatory Documentation Support Corpseed can assist in organising applicable orders, approval documents and supporting compliance records so that the business has a clearer regulatory trail. Environmental Regulatory Advisory Where CAQM requirements interact with CPCB, DPCC or State Pollution Control Board conditions, Corpseed can assist businesses in reviewing the applicable regulatory position. Ongoing Environmental Compliance Support A time-bound Order needs monitoring. Corpseed can support businesses with environmental regulatory updates and continuing compliance requirements as the position changes. Businesses in NCR that are considering a temporary fuel change can obtain professional environmental compliance support before making operational decisions based on the relaxation. Key Takeaways CAQM issued the latest extension Order on 13 August 2026.  The development concerns a temporary relaxation, not a permanent replacement of Direction No. 65.  The arrangement covers industries, hotels, restaurants, and other enterprises in NCR as stated in the Order.  HSD, biomass and RDF pellets are named as alternative fuels.  Coal and kerosene are not unrestricted alternatives their temporary use is linked to limited availability of the specified alternative fuels.  The Order refers to continuing disruption in natural gas supply since early March 2026.  The latest extension runs up to 13 September 2026, subject to restoration of gas supplies or further orders as provided in the Order.  Businesses should review the latest CAQM position and any independently applicable environmental approval conditions before making a fuel change.