Law Updates

Subject

Summary: The Directorate General of Foreign Trade ( DGFT ) has introduced automated issuance of Free Sale and Commerce Certificates (FSC) through its online portal. The change was announced through Trade Notice No. 24/2026-2027 dated 31 August 2026 and is aimed at reducing the manual processing involved in eligible FSC applications. Exporters were already applying for an FSC online . The major change is what happens after an application is submitted. Earlier, the file was routed to the concerned DGFT Regional Authority (RA) for manual analysis, verification, and approval. Under the new arrangement, eligible applications can be considered for automatic issuance through a rule-based and system-driven workflow. Automation, however, does not mean every FSC application will be approved automatically. Applications requiring verification or failing to meet automated-processing parameters can still be sent to the concerned Regional Authority. Even some auto-approved applications may later be selected for review under DGFT's risk-management parameters.  Notification at a Glance Particular Verified Details Issuing authority Directorate General of Foreign Trade (DGFT) Ministry Ministry of Commerce and Industry Department Department of Commerce Document Trade Notice Trade Notice No. 24/2026-2027 Date 31 August 2026 Subject Automated Issuance of Free Sale and Commerce Certificates (FSC) Relevant provision Paragraph 2.34 of the Handbook of Procedures Automation reference Paragraph 1.04(d) of HBP 2023 Main stakeholders Exporters, trade and industry, Export Promotion Councils, DGFT Regional Authorities Earlier position Online application followed by manual RA analysis, verification and approval New development Automated FSC issuance for eligible applications Processing model Rule-based, system-driven and risk-based Manual processing Retained for applications requiring verification or not meeting automated parameters Post-approval review Certain auto-approved applications can be flagged to the RA Separate compliance deadline Not expressly specified in the Trade Notice Guaranteed processing time Not specified Stated effect Paperless processing and expedited turnaround for trade and industry The notice is therefore mainly a processing reform. It does not replace the FSC framework itself. It changes the way qualifying applications may be examined and issued.  What Is a Free Sale and Commerce Certificate (FSC)? A Free Sale and Commerce Certificate is an export-related certificate that confirms the specified product is freely sold in the country from which it is being exported. DGFT's official FAQ also explains that an FSC does not, by itself, mean that the product has been evaluated for safety or efficacy.  Under Paragraph 2.34 of the Handbook of Procedures, DGFT Regional Authorities may issue FSCs for specified categories of products. The provision covers certain products not falling under the Drugs & Cosmetics Act, 1940, as well as other items that are not restricted or prohibited for export. The HBP also provides that the certificate is normally valid for two years from the date of issue unless otherwise specified.  An FSC should therefore not be treated as a universal export certificate. Whether it is relevant depends on the product, its regulatory status and the requirements applicable to the proposed export. The Regulatory Framework for Free Sale and Commerce Certificates The automation introduced in August 2026 takes place within an existing DGFT process and not through the creation of a new certificate. DGFT Functions DGFT functions under the ambit of the Department of Commerce, Ministry of Commerce and Industry. It deals with processes related to India's foreign trade policy. For FSCs, the relevant procedural provision is Paragraph 2.34 of the Handbook of Procedures 2023. Paragraph 2.34 of the Handbook of Procedures- Paragraph 2.34 provides for FSC issuance by Regional Authorities. It covers: Certain items not covered under the Drugs & Cosmetics Act, 1940 that have medical or surgical use in hospitals, nursing homes, and clinics and are not prohibited for export.  Other items that are not restricted or prohibited for export.  Application through the prescribed ANF 2H framework.  Issuance of the certificate in the prescribed format.  A normal certificate validity of two years unless otherwise specified.  For items falling under the Drugs & Cosmetics Act, the HBP refers applicants to the Central Drugs Standard Control Organisation (CDSCO) for the relevant FSC route.  Paragraph 1.04(d) of HBP 2023 The automation is also linked to Paragraph 1.04(d), titled Automated Processing in Online Environment. That provision establishes the wider DGFT policy of progressively introducing rule-based and system-driven processing with a risk-based management approach.  The FSC change is therefore part of a wider shift from officer-led processing of every routine case towards automated processing where system conditions allow it. What Has DGFT Changed in the FSC Issuance Process? The change is in processing after online submission, not in moving the application from offline to online. Before this Trade Notice, an exporter submitted the FSC application online. The file was then sent to the concerned Regional Authority, where officers carried out manual analysis, verification, and approval. Under the automated system, eligible applications can now move through a system-driven route. The practical change can be understood as: Earlier: Online application → Regional Authority → manual analysis → verification → approval New system for eligible cases: Online application → system-based assessment → automatic issuance where applicable For cases requiring closer examination: Online application → system assessment → Regional Authority → manual processing This distinction matters. The reform is about reducing unnecessary manual examination in suitable cases, not removing regulatory oversight.  Who Is Eligible for Automated FSC Issuance? The Trade Notice says that eligible applications will be considered for automatic issuance in accordance with the prevailing framework. It does not, however, publish a complete list of the internal parameters that determine whether a particular application will pass through the automated route. There are therefore two separate questions: Eligibility for an FSC This comes from the existing DGFT framework, including Paragraph 2.34 of the HBP and applicable application requirements. Eligibility for Automatic Issuance This depends on whether an application satisfies the parameters built into DGFT's automated system. The Trade Notice does not disclose every system parameter or risk condition used to make that decision. Exporters should therefore avoid assuming that being eligible to apply for an FSC automatically means the certificate will be issued through the automated route. Which Products Are Covered Under the DGFT FSC Mechanism? Paragraph 2.34 provides clearer product coverage than the short Trade Notice itself. The HBP permits Regional Authorities to issue FSCs for: Products outside the Drugs & Cosmetics Act, 1940 that are used in hospitals, nursing homes, or clinics for medical and surgical purposes and are not prohibited for export.  Other products that are not restricted or prohibited for export.  The prescribed ANF 2H certificate format also refers to specified products being freely permitted for sale in India and freely exportable, subject to the declaration underlying the certificate.  Product classification should therefore be checked before filing. A business should not choose the DGFT FSC route merely because a foreign buyer asks for a "free sale certificate." Which Products Are Outside the Scope of This DGFT Trade Notice? One important boundary concerns product covered under the Drugs & Cosmetics Act, 1940. Paragraph 2.34 specifically provides that applications relating to products falling under that Act may be made to the Central Drugs Standard Control Organisation (CDSCO) for the relevant Free Sale and Commerce Certificate.  This distinction can be important for businesses dealing with pharmaceutical, drug, cosmetic or other products regulated under that legislation. The correct regulator should therefore be identified before starting an application. Filing through the wrong route can create avoidable delays even if the underlying product is otherwise exportable. How Will Automated FSC Issuance Work on the DGFT Portal? The Trade Notice does not publish a detailed technical workflow, but its provisions can be understood through the following practical sequence. Step 1: Submission of the FSC Application in an Online Format The exporter continues with the DGFT online system. Automation does not eliminate online filing but affects how the submitted application can be handled. Step 2: Evaluation of the FSC Application The FSC application is evaluated according to the current framework and criteria for automation. Step 3: Issuance of the Application Automatically When the requirements are fulfilled, the FSC can be issued automatically. Step 4: Some Cases Continue to the Regional Authority Applications requiring verification or those that do not meet the automated parameters can still be routed to the concerned RA. Step 5: Certain Auto-Approved Cases May Be Reviewed Even after automatic approval, a case can subsequently be flagged to the relevant Regional Authority under DGFT's risk-management parameters. This is an explanatory reading of the Trade Notice. DGFT has not presented these points as a separately numbered five-stage statutory procedure.  When Will an FSC Application Still Go for Manual Verification? Manual processing has not been abolished. The Trade Notice identifies two broad situations in which an application may continue to the concerned Regional Authority: The application requires verification.  The application does not meet the automated-processing parameters.  In those situations, the RA can continue with manual processing. A manual referral should not automatically be read as a rejection. It simply means that the application has not completed the automatic route and needs officer-level processing or verification. This is one of the most important practical points for exporters because the new system creates an automated route alongside the existing regulatory review mechanism rather than replacing it completely.  Can an Automatically Approved FSC Be Reviewed Later? Yes. Trade Notice No. 24/2026-2027 specifically states that certain auto-approved applications may later be flagged to the concerned Regional Authority for review under the system's risk-management parameters.  This means receiving an FSC through the automated route should not be understood as immunity from later regulatory scrutiny. For exporters, the practical lesson is straightforward: information submitted in the application should be accurate and capable of being supported if a review is later initiated. Supporting records should also be organised rather than treated as unnecessary simply because the initial decision was automated. The Trade Notice does not state how many cases will be reviewed or reveal the internal criteria used to select them. How Does DGFT's Risk-Based FSC Processing System Work? Risk-based processing allows a digital system to distinguish between applications that can proceed through automated processing and cases where further regulatory attention may be needed. For FSCs, DGFT has confirmed three broad outcomes: Eligible applications can be automatically issued.  Applications requiring verification or failing automated parameters can be sent for manual processing.  Certain auto-approved cases can later be flagged for review.  The Trade Notice does not disclose the risk-scoring system behind these decisions. It does not identify: A numerical risk scores  Specific red flags  Selection percentages  Review frequency  Internal algorithms  Product-wise risk categories  These details should not be guessed. The broader HBP framework itself provides for phased use of rule-based, system-driven workflows combined with risk-based management.  Manual vs Automated FSC Issuance: What Has Changed for Exporters? Compliance Area Turnaround Automated Mechanism Practical Meaning Application Filed online Continues online Filing itself was already digital Initial processing File went to RA System can assess qualifying applications Less routine officer handling Verification Manual RA verification Not required for every automatically processed case Qualifying cases may move faster Automatic issuance Manual RA verification Available for eligible applications New automated route RA involvement Central to routine processing Focus remains on cases needing manual examination RAs remain part of the system Applications failing system parameters Central to routine processing Focus remains on cases needing manual examination Not necessarily rejected Post-approval review Not the focus of earlier workflow Certain auto-approved cases may be reviewed Automation does not end oversight Risk management Not central to the described FSC workflow Certain auto-approved cases may be reviewed Regulatory scrutiny becomes more targeted Paperless processing Application already online Greater end-to-end system processing intended Reduced dependence on routine manual handling Turnaround Manual processing involved substantial time DGFT aims for expedited turnaround No fixed time guarantee The most important difference is therefore not the application form. It is the way DGFT handles the file after it enters the system. What Is the Role of DGFT Regional Authorities After Automation? Regional Authorities continue to have a meaningful role. Under the new arrangement, their involvement may become more targeted rather than routine for every application. RAs may still deal with: Applications requiring verification  Cases that do not meet automated-processing parameters  Manual processing of referred applications  Certain auto-approved applications later flagged under risk-management parameters  The system should therefore not be described as replacing Regional Authorities. A better description is that automation may reduce the number of straightforward applications requiring routine manual processing while preserving RA scrutiny where the system determines that further examination is appropriate. Does Automated FSC Issuance Mean Automatic Approval for Every Application? No. "Automated issuance" and "automatic approval of every application" are not the same thing. The Trade Notice uses the word eligible applications. That qualification is important. An applicant may face one of several outcomes: The application satisfies the automated route and is issued through the system.  The application needs verification and moves to the Regional Authority.  The application does not satisfy automated parameters and moves to manual processing.  An automatically issued application is later selected for review.  The notice therefore introduces differentiated processing rather than unrestricted automatic approval. What Happens If an FSC Application Does Not Meet Automated Processing Parameters? The Trade Notice allows such an application to continue to the concerned Regional Authority for manual processing. It does not say that failure to qualify for automated processing automatically causes rejection. This matter because an exporter may see a manually routed application and incorrectly assume something is wrong with the underlying FSC eligibility. The two issues are different. A file can fail to complete the automated route but remain capable of being processed manually under the prevailing framework. Exporters should therefore follow the status and any communication issued through the official DGFT system rather than concluding only from the fact that the application has moved to an RA. Why Has DGFT Introduced Automated FSC Issuance? DGFT gives a clear administrative reason for the change: reduce manual work and move suitable applications through a faster, paperless system. Reduce Manual Processing The notice records that the earlier workflow involved manual analysis, verification, and approval, which could involve substantial processing time. Support Paperless Trade Procedures Automation allows more of the decision-making process to take place within the digital environment rather than requiring routine manual handling. Improve Processing Efficiency A rule-based system can process qualifying applications without waiting for the same level of individual officer intervention in every case. Apply Risk-Based Regulatory Oversight The system retains the ability to direct selected cases towards manual review. Reduce Compliance Burden DGFT expressly links the change with its broader efforts to digitise processes, reduce compliance burden and facilitate trade.  The intended direction is faster processing, but the Trade Notice does not guarantee a particular turnaround period for individual applications. What Does the New FSC System Mean for Indian Exporters? For exporters, the change can affect both processing speed and the way applications should be prepared. Faster Processing Potential Applications that successfully satisfy the automated route may avoid routine manual verification. That creates the potential for quicker issuance. Reduced Routine Manual Intervention Straightforward applications may no longer need to move through the same officer-led analysis that formed part of the earlier process. Greater Importance of Accurate Digital Applications When a system takes a larger role in processing, inconsistencies in submitted information can become more important. Exporters should therefore treat data quality as part of their regulatory preparation. Continued Regulatory Scrutiny Manual verification remains available, and even auto-approved applications may be reviewed later. Better Process Predictability A rule-based process can potentially make routine cases more predictable, although the notice does not guarantee identical processing for every applicant. Benefits of Automated FSC Issuance for Exporters The main benefit is the possibility of reducing routine administrative time for applications capable of being processed automatically. The likely benefits include: Less routine manual handling: Qualifying applications can move without every file passing through the same manual examination.  Paperless processing: The change builds on DGFT's existing online system and extends automation deeper into the processing stage.  Potentially faster issuance: DGFT expressly intends the system to support expedited turnaround.  Better use of Regional Authority resources: Manual attention can be directed towards applications that actually require verification.  System-driven processing: Routine cases can be dealt with using predefined processing parameters.  Continued regulatory control: Risk-based checks remain available instead of being removed for the sake of speed.  Improved export-document workflow: Faster handling of qualifying applications may help exporters organise downstream documentation more efficiently.  These are procedural benefits. The Trade Notice does not guarantee approval, a fixed time saving, a particular cost reduction, or any increase in export revenue. Challenges and Practical Concerns for Exporters Automation reduces some manual work, but it does not remove every practical issue. Not Every Application Will Qualify for Automation An exporter should not plan on automatic issuance merely because an FSC application has been submitted. Automated Parameters Are Not Fully Explained The Trade Notice does not disclose every parameter used by the automated system. That can make it difficult for applicants to predict with certainty whether a case will complete the automatic route. Manual Verification Can Still Apply Businesses must remain prepared to deal with RA review where required. Auto-Issued Cases Can Still Be Reviewed An automatically issued certificate does not necessarily close the regulatory file permanently. Application Accuracy Matters The move towards system-driven processing makes clean, consistent, and correct data even more valuable. Product Applicability Still Needs Attention Automation does not change the need to determine whether DGFT is the correct route for the product in question. Is Automated FSC Issuance a Right Decision or an Additional Burden? The measure is better understood as a change in how regulatory scrutiny is allocated rather than a removal of scrutiny. Evaluation Area Potential Benefit Possible Concern Processing Faster route for qualifying applications Not every case will qualify Manual intervention Less routine officer handling RA review remains Paperwork More end-to-end digital processing Accurate online information becomes more important Risk management Greater focus on selected cases Some auto-approved cases can still face review Exporter experience Potentially quicker routine processing Internal parameters are not fully disclosed Compliance burden Less administrative waiting in eligible cases Existing regulatory requirements continue MSMEs Smaller exporters may benefit from quicker routine processing Regulatory classification and documentation can still be difficult Oversight Resources can focus on cases requiring attention Automation should not be mistaken for unconditional approval On balance, the change appears favourable for exporters whose applications can be processed automatically. It removes part of the routine manual layer without removing the regulator's ability to verify cases that require attention. The burden is therefore more likely to come from application quality and regulatory preparedness than from a new compliance obligation created by this Trade Notice. For businesses already maintaining correct records and filing complete applications, the automated route may make the process easier. Businesses with unclear product applicability or inconsistent information may still encounter manual examination. What Exporters Should Check Before Filing an FSC Application The following are practical preparation points. They should not be confused with a new list of statutory duties created by Trade Notice No. 24/2026-2027. Exporters should check: Applicability of product: Verify if the product falls within the category of DGFT FSC route. Applicability of regulation: Verify whether Drugs & Cosmetics Act or any other product-specific regulations apply to the product. Export eligibility: Verify whether the product is free, restricted, or prohibited for export in accordance with the relevant policy. Accuracy of application information: Maintain correct business/product/exporter data. Applicable ANF: ANF 2H application can be made in accordance with 2.34 of Paragraphs. Documentation: Maintain documentation for the claims mentioned in the application. Business details on DGFT system: Maintain relevant business details up-to-date on the DGFT portal where required. Communication with DGFT portal: Follow up on application for any query/manual referral. DGFT's official FAQ has historically identified an IEC-linked user profile, registered digital signature, and valid RCMC details among the prerequisites for the FSC online service. Businesses should check the current portal requirements at the time of filing because operational requirements can be updated.  What Should Exporters Do If Their FSC Application Goes for Manual Processing? A manual referral should first be treated as a processing status, not as an adverse decision. The exporter should: Check the application status on the DGFT portal.  Review any communication issued by the concerned Regional Authority.  Identify whether verification or additional information has been requested.  Keep product and supporting records available.  Respond through the method and within any timeline specified by DGFT.  Check that the information supplied is consistent with the original application.  Seek regulatory assistance where the issue relates to product coverage, export policy, or interpretation of the FSC framework.  The Trade Notice itself does not create a separate appeal mechanism or special procedure simply because a case enters manual processing. Does the Trade Notice Change FSC Eligibility or Mainly the Processing Method? The central change is the processing method. Paragraph 2.34 already provides the regulatory basis for FSC issuance. The 31 August 2026 Trade Notice does not replace that framework with a new certificate. Instead, DGFT has enabled an automated route for eligible applications under the prevailing framework. This distinction prevents a common misunderstanding: exporters do not receive a new type of FSC because of this notice. What changes is how qualifying applications may move from submission to issuance. Existing provisions on product scope and FSC eligibility remain relevant unless separately amended. How Will Risk-Based Review Affect Exporters After FSC Approval? The possibility of post-approval review means businesses should not discard their regulatory records simply because the system has issued an FSC automatically. Practical preparation should include: Keeping the underlying product information available.  Maintaining consistency between the application and supporting records.  Retaining relevant certificates or regulatory records used for filing.  Monitoring DGFT communication after issuance.  Responding properly if an RA seeks review or clarification.  This should not be overstated. The Trade Notice does not say that every automatically issued certificate will be reviewed. It only provides that certain auto-approved applications may subsequently be flagged under risk-management parameters. DGFT FSC Automation: Key Points Exporters Should Not Misunderstand These are the main distinctions businesses should keep in mind: FSC filing was already online before this notice. The new development is automated processing and issuance for qualifying applications. Not every FSC application will automatically be approved. Manual processing continues where verification is required. Applications failing automated parameters can still move to the RA. Manual referral does not automatically mean rejection. DGFT Regional Authorities remain part of the FSC process. Certain auto-approved applications can later be reviewed. DGFT has not disclosed all internal automated-processing or risk parameters. No fixed turnaround time is promised in the Trade Notice. The correct FSC route depends on the product and applicable regulatory framework. How Can Exporters Prepare for DGFT's Shift Towards Automated Approvals? Businesses do not need to create an entirely new compliance structure because of this Trade Notice. They do, however, have a reason to improve the quality of information used in digital filings. Useful practices include: Maintain correct and updated exporter master data.  Keep IEC-linked information consistent with relevant business records.  Verify product descriptions before filing.  Check applicable export-policy conditions.  Avoid conflicting details across supporting documents.  Keep documents organised even if the application appears likely to qualify for automated processing.  Monitor portal messages after submission and issuance.  Assign responsibility internally for replying to any RA query.  Review future DGFT notices because automated-processing conditions can evolve.  These are practical controls rather than additional statutory requirements created by the Trade Notice. Impact on Businesses The effect will differ depending on how frequently a business uses the FSC process and how well organised its export-compliance records are. Stakeholder Likely Impact Main Consideration Exporters Potentially quicker processing of eligible applications Application accuracy MSME exporters Less routine waiting in qualifying cases Understanding product applicability Compliance teams More focus on pre-filing data quality Record consistency Export documentation teams More digital processing Portal monitoring Regulatory consultants Greater focus on applicability and complex/manual cases Correct interpretation DGFT Regional Authorities Fewer routine cases may require manual handling Verification and risk-selected cases Exporters Regular exporters may gain the most operational benefit where applications meet automated parameters, and no additional verification is needed. MSME Exporters Smaller exporters may benefit from reduced routine processing, particularly where they have limited internal resources. At the same time, automation does not remove the need to identify the correct certificate route. Export Compliance Teams Internal teams may need to place greater emphasis on getting the information right before submission rather than relying on later manual interaction to resolve inconsistencies. Export Consultants and Regulatory Teams Professional support may become more focused on product applicability, documentation quality, complex cases, and applications that move into manual review. What Businesses Should Do Next Exporters dealing with Free Sale and Commerce Certificates should take a few practical steps. Check Product Applicability- Determine whether DGFT is the correct authority for the product. Review Paragraph 2.34 Requirements- Check the current Handbook of Procedures rather than relying only on the two-page Trade Notice. Verify Application Information- Review business, exporter, and product details carefully before filing. Keep Supporting Records Ready- An automated decision does not rule out later review. Prepare for Manual Verification- A file can still be sent to the relevant RA where system conditions require it. Monitor the Application After Submission- Check official portal communication rather than assuming the application will proceed automatically. Retain Records After Issuance- Certain auto-approved applications can later be flagged for review. Follow Future DGFT Updates- The HBP expressly envisages phased implementation of automated processing, so exporters should keep track of subsequent operational changes.  How Corpseed Can Help with DGFT and Export Compliance The move towards automated FSC processing can make routine applications faster, but it also increases the value of getting the application right before submission. Corpseed's DGFT compliance services can support exporters who need help with applicability, documentation, and regulatory interpretation. Here are the areas where support may be useful: FSC Applicability Assessment Corpseed can help review the product and determine whether the DGFT Free Sale and Commerce Certificate framework is relevant. DGFT Regulatory Interpretation Businesses can receive assistance in understanding Paragraph 2.34, applicable DGFT procedures, and product-specific regulatory issues. FSC Application Support Corpseed can assist with preparation and filing of the Free Sale and Commerce Certificate application where the DGFT route applies. Export Documentation Review Application information and supporting records can be reviewed for completeness and consistency before submission. Manual Verification Support Where an application moves to the Regional Authority, Corpseed can assist businesses in understanding the communication and preparing the required response based on the official query. DGFT Query and Clarification Support Exporters facing a portal query or regulatory clarification can obtain help in understanding what has been requested and organising the response. Export Compliance Advisory Businesses can also seek support for related DGFT, IEC and foreign trade compliance matters where they affect an export transaction. Ongoing DGFT Compliance Support Exporters dealing with recurring regulatory requirements can use ongoing support to monitor relevant DGFT changes and maintain better filing controls. Exporters requiring assistance with FSC applications or related foreign trade requirements can use Corpseed's DGFT compliance services for product-applicability review, documentation support, filing assistance, and regulatory guidance. Professional support cannot guarantee automatic issuance or approval, but it can help reduce avoidable filing and documentation errors. Key Takeaways DGFT issued Trade Notice No. 24/2026-2027 on 31 August 2026 concerning automated FSC issuance. The change affects the processing of Free Sale and Commerce Certificate applications, not merely online filing.  Eligible applications may now be considered for automatic issuance.  Applications requiring verification or failing automated parameters can continue to the concerned Regional Authority.  Manual referral does not automatically mean rejection. Certain auto-approved applications may later be selected for risk-based review. The DGFT automated Free Sale and Commerce Certificate system is intended to support paperless processing and faster turnaround while retaining regulatory checks where needed.

Subject

Summary: The Commission for Air Quality Management in NCR and Adjoining Areas (CAQM) has reviewed its latest enforcement activity across the National Capital Region, with 121 Flying Squad inspections carried out during the 16 days from 8 August to 23 August 2026. The review took place at the 138th meeting of the Enforcement Task Force (ETF), held on 31 August 2026. The inspection activity covered several sectors, including industrial units, Construction & Demolition (C&D) sites and Diesel Generator (DG) sets. According to the government release, inspection reports led to proposals involving closure of four projects or industries, sealing of 17 DG sets, seven compliance orders or directions, and imposition of Environmental Compensation in five cases. The ETF also reviewed compliance with earlier enforcement decisions and the status of resumption after verification.  For businesses in Delhi-NCR, the update is less about a new rule and more about how environmental requirements are being checked and enforced on the ground. CAQM Enforcement Update at a Glance The main details reported by CAQM are summarised below.  Particular Verified Details Authority Commission for Air Quality Management in NCR and Adjoining Areas Enforcement body Enforcement Task Force Meeting 138th ETF meeting Meeting date 31 August 2026 PIB release date 1 September 2026 Reporting period reviewed 8 August to 23 August 2026 Reporting period length 16 days Total inspections 121 C&D inspections specifically reported 10 Industrial-sector inspections specifically reported 56 DG-set inspections specifically reported 20 Projects/industries proposed for closure 4 DG sets proposed/reported for sealing action 17 Compliance orders/directions 7 Environmental Compensation cases Imposition proposed in 5 cases New resumption orders reviewed 9 Cumulative inspections as of 31 August 2026 28,397 Cumulative Closure Directions 1,823 Cumulative Resumption Orders 1,473 Cases transferred to SPCBs/DPCC 126 Entities under examination for resumption 224 One point deserves attention. The release reports 121 inspections overall, while separately identifying 10 C&D inspections, 56 industrial inspections, and 20 DG-set inspections. These three figures total 86. The release does not provide a complete category-wise breakdown for the remaining inspections, so no additional sector should be assumed. What Did CAQM Review in the 138th Enforcement Task Force Meeting? The meeting was held to examine three connected areas: enforcement action, inspection activity, and compliance status across NCR. The review was not limited to inspections conducted during the latest reporting period. The Enforcement Task Force also checked what happened in actionable cases arising from the previous 137th ETF meeting. According to the release, all actionable cases relating to the industrial sector, C&D sector, and DG sets from the previous meeting had been acted upon. It also reviewed cases where entities had addressed compliance issues and subsequently received resumption orders after verification.  This makes the update useful for businesses because it shows that the enforcement cycle does not necessarily end with an inspection. Depending on the findings and later compliance position, further action can include closure, directions for compliance, verification and, where applicable, resumption. CAQM Inspection Drive Across NCR: What Happened Between 8 and 23 August 2026? CAQM reported that its Flying Squads conducted 121 inspections during the 16 days from 8 August to 23 August 2026. The release specifically identifies inspections involving C&D sites, industrial units and DG sets. These are important operational areas because non-compliance can involve activities taking place directly at a project site, factory or facility rather than being limited to documentation.  The 121-inspection figure must be separated from CAQM's cumulative enforcement data. The 121 inspections belong only to the latest reporting period. The much larger figure of 28,397 inspections relates to the cumulative enforcement position reviewed as of 31 August 2026. Sector-Wise CAQM Inspections Across NCR The release identifies three sectors within the latest inspection exercise. Their reported position is as follows: Sector/Activity Total inspections across all covered activities Business Relevance Construction & Demolition sites 10 Site-level environmental compliance remains under enforcement attention Industrial sector 56 Industrial facilities formed the largest specifically identified inspection category Diesel Generator sets 20 DG-set operation and compliance remain an enforcement focus Total inspections across all covered activities 121 Includes inspections beyond the three specifically quantified categories Construction & Demolition Sites CAQM reported 10 inspections across C&D sites during the 16 days. For developers, contractors and project owners, the main takeaway is straightforward: compliance has to exist at the physical project site. A project may have internal policies and records, but those will not replace actual implementation where environmental controls are required. The press release does not set out a fresh list of C&D requirements. Businesses should therefore refer to the currently applicable CAQM directions and other relevant approvals when assessing a project's actual compliance position. Industrial Sector The industrial sector accounted for 56 specifically reported inspections, making it the largest of the three quantified sectors in the release. Industrial units need to view environmental compliance as an operating responsibility rather than only a licence or documentation exercise. Where authorities carry out field inspections, actual plant conditions, operations and implementation can become relevant. This does not mean every factory in NCR will be inspected. The release shows that industrial units remain an active area of CAQM enforcement attention. Diesel Generator Sets CAQM reported 20 inspections related to DG sets during the period. The same release states that sealing of 17 DG sets was proposed or taken up on the basis of inspection reports for reported violations. Businesses relying on backup power should therefore check which CAQM directions currently apply to their DG sets rather than assume older operating conditions continue unchanged.  What Enforcement Actions Followed the Latest CAQM Inspections? An inspection does not automatically mean that enforcement action will follow. In the latest review, however, CAQM reported several proposed actions based on inspection reports concerning reported violations. The position stated in the release is: Enforcement Action Reported Position Practical Meaning Closure 4 projects/industries Operations or project activity may face interruption where closure action is ordered DG-set sealing 17 DG sets The concerned equipment cannot be treated as freely available for normal use once sealed Orders/directions for compliance 7 Concerned entities were required to address identified compliance issues Environmental Compensation Proposed in 5 cases Financial environmental liability was proposed; the release does not state the amount The terminology matters here. The press release says these actions were proposed based on inspection reports for reported violations. It should not be read as meaning every inspection resulted in closure or compensation.  Closure of Projects and Industrial Units for Reported Violations “Release” refers to the closure of four projects/industries, which include C&D facilities, as per the inspection reports received concerning violations of the laws. Closure is one of the major operational repercussions that come out clearly from the enforcement update due to the impact that it might have on ongoing operations. It may cause disruption of operations at a factory and delays in the process of construction works. The PIB release does not specify the length of closure for these cases, the individual entities involved, or a standard reopening timeline. Those details should therefore not be assumed. For businesses, the practical lesson is to deal with compliance gaps before they reach the stage where an enforcement direction affects normal operations. CAQM Action Against Diesel Generator Sets in NCR Diesel Generator sets receive separate attention in the enforcement data. CAQM reported 20 DG-related inspections during the review period and sealing action concerning 17 DG sets based on reported violations.  This does not mean that every DG set in NCR is prohibited or that all DG sets operate under identical conditions. Applicability can depend on the current CAQM directions and the particular circumstances of the equipment and facility. A business that depends on DG power should therefore avoid relying on assumptions based on old practices. Facilities and EHS teams should identify the current rules applicable to the DG set and keep an alternative operational plan where power continuity is important. Environmental Compensation Proposed in Five Cases The release states that imposition of Environmental Compensation (EC) in five cases was proposed. Environmental Compensation is distinct from inspection, sealing or closure. The important point in this update is the word “proposed.” It should not automatically be described as a finally recovered financial penalty. The press release does not specify the amount of Environmental Compensation proposed in these cases. It also does not provide a case-wise calculation or amount. Any specific rupee figure would therefore go beyond the source.  For businesses, this reinforces the financial side of environmental compliance. A compliance problem can affect operations, equipment, and potentially finances at the same time. What Are CAQM Resumption Orders? In the context of this release, a resumption order is connected with allowing activity to resume after the relevant authority has verified compliance. CAQM reported that nine resumption orders were issued after verification of compliance. These covered two industrial units and seven C&D projects. The broad enforcement pattern visible in the update is: enforcement action → corrective compliance → verification → resumption where accepted This should not be treated as a complete statutory resumption procedure for every CAQM case. The press release does not prescribe a universal application form, document list, or fixed processing timeline. What it does show is that corrective work needs to be capable of verification. Simply stating that a problem has been corrected may not be enough where the authority needs to check actual compliance before operations resume. State-Wise Resumption Orders Issued After Compliance Verification CAQM gave a state-wise split of the nine resumption orders discussed in the meeting.  State/UT Resumption Orders Delhi 1 Haryana 6 Uttar Pradesh 2 Total 9 The nine orders consisted of two industrial units and seven C&D projects. These figures also total nine, which is consistent with the state-wise distribution reported by the Commission. The key phrase used by CAQM is that the resumption orders were issued after verification of compliance. For a closed entity, corrective action therefore has practical value only when it can be demonstrated and accepted through the relevant verification process. Closure Direction vs Resumption Order: What Is the Difference? The two terms represent very different stages of enforcement. Point Closure Direction Resumption Order Basic meaning Requires the concerned activity or operation to stop as directed Allows the concerned activity or operation to resume. Compliance position Connected with enforcement action Connected with compliance being verified in the cases referred to by CAQM Operational effect Can interrupt production, construction, or other activity Restores the ability to resume the affected activity, subject to the order Business priority Correct the issue giving rise to enforcement Demonstrate compliance for verification Position in this release CAQM reported cumulative Closure Directions and recent closure actions CAQM reported resumption after compliance verification This is a practical explanation based on the enforcement position described in the release. It should not be treated as a substitute for the wording of an individual closure or resumption order. CAQM Cumulative Enforcement Status Across NCR as of 31 August 2026 The latest meeting also reviewed CAQM's cumulative enforcement position as of 31 August 2026. These figures are separate from the 121 inspections conducted during the 16-day reporting period. Enforcement Indicator Cumulative Position Inspections by Flying Squads 28,397 Closure Directions issued 1,823 Resumption Orders issued after compliance verification 1,473 Cases transferred to SPCBs/DPCC for final decision 126 Entities under examination for resumption orders 224 CAQM stated that 28,397 inspections had been carried out across units, projects and entities in NCR. Based on these inspections, 1,823 Closure Directions had been issued. Of these, 1,473 had subsequently resulted in Resumption Orders after verification of compliance.  The release does not specify in this passage the complete historical start date for the cumulative inspection figure. It is therefore safer to describe it as the cumulative position reported as of 31 August 2026 rather than assign an unsupported period to it. What Do the Cumulative CAQM Enforcement Figures Show? The cumulative figures reveal something that individual inspection numbers cannot: CAQM's enforcement system includes both restrictive action and a route back to operation after compliance is verified. The 1,823 Closure Directions show that enforcement can move beyond warnings or inspection observations. At the same time, 1,473 Resumption Orders indicate that a large number of cases subsequently moved to resumption after verification. There were also 224 entities still under examination for issuance of resumption orders as of the review date. This means some matters were still pending at that stage and should not be described as approved or rejected. For businesses, the practical message is that site-level compliance and evidence of corrective action can directly affect operational continuity. Role of State Pollution Control Boards and DPCC in CAQM Enforcement CAQM reported that 126 cases had been transferred to the respective State Pollution Control Boards (SPCBs) or the Delhi Pollution Control Committee (DPCC) for final decision.  The release does not disclose the outcome of those cases. It would therefore be incorrect to describe the entities as cleared, penalised or permanently closed. The figure also shows why environmental compliance in NCR can involve more than one authority. Depending on the matter, businesses may have to deal with both CAQM directions and requirements administered by the relevant state pollution-control authority. Internal compliance teams should therefore be clear about which regulator, approval, or direction applies to each operational issue rather than treating all environmental obligations as a single filing exercise. Which Businesses and Activities Are Under Continued CAQM Enforcement Attention? The release does not say that every business in these sectors will be inspected. It does, however, specifically identify certain activities for continued monitoring and active inspection. CAQM highlighted the following areas: Industrial units: Manufacturing and industrial operations remain part of the Commission's priority enforcement focus.  C&D activities: Construction and demolition projects continue to receive attention through site inspections and compliance review.  DG sets: Diesel Generator-related compliance remains an active area of enforcement.  Road works: The Commission also referred to road works among the priority sectors for continued inspection and monitoring.  CAQM linked this continued enforcement focus with effective mitigation of air pollution across NCR.  Impact of CAQM Enforcement on NCR Businesses The impact will differ by activity. An industrial unit, a construction project, and a facility using DG sets do not face the same operational issues. Industrial Units Industrial facilities face the possibility of field-level inspection rather than only scrutiny of documents. This makes the difference between paper compliance and operating compliance especially important. A permission or approval may show that a facility was authorised under a particular framework, but the actual site still needs to operate in line with the applicable conditions. Where an inspection identifies a serious issue and enforcement follows, operations may be interrupted. Plant heads, EHS teams and management therefore have a commercial reason to resolve environmental gaps before they become enforcement cases. Construction and Demolition Projects For construction businesses, a closure can affect schedules, contractors, labour planning and project delivery. The latest update also shows that C&D projects can move from enforcement to resumption once compliance is verified seven of the nine resumption orders discussed at the meeting related to C&D projects. Project managers should therefore treat environmental compliance as part of day-to-day site management rather than a responsibility that sits only with a central compliance team. Businesses Using DG Sets A sealed DG set can create an immediate business-continuity problem where a facility depends heavily on backup power. The practical response is not to assume that all DG sets face the same restriction. Businesses should first identify the current CAQM direction applicable to their location, equipment, and operating circumstances. Facilities teams should also discuss backup arrangements with management so that an equipment-related compliance issue does not unexpectedly interrupt critical operations. What Should Industrial Units Review Before a CAQM Inspection? The PIB release does not create a new inspection checklist. The following are therefore practical readiness measures, not a new list of statutory duties. Industrial units may consider reviewing these areas: Applicable CAQM directions: Identify which current directions apply to the facility's operations and equipment. Using an old compliance understanding can create avoidable gaps.  SPCB or DPCC permissions: Existing pollution-control permissions and their conditions should be checked against the facility's current operations.  On-site pollution-control arrangements: Equipment and controls that are required for the facility should be working in practice, not simply mentioned in internal documentation.  Monitoring and maintenance records: Where records are required or maintained, they should be organised and consistent with actual plant conditions.  Corrective actions: Older environmental observations should not remain unresolved without ownership or follow-up.  Inspection responsibility: Plant, EHS and operations teams should know who will coordinate with inspecting officials and where relevant records are maintained.  Evidence of compliance: Where a deficiency has been corrected, businesses should retain appropriate evidence showing what was changed and when.  These measures cannot replace the specific requirements applicable to a particular facility, but they can reduce avoidable gaps between formal approvals and actual operations. What Should C&D Projects Review for CAQM Compliance? Construction and demolition projects may use the latest enforcement update as a reason to check whether site-level environmental responsibilities are actually being followed. Useful areas for internal review include: identifying the latest CAQM directions applicable to the project;  checking relevant environmental or pollution-control conditions;  reviewing the condition of on-site pollution-control arrangements;  ensuring project and contractor responsibilities are clearly assigned;  checking whether identified deficiencies have been corrected;  maintaining relevant site records;  keeping evidence of corrective work; and  ensuring project teams are prepared to respond properly during an inspection.  The exact requirements will depend on the project and current applicable directions. Businesses should therefore avoid turning a generic checklist into a substitute for reviewing the actual legal and regulatory position. What Should Businesses Using DG Sets Review? DG-set users should begin with applicability rather than assumptions. Practical areas to check are: Current CAQM directions: Confirm the latest requirements relevant to the DG set.  Operating circumstances: Check whether the intended use is consistent with the applicable regulatory position.  Equipment condition: Maintenance and equipment condition should support whatever operating requirements apply.  Internal records: Relevant maintenance and compliance records should be available where required.  Responsibility: Facilities or engineering teams should know who owns DG-set compliance.  Contingency planning: Businesses that depend on backup generation should assess what happens if a DG set cannot be operated.  The PIB release itself does not specify technical capacity limits, fuel conditions or operating-hour restrictions, so those should not be inferred from this enforcement update. Compliance Risks Businesses Should Avoid The latest CAQM review also provides some useful compliance-management lessons. Practical risks that businesses may want to avoid include: Treating an environmental approval as the end of compliance: An approval does not remove the need to follow the conditions applicable during actual operations.  Relying only on paperwork: Inspection-based enforcement means site conditions can matter as much as files.  Leaving corrective work incomplete: Unresolved deficiencies can become more difficult to manage once formal enforcement has started.  Weak internal ownership: Environmental compliance can fail when no plant, EHS, project, or management team clearly owns an issue.  Poor evidence of correction: If a business has fixed a problem, it should be able to demonstrate what was corrected.  Ignoring new directions: Rules and operating conditions can change. Internal teams should not automatically rely on past practice.  Delayed response after enforcement action: Once a direction has been issued, delays can extend operational disruption.  How Does Compliance Verification Affect Resumption of Operations? The CAQM release shows a clear connection between compliance verification and resumption. The ETF reviewed cases from the 137th meeting and reported that nine resumption orders had been issued after verification of compliance. At the cumulative level, 1,473 resumption orders had also been issued following compliance verification.  For an affected business, this means corrective work should be capable of being checked. A response that exists only in email correspondence or an internal note may not be enough if the underlying site condition has not changed. It is also important not to treat every case as identical. The PIB release does not prescribe one universal resumption application or document set. The required response will depend on the actual enforcement direction and applicable regulatory framework. Operational and Cost Impact of CAQM Enforcement The release does not provide a rupee estimate of compliance costs. Still, several practical business effects can arise where environmental enforcement interrupts normal activity. Possible impacts include: Operational interruption: Closure can affect production or project execution.  Project delays: C&D businesses may need to adjust contractor and delivery schedules.  Corrective-work expenditure: Identified deficiencies may require technical or operational changes.  DG-set availability: Sealing can affect backup-power planning.  Internal management time: Compliance, legal, EHS, and operations teams may all have to work on the response.  Verification time: Resumption may depend on authorities being satisfied with corrective compliance.  Contractual effects: Delays can create knock-on issues for customers, contractors, or project commitments.  These are practical business implications. CAQM has not assigned a standard cost to them in the cited release. Is Stronger CAQM Enforcement a Right Decision or an Additional Burden? Stronger air-pollution enforcement has a clear public purpose: rules are useful only when compliance is checked. At the same time, inspections, corrective work, closure action, and compliance verification can place real pressure on businesses, particularly smaller units with limited environmental-compliance resources. The issue is therefore not simply enforcement versus business. The quality, consistency, and proportionality of implementation also matter. Evaluation Area Potential Regulatory/Public Benefit Possible Business Burden Balanced Assessment Air-quality protection Helps identify and address non-compliant activity Businesses may need additional controls and resources Environmental objectives require enforcement, but requirements should remain clear. Industrial inspections Encourages actual operating compliance Inspection preparation and corrective work take management time Regular readiness is more practical than last-minute correction. C&D inspections Supports better environmental control at project sites Work may be disrupted if serious gaps lead to action Site compliance should be integrated into project management DG-set enforcement Supports control of pollution from non-compliant operation Power backup can be affected Businesses need both compliance and contingency planning. Closure action Creates a strong response to serious non-compliance Can stop production or construction Closure has major commercial consequences and should be addressed quickly. Compliance verification Prevents unsupported claims of correction Verification can extend the recovery period Clear evidence and timely verification benefit both sides. Resumption orders Creates a route for compliant entities to restart Corrective work may require time and cost Resumption after verification encourages actual correction. MSME impact Encourages smaller units to follow the same environmental objectives MSMEs may have fewer technical and compliance resources Simple guidance and proportionate implementation are especially important Administrative workload Improves documentation and accountability Adds work for EHS, legal, and operational teams Strong internal ownership can reduce repeated compliance gaps. Long-term compliance culture Moves businesses toward regular environmental management Requires ongoing attention rather than one-time filing Long-term compliance is generally less disruptive than repeated enforcement. The strongest case for enforcement is that it makes environmental obligations meaningful. The strongest concern from a business side is operational disruption when gaps are discovered late. A workable balance therefore depends on clear rules, consistent implementation, timely compliance verification, and businesses taking responsibility before an issue reaches the closure stage. What Businesses in Delhi-NCR Should Do Now Businesses in sectors highlighted by CAQM can use this enforcement review as a reason to reassess their present compliance position. 1. Identify Applicable CAQM Directions Start with the actual activity being carried out. An industrial unit, C&D project, and DG-set user may be subject to different directions. The compliance team should identify the current documents applicable to the site rather than rely on an old internal checklist. 2. Review Current Environmental Permissions Check relevant approvals, consents, and operating conditions that apply to the facility or project. The purpose is not simply to confirm that a document exists. Actual operations should also be checked against its conditions. 3. Conduct a Compliance Gap Assessment Compare the current site position with applicable requirements. A gap assessment can identify unresolved issues before an external inspection brings them into an enforcement process. 4. Check On-Ground Implementation Management should not assume that a policy written at head-office level is being followed at every plant or project. Physical conditions should match the compliance position recorded internally. 5. Correct Identified Deficiencies Once a gap is found, give it a responsible owner and completion date. Leaving a known issue open without action can increase operational risk. 6. Maintain Evidence of Corrective Action Where a problem has been rectified, keep relevant evidence in an organised manner. This becomes especially useful if compliance later needs to be demonstrated or verified. 7. Prepare Responsible Personnel for Inspection EHS, facilities, plant and project teams should know who will communicate with inspectors and where relevant compliance records are maintained. Poor coordination can make even a manageable issue harder to explain. 8. Review DG-Set Compliance Where Applicable Businesses using DG sets should separately check the latest regulatory position applicable to their equipment. Backup-power planning should also consider the possibility that a DG set may become unavailable. 9. Review Active C&D Sites Construction companies and developers should not assume compliance at one project means every project is equally prepared. Each active site should be reviewed against the requirements applicable to it. 10. Track Future CAQM Directions and Enforcement Updates The regulatory position can change over time. Businesses operating in NCR should therefore have a process for identifying relevant CAQM updates and assigning them internally. Future Outlook for CAQM Inspections Across NCR The Commission has made clear that enforcement activity is expected to remain a focus. According to the release, CAQM reiterated the need to strengthen enforcement, ensure timely compliance verification, and improve coordination among implementing agencies. It also called for continued expeditious enforcement action, strict compliance monitoring, and active inspections across priority sectors.  The sectors specifically mentioned for continued attention include: industrial units;  C&D activities;  DG sets; and  road works.  This does not provide a future inspection number or timetable. It does, however, show that businesses in these sectors should not treat the latest inspection period as a one-off exercise. How Corpseed Can Help With CAQM and Environmental Compliance Environmental compliance in NCR can involve CAQM directions, pollution-control permissions, operating conditions and site-level implementation. The requirements can vary with the nature of the business, project, equipment and location. Corpseed can support businesses through relevant environmental compliance services, including: CAQM applicability review: Assess which CAQM directions may be relevant to the business, project or equipment.  Environmental compliance gap assessment: Compare current operations and records with identified compliance requirements and highlight areas needing attention.  Review of applicable CAQM directions: Help internal teams understand how current directions relate to their activity.  Pollution-control consent support: Assist with Consent to Establish or Consent to Operate requirements where these are applicable to the business.  Industrial environmental compliance support: Review environmental-compliance issues connected with industrial operations and ongoing regulatory obligations.  C&D compliance advisory: Support developers and contractors in understanding the environmental requirements applicable to project sites.  DG-set regulatory applicability review: Help businesses identify the current regulatory position relevant to their DG-set operations.  Environmental documentation review: Check whether relevant records and supporting documents are organised and consistent with the business's compliance position.  Inspection-readiness support: Assist teams in identifying gaps before an inspection and organising responsibilities internally.  Corrective-action support: Help structure the documentation and follow-up required where deficiencies have already been identified.  Ongoing environmental regulatory support: Track and assess compliance requirements relevant to continuing operations.  Industrial units, C&D projects and businesses operating DG sets in NCR can use professional environmental compliance services to identify applicable requirements, examine gaps and improve readiness for inspection and compliance verification. Key Takeaways The 138th CAQM Enforcement Task Force meeting gives businesses a clear picture of how inspection, enforcement, corrective compliance, and resumption can connect in practice. The main points are: CAQM's 138th ETF meeting was held on 31 August 2026.  The latest review covered the 16 days from 8 to 23 August 2026.  Flying Squads conducted 121 inspections during that period.  The release specifically reports 56 industrial, 10 C&D, and 20 DG-set inspections.  Closure of four projects/industries, sealing of 17 DG sets, seven compliance directions, and Environmental Compensation in five cases were proposed based on reported violations.  Nine resumption orders were issued after compliance verification: two for industrial units and seven for C&D projects.  CAQM's cumulative figures as of 31 August 2026 included 28,397 inspections, 1,823 Closure Directions and 1,473 Resumption Orders.  Industrial units, C&D activities, DG sets, and road works remain among the areas identified for continued enforcement attention.

Subject

Summary: The Telecom Regulatory Authority of India (TRAI) has given stakeholders more time to respond to its consultation on proposed changes to the Standards of Quality of Service of Access (Wireline and Wireless) and Broadband (Wireline and Wireless) Service Regulations, 2024. TRAI had issued the Consultation Paper on 5 August 2026. Comments were originally due by 26 August 2026, and counter-comments by 7 September 2026. Through Press Release No. 115/2026 dated 25 August, TRAI extended the deadline for comments to 2 September 2026 and stated that the deadline for counter-comments would be 15 September 2026. The extension followed requests from industry associations and other stakeholders.  The development matters because the underlying consultation is much wider than a simple deadline change. TRAI is examining proposed rules affecting 5G network slicing, network congestion, coverage maps, significant outages, broadband fault repair, billing complaints, service-quality reporting and financial disincentives. These are, however, draft proposals. They should not be treated as final compliance requirements until TRAI issues the final amendment. Notification at a Glance Particular Verified Details Regulator Telecom Regulatory Authority of India Related Ministry Ministry of Communications Document Press Release No. 115/2026 PIB Release ID 2303218 Press Release Date 25 August 2026 Consultation Paper Date 5 August 2026 Subject Draft amendments to the 2024 telecom and broadband quality of service Regulations Original Comments Deadline 26 August 2026 Revised Comments Deadline 2 September 2026 Original Counter-Comments Deadline 7 September 2026 Revised Counter-Comments Deadline in Press Release 15 September 2026 Reason for Extension Requests from industry associations and stakeholders Nature of Document Consultation/deadline extension not a final amendment What Has TRAI Announced in the Latest quality of service Consultation Update? TRAI has not announced a final amendment to the Quality of Service Regulations. The immediate announcement is much narrower: stakeholders have been given additional time to respond to proposals already placed in the public domain. The consultation was released on 5 August 2026. Its original timetable allowed comments until 26 August and counter-comments until 7 September. TRAI subsequently said it had received requests from industry associations and stakeholders seeking more time, after which the comments date was moved to 2 September and, according to Press Release No. 115/2026, counter-comments to 15 September.  That distinction matters. A telecom company does not become subject to the proposed 2026 provisions simply because the Consultation Paper has been issued. The consultation is an opportunity to examine the draft, point out difficulties, suggest alternatives, and place technical or commercial concerns before TRAI. What Is the Regulatory Framework Behind the Consultation? The existing framework is the Standards of Quality of Service of Access (Wireline and Wireless) and Broadband (Wireline and Wireless) Service Regulations, 2024, notified on 2 August 2024. The Regulations came into force from 1 October 2024. Their application covers service providers holding specified access-service licences, Unified Licences with access-service authorisation, internet-service authorisation under a licence, and entities authorised under the Telecommunications Act, 2023 to provide access or broadband services. The existing Regulations also contain an exclusion for certain internet service providers whose subscriber count does not exceed the prescribed level.  TRAI explains in the 2026 Consultation Paper that the 2024 framework consolidated quality of service requirements for access and broadband services and established parameters, benchmarks and reporting requirements. Following implementation, TRAI issued several directions on reporting, audits, coverage maps, and publication of performance.  The current consultation is therefore not a completely new quality of service regime. It is a proposed revision of an operating framework that has been in force since October 2024. Why Is TRAI Proposing Changes to the 2024 quality of service Regulations? TRAI says the proposed changes arise from its experience implementing the 2024 Regulations, interactions with service providers, technological developments, and the need for reliable digital connectivity. The Consultation Paper identifies four broad areas for review: emerging 5G issues such as network slicing, the framework for publishing coverage maps, changes needed for more effective quality of service monitoring, and correction of minor inconsistencies or issues identified during implementation.  This explains why the proposed amendment contains both major new ideas and relatively technical corrections. Some proposals could introduce new monitoring obligations, while others are intended to clarify how an existing parameter should be calculated or reported. What Are the Major Changes Proposed in the TRAI Consultation Paper? The Consultation Paper runs far beyond the deadline-extension announcement. Several proposed changes could materially affect telecom and broadband operations if they are eventually adopted. Area Proposal Under Consultation Possible Business Relevance Coverage maps Minimum 98% accuracy benchmark Greater validation and mapping controls 5G network slicing New PRB-utilisation parameter Cell-capacity and slice monitoring New 5G network slices Information to TRAI 21 days in advance Advance regulatory planning Silence calls ≤1% benchmark Additional voice-quality monitoring Wireline broadband MTTR ≤10 hours Stronger fault-repair monitoring Billing complaints Resolution within one week Faster complaint-handling processes Network outages Revised significant-outage framework Reporting and subscriber rebate implications Quality of Experience Proposed service-wise QoE Score Greater public comparison of providers Compliance reports Stronger treatment of incorrect reporting Higher data-governance importance Other non-compliance Proposed Regulation 16B Wider enforcement coverage Every item in this table remains proposed at the consultation stage. 1. Accuracy of Network Coverage Maps One of the clearest proposals concerns network coverage information. Under the draft, TRAI proposes replacing the existing parameter, based largely on the availability of a service-wise geospatial coverage map, with an accuracy-based parameter carrying a benchmark of at least 98%. The proposed assessment period is monthly.  The Consultation Paper explains the concern behind this change. TRAI observed that a coverage map can technically exist without necessarily matching actual on-ground experience. Areas shown as covered may still produce weaker coverage in field tests. The proposed framework therefore goes further into validation. Draft Schedule III deals with technology-wise maps for 2G, 3G, 4G and 5G, self-validation, updating the map when network coverage changes, and possible validation by TRAI through field samples.  For operators, the practical issue is no longer simply whether a map has been uploaded. If the proposal survives consultation, the quality and reliability of the underlying map could itself become a measurable quality of service matter. 2. 5G Network Slicing and PRB Utilisation The draft also responds to the growing use of 5G network slicing. Network slicing allows different virtual network segments to be created over shared physical infrastructure for different service needs. One slice may be designed for a particular business or use case while another serves general traffic. TRAI proposes a new parameter based on cells having daily Physical Resource Block (PRB) utilisation above 80%, with the proposed benchmark set at not more than 1%. TRAI describes PRB utilisation as a way to monitor whether radio resources are becoming persistently congested.  The thinking behind the proposal is straightforward: specialised network slices should not result in inadequate capacity for other users. The draft also proposes that a service provider planning to create a new 5G network slice submit details of proposed and existing slice parameters to TRAI at least 21 days in advance, demonstrating sufficient capacity in the relevant cells.  For 5G operators, this could bring network-slice planning much closer to regulatory and quality of service teams rather than leaving it only as a network-engineering decision. 3. New Silence Call Rate Parameter TRAI has proposed a new Silence Call Rate parameter with a benchmark of ≤1%. A silence call is a situation where a voice call remains connected but usable speech is not heard as expected. TRAI says such instances have been observed during drive tests and have also been reported by consumers. The current quality of service Regulations do not contain a dedicated silence-call benchmark.  If adopted, operators would have another measurable voice-quality parameter to monitor and report. For network teams, this may require closer examination of call-performance data rather than relying only on more familiar parameters such as call setup success or dropped calls. 4. Mean Time-To-Repair for Wireline Broadband The Consultation Paper proposes adding a Mean Time-To-Repair (MTTR) requirement for broadband delivered over wireline media. TRAI notes that an MTTR benchmark already exists for access service (wireline) but was omitted for broadband (wireline) when the 2024 framework was prepared. The proposed benchmark is ≤10 hours, assessed quarterly.  This proposal could have a direct operational effect on fibre, copper and cable broadband providers if finalised. Fault-ticket systems, field teams, restoration processes and escalation mechanisms may all need to produce reliable evidence of repair times. 5. Faster Resolution of Billing and Charging Complaints The existing provision referred to resolution of billing or charging complaints within four weeks. TRAI now proposes reducing that period to one week, while keeping the benchmark at 100%. This is a proposal with a clear customer-service impact. If adopted, affected providers would need to examine whether their current complaint-management workflow allows billing disputes, charging issues, and related monetary complaints to be investigated and closed within the shorter period. 6. Changes Relating to Significant Network Outages The draft also revisits the treatment of significant network outages. For wireless access services, the proposal would cover an event where service in a district remains unavailable continuously for more than four hours, or where more than 10% of subscribers in a Licensed Service Area experience complete loss of service for more than four continuous hours. For outages continuing beyond 24 hours, the draft provides for proportional rent rebate for applicable post-paid subscribers and validity extension for applicable pre-paid subscribers. Similar concepts appear in the proposed wireline-broadband provisions, although the exact definition and treatment differ by service. Operators should therefore study the actual drafting rather than treating “network outage” as a single uniform concept across all services. 7. Quality of Experience Score Traditional quality of service regulation mainly relies on measurable technical benchmarks. TRAI is now proposing an additional consumer-facing layer. The draft would allow TRAI to publish a service-wise Quality of Experience Score (QoES) based on factors relating to network performance, consumer service and consumer perception gathered from multiple sources.  The concept could matter commercially as well as regulatorily. A publicly available experience score may influence how consumers, enterprises and other stakeholders compare service providers. For operators, this would make customer experience, complaint handling and perceived service quality more closely connected to public regulatory reporting. What Are the Revised Deadlines for Comments and Counter-Comments? According to the 25 August 2026 PIB and TRAI press releases: Submission Original Date Date Announced on 25 August 2026 Extension Comments 26 August 2026 2 September 2026 7 days Counter-comments 7 September 2026 15 September 2026 8 days TRAI said the extension was granted after considering requests received from industry associations and stakeholders.  There is, however, an official-site discrepancy that businesses should check before relying on the second date. TRAI's homepage currently displays 2 September 2026 for comments and 15 October 2026 for counter-comments. The individual consultation page lists a 2 September closing date.  Until TRAI clarifies or publishes a later formal extension, the safest course is to verify the live deadline directly with the Authority before submitting counter-comments. What Is the Difference Between Comments and Counter-Comments? The two stages serve different purposes. Comments are the first substantive responses to the Consultation Paper. A service provider, industry association or other stakeholder can examine the proposed clauses, explain whether it agrees or disagrees, identify implementation issues and provide technical or regulatory justification. Counter-comments come later. They allow stakeholders to consider positions raised by others and respond where further clarification, disagreement or additional evidence is necessary. The original Consultation Paper asked stakeholders to give paragraph-wise input, comments or counter-comments along with justification and supporting references where available.  The consultation should therefore be viewed as a structured policy-feedback exercise rather than a simple yes-or-no vote. Why Did TRAI Extend the Consultation Deadline? TRAI gives a specific reason: requests were received from industry associations and stakeholders seeking an extension. Nothing in the release says that the draft was defective, that its implementation had been postponed, or that TRAI had changed its position on any proposal. Those conclusions should not be drawn from the deadline extension alone.  From a business perspective, however, more time can be valuable. The draft deals with network engineering, customer service, regulatory reporting, financial exposure, and public disclosure. A meaningful response may therefore require input from several internal teams rather than only the legal department. Who Should Pay Attention to the TRAI quality of service Consultation? Telecom and Access Service Providers Wireless and wireline access providers have the clearest interest because several proposals deal directly with mobile coverage, network outages, 5G capacity, voice performance and reporting. Broadband Service Providers Wireline broadband businesses should closely review the proposed MTTR requirement, fault-incidence calculations, network-outage provisions, billing complaint timelines and reporting changes. 5G Network and Engineering Teams Network-slicing proposals are technical enough that regulatory teams may not be able to assess them alone. Network planners may need to examine PRB utilisation, capacity thresholds and the proposed 21-day advance information requirement. Customer-Service and Billing Teams A proposed reduction in the billing/charging complaint-resolution period from four weeks to one week could require changes to escalation, investigation and account-adjustment processes. Regulatory, Compliance and Legal Teams These teams need to ensure that business responses distinguish between current law and proposed provisions, and that any objection is supported by operational or technical evidence. The existing 2024 Regulations apply to specified licensed or authorised service providers, with the application provisions set out in Regulation 1.  How Can Stakeholders Submit Comments to TRAI? The 25 August extension release says that comments and counter-comments may be sent electronically to: The original Consultation Paper also asks stakeholders to justify their input and, where available, provide supporting references.  TRAI's consultation webpage additionally displays an Add/View Comments facility requiring login.  Businesses should check the live consultation page and submission instructions immediately before filing. Does This Deadline Extension Create a New Compliance Requirement? No. The deadline-extension notice itself does not create a new substantive quality of service compliance requirement. That is one of the most important points in this update. Three things must be kept separate: Stage Legal Position 2024 quality of service Regulations Existing regulatory framework currently in force 5 August 2026 Consultation Paper Proposed amendments open for stakeholder feedback Final 2026 Amendment Not the same as the consultation will depend on subsequent TRAI action The Consultation Paper contains a draft notification titled the proposed First Amendment Regulations, 2026, and the draft currently refers to 1 October 2026 as its proposed commencement date. That date is part of the draft text and should not be presented as the effective date of a final regulation unless TRAI formally notifies the amendment.  The correct approach for businesses right now is to review, comment, and prepare not to treat every draft provision as already binding. Is Submission of Comments to TRAI Mandatory? The consultation notice does not say that every regulated entity is legally required to submit comments. Submitting comments is a form of participation in the regulatory consultation. That is different from complying with an existing quality of service benchmark or filing a mandatory performance report. A service provider may still have a strong commercial reason to participate. If a proposal creates technical difficulty, raises implementation concerns, or needs clearer drafting, the consultation is the stage at which those concerns can be placed on record. But failure to comment should not be described as a quality of service violation merely because an organisation chose not to participate. What Should Businesses Review Before Making a TRAI Submission? A useful submission should start with the exact proposed clause rather than a general objection. For each relevant amendment, businesses should examine the existing requirement, TRAI's proposed language, technical feasibility, availability of reliable data, system changes needed, implementation time, impact on network operations, effect on consumers and possible cost consequences. For example, an operator assessing the proposed 98% coverage-map accuracy benchmark may need input from radio-network planning, GIS and drive-test teams. A company responding to the one-week billing complaint proposal will need operational information from customer service, billing and dispute-resolution functions. The point is to show why a provision works or does not work—not simply to state that it is difficult. How Should Businesses Prepare an Effective TRAI Consultation Response? A practical response can follow a simple sequence: Identify the exact paragraph or draft provision being addressed.  State clearly whether the stakeholder agrees, disagrees, or proposes modification.  Explain the technical, operational or consumer basis for the position.  Add supporting data or references where reliable evidence is available.  Explain foreseeable implementation difficulties without exaggeration.  Suggest workable wording or an alternative approach where possible.  Check that claims made by different internal teams do not conflict.  Submit the final response using TRAI's applicable instructions and within the confirmed deadline.  This is practical preparation guidance, not a statutory filing checklist. What Should Telecom Businesses Do Before 2 September 2026? With the comment’s deadline stated as 2 September 2026, affected stakeholders have very little time left to complete their review. Businesses that intend to participate should first identify which proposals actually affect their network or operations. There is little value in submitting broad observations on every clause if only a few provisions create a real issue. Technical comments should be checked by the relevant network or systems team. Consumer-service proposals should be validated with operational teams. Legal and regulatory teams should review the final wording to ensure it does not confuse existing obligations with proposed ones. The final response should then be internally approved and sent using TRAI's official submission mechanism. What Should Stakeholders Do Before the Counter-Comment Deadline? Counter-comments require a different exercise. Once stakeholder comments are available, businesses should examine whether another submission raises an issue affecting their position. A counter-comment may be useful where another proposal would materially affect network design, compliance processes, competition, consumer experience or implementation feasibility. Not every stakeholder needs to respond to every comment. Given the present discrepancy between the 15 September date in Press Release No. 115/2026 and the 15 October date shown on TRAI's homepage, organisations planning to file counter-comments should verify the deadline directly with TRAI.  TRAI quality of service Consultation Timeline Date Development Meaning 2 August 2024 quality of service Regulations notified Principal regulatory framework 1 October 2024 2024 Regulations came into force Existing rules became operational 5 August 2026 Draft amendment Consultation Paper released Stakeholder consultation opened 26 August 2026 Original comments date Superseded by extension 25 August 2026 Extension announced More time provided 2 September 2026 Revised comments deadline Current comments date shown by TRAI 7 September 2026 Original counter-comments date Superseded by extension release 15 September 2026 Counter-comments date stated in Press Release 115 Verify before filing due to site discrepancy 15 October 2026 Date currently displayed on TRAI homepage Official-site discrepancy requiring confirmation The underlying 2024 Regulations were notified on 2 August 2024 and came into force on 1 October 2024. The 2026 consultation and subsequent extension are confirmed by TRAI and PIB.  What Could the Proposed Financial Disincentive Changes Mean? This part needs particularly careful wording because the amounts appear in the draft amendment, not in a final 2026 regulation. TRAI proposes separating different types of non-compliance more clearly. Proposed Regulation 16A deals with incorrect compliance reports. The draft provides for a financial disincentive of up to ₹2 lakh per benchmark per compliance report for a first contravention, up to ₹5 lakh for a second consecutive false report for the same parameter, and up to ₹10 lakh for subsequent consecutive cases. The draft also proposes treating a sufficiently large mismatch between reported and assessed data as false reporting in the circumstances specified.  Proposed Regulation 16B would address certain other provisions not already covered by specified financial-disincentive clauses. The proposal provides for up to ₹5 lakh per instance, potentially increasing to ₹8 lakh for a second consecutive contravention and ₹10 lakh for later consecutive contraventions.  The draft also proposes that failure to submit a compliance report within three months of its due date could attract a financial disincentive up to ₹10 lakh per report.  Again, these figures are proposals under consultation. They should not be described as newly effective penalties. What Happens After TRAI Receives the Comments and Counter-Comments? TRAI can consider stakeholder submissions as part of its regulatory review. That does not mean every suggestion will be accepted. TRAI may retain a proposal, revise it, remove it, or alter its wording before issuing any final regulation. The final amendment may therefore differ from the 5 August draft. Businesses should avoid redesigning their compliance framework solely on the assumption that every draft clause will survive unchanged. At the same time, proposals with potentially substantial operational consequences should be assessed early so implementation does not begin only after the final notification. Could the Consultation Lead to Future quality of service Compliance Changes? Yes. That is precisely why the consultation deserves attention. The proposals deal with matters that could require changes to network monitoring, complaint systems, regulatory reporting, GIS coverage maps, 5G capacity management and consumer-facing processes. A 5G operator may need different PRB reporting. A broadband company may need tighter fault-restoration monitoring. A customer-service team may need to process billing complaints much faster. Regulatory teams may need stronger validation before submitting quality of service data. But these are future compliance possibilities based on the current draft. They are not yet final requirements. Impact of the Proposed Changes on Telecom Businesses If the proposals are finalised substantially in their present form, their effect is unlikely to remain confined to regulatory teams. Network operations may face tighter monitoring of congestion, outages, silent calls and fault restoration. IT and data teams may need to improve the accuracy and traceability of quality of service information. GIS and radio-planning teams could have greater responsibility for published coverage information. Customer-service teams may face shorter complaint-resolution periods. Finance and billing teams may need dependable processes for rebates, validity extensions and customer adjustments. Management teams may need stronger assurance that compliance reports are based on validated data, especially where inaccurate reporting could carry separate financial consequences. The wider message is that quality of service regulation is becoming increasingly linked to the actual consumer experience rather than remaining only a set of network-level engineering metrics. Is the TRAI Deadline Extension Helpful for the Telecom Industry? For a consultation of this technical depth, additional time is useful. The proposed amendments touch radio networks, broadband operations, consumer complaints, financial exposure, reporting, and 5G architecture. A meaningful response can require coordination between people who normally work in separate functions. The extension allows businesses to improve the quality of their submissions and gives industry associations more room to consolidate member views. There is still a burden. Analysing a 200-plus-page Consultation Paper, testing proposals against network data and obtaining internal approvals can demand substantial effort, especially within a short response period. Even so, consultation-stage effort is usually more useful than raising implementation concerns only after a provision has been finalised. The real value of the extension lies in giving stakeholders a better opportunity to put specific, evidence-based concerns before the regulator. Business and Regulatory Perspective TRAI's draft shows how telecom regulation is moving alongside changes in network technology. The 2024 framework already created a consolidated quality of service structure. The 2026 proposals look at problems that have become clearer during implementation and at newer issues such as commercial 5G network slicing. TRAI specifically notes that network-slice services have begun to emerge on 5G Standalone networks in India, prompting examination of their possible impact on ordinary subscribers.  The coverage-map proposal follows a similar logic. Publishing a map is useful only if customers can reasonably rely on it. TRAI therefore wants the regulatory focus to shift from simply making coverage information available towards assessing whether that information is accurate.  For businesses, the direction is clear even before the final amendment: regulatory evidence will increasingly depend on measurable, auditable and consumer-relevant data. What Telecom and Broadband Businesses Should Monitor Next Businesses should watch the TRAI consultation page rather than treating the 25 August extension notice as the end of the process. The immediate items to monitor are publication of stakeholder comments, confirmation of the correct counter-comment deadline and any additional clarification issued by TRAI. After the consultation closes, attention should shift to any final amendment notification. At that point, businesses should compare the final text against the August draft clause by clause. Effective dates, transition arrangements, and technical specifications should be taken only from the final official document. Where a proposed provision is changed or dropped, internal planning should be adjusted accordingly. How Corpseed Can Help with TRAI and Telecom Regulatory Compliance? Telecom regulation often involves more than reading the wording of a notification. A proposed quality of service rule may need to be checked against network systems, operational data, reporting procedures and existing authorisations before its real business impact becomes clear. Corpseed can support businesses through relevant telecom regulatory compliance services, including regulatory applicability assessment, TRAI notification and consultation-paper review, compliance-gap assessment, regulatory research, documentation support, proposed-rule impact analysis and ongoing compliance monitoring. For a consultation such as this one, support can also focus on organising regulatory requirements, identifying business functions affected by individual proposals and reviewing documentation before a representation or response is finalised. Professional support cannot guarantee that TRAI will accept a stakeholder's position. Its value lies in helping the business prepare a clear, consistent and evidence-based regulatory response and understand what may need to change if the proposals are eventually notified.

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.

Subject

Summary: The Securities and Exchange Board of India (SEBI) has pushed back the implementation of certain trading norms for Exchange Traded Funds (ETFs) by six days. According to a circular dated August 28, 2026, the norms that were supposed to be made effective from September 1 shall now be implemented from September 7, 2026. This deferment is in view of an earlier SEBI circular dated June 15, 2026, related to base prices, price bands, call auctions and close-out in the pre-open session for ETFs. SEBI has not done away with those norms but has just extended the date for their implementation. The rest of the norms in the circular are unaffected. For the stock exchanges and others concerned with the trading in ETFs, this is merely a grace period. SEBI ETF Circular at a Glance Particular Details Regulator Securities and Exchange Board of India Department Market Regulation Department Circular Date August 28, 2026 Circular Number HO/47/11/11(1)2026-MRD-POD3/I/19839/2026 Earlier Circular June 15, 2026 Previous Implementation Date September 1, 2026 New Implementation Date September 7, 2026 Main Change Extension of implementation timeline Areas Covered Base price, price bands, pre-open call auction and close-out procedure for ETFs Main Addressees Recognised stock exchanges, recognised clearing corporations, AMCs of mutual funds and AMFI Other Provisions Remain unchanged The key point is fairly narrow. The August circular changes when the June requirements begin. It does not create a fresh set of ETF regulations. What Exactly Has SEBI Changed? SEBI has changed the implementation date from September 1, 2026 to September 7, 2026. That is the main regulatory development. The June 15 circular remains the document that contains the underlying ETF norms. According to the August 28 circular, those provisions were originally scheduled to become effective on September 1. Following feedback from stock exchanges, the regulator decided to allow implementation to commence on September 7 instead. Nothing in the extension circular suggests that SEBI has cancelled the new ETF framework. It also does not say that the requirements relating to price bands, base price, pre-open call auctions or close-out procedures have been relaxed. Businesses should therefore avoid reading the extension as a withdrawal of the earlier framework. Why Did SEBI Extend the Timeline? SEBI gives two clear reasons. It refers to feedback received from stock exchanges and says the change has been made to support the smooth implementation of the June 15 circular. The circular does not provide further detail on the nature of that feedback. It would therefore be wrong to assume that exchanges had reported system failures, legal difficulties or trading problems unless another official document says so. From a practical point of view, however, the short extension can give market institutions a little more time to finish work that was already underway. That may include checking technology systems, reviewing internal rules, coordinating between teams and making sure members and investors receive the correct implementation date. The extension gives more time. It does not remove the work. Which ETF Trading Areas Are Covered? SEBI's August circular refers to four parts of the earlier framework. Base Price for ETFs A base price generally acts as a reference point for applying trading controls to a security. The August circular confirms that base-price norms for ETFs form part of the June framework, whose effective date has been moved. It does not, however, repeat the actual calculation method. Any exchange, AMC, or other market participant that needs the precise formula or mechanism should refer to the original June 15 circular rather than trying to derive it from the August extension. Price Bands Price bands are used in securities markets to control the range within which a security can move during trading, subject to the rules applicable to that product. The June circular includes norms for price bands on ETFs. The August circular does not change or reproduce the percentages or calculation method. Its purpose is only to move implementation to September 7. Call Auction in the Pre-Open Session A call auction is a mechanism in which buy and sell orders are collected for a defined period and then matched according to the applicable market rules. SEBI's earlier ETF framework includes provisions concerning a call auction in the pre-open session. The August circular does not introduce new auction timings or a different matching method. It simply shifts the start date of the earlier provisions. Close-Out Procedure for ETFs A close-out procedure generally becomes relevant where a normal securities settlement cannot be completed in the expected manner. SEBI's June circular also deals with a close-out procedure for ETFs. As before, the extension circular does not provide any fresh rate, formula, or settlement amount. These have to be verified from the original June circular. Earlier Position vs New Position Area Earlier Position Position After August 28 Circular Implementation Date September 1, 2026 September 7, 2026 Base Price Norms Due to apply from September 1 Due to apply from September 7 ETF Price Bands Due to apply from September 1 Due to apply from September 7 Pre-Open Call Auction Due to apply from September 1 Due to apply from September 7 Close-Out Procedure Due to apply from September 1 Due to apply from September 7 Other June 15 Provisions Applicable as prescribed No change announced This comparison is useful because it prevents a common misunderstanding: the date has changed, but the August circular has not rewritten the rest of the June framework. Important Dates Businesses Should Track Event Date September 7, 2026 Original ETF Circular June 15, 2026 SEBI issued the relevant ETF trading norms Extension Circular August 28, 2026 SEBI changed the implementation timeline Earlier Start Date September 1, 2026 No longer the applicable commencement date Revised Start Date September 7, 2026 Covered provisions are now to take effect The critical date for implementation teams is now September 7. All internal calendars, operational plans, and regulation trackers need to be updated to reflect this new date. What Has Not Changed? SEBI has been quite clear on this point. The circular says that all other provisions of the June 15, 2026 circular remain unchanged. This implies that companies should not think that this extension has altered the essence of the requirements made previously. In simpler terms: The circular issued on June 15 still holds good, September 1 is no longer the start date, September 7 is now the implementation date, and The detailed technical requirements still need to be read from the June circular. Though the difference may seem small, it makes a difference in terms of compliance records. In case the policy paper or internal document still mentions September 1, it will cause confusion despite the rest of the organisation already using September 7. Who Needs to Pay Attention? The circular is addressed to: Recognised stock exchanges, Recognised clearing corporations, Asset Management Companies of Mutual Funds, and The Association of Mutual Funds in India. These are the entities named directly by SEBI. Other market participants and investors are also relevant because SEBI specifically requires the circular to be brought to their notice. Stock Exchanges Stock exchanges are at the centre of implementation because the framework deals with trading matters such as base prices, price bands and pre-open call auctions. They also have direct responsibilities under the August circular relating to systems, rules and communication. Clearing Corporations Clearing corporations need to consider the revised implementation from the perspective of the functions for which they are responsible. Where the June framework affects settlement or close-out arrangements, internal readiness may require coordination with exchanges and other relevant teams. Asset Management Companies AMCs managing ETF products should be aware of the revised implementation date and the way the exchange-level framework may affect ETF trading. The August circular does not create a fresh registration or approval process for AMCs. Its immediate effect is on implementation timing. Investors Investors do not need to make a new regulatory filing because of the extension. For them, the main point is that the covered ETF trading framework will start on September 7 instead of September 1. What Has SEBI Asked Market Infrastructure Institutions to Do? The August circular is not limited to announcing a new date. SEBI has also advised Market Infrastructure Institutions to take steps needed for implementation. The regulator specifically asks them to: Put the necessary systems in place, Amend relevant byelaws, rules and regulations wherever required, Bring the circular to the notice of market participants, including investors, and Disseminate the circular through their websites. These directions explain why the implementation extension matters. The additional time is meant to support preparation, not simply postpone the deadline on paper. What Should Exchanges Review Before September 7? A sensible readiness review should start with systems. If the June circular requires changes in how ETFs are handled during trading, the relevant systems should be tested against the new framework before it goes live. The next area is the rulebook. SEBI has specifically asked institutions to make amendments to byelaws, rules, and regulations wherever required. That qualification matters. It does not mean every existing byelaw has to be changed. It means each institution should check whether amendments are actually needed. Communication is the third area. Market participants should not be left working with two different implementation dates. Current notices, member communication and website information should therefore reflect September 7. System Readiness May Matter More Than the Extra Six Days Six additional days can be useful, but the value of the extension depends on how the time is used. For an exchange that had already completed most of its implementation work, the extra window may help with final testing and internal verification. For an organisation that still has major gaps, six days may not be enough to resolve everything. This is why implementation should not be treated as a last-day exercise. Technology, compliance, legal and operations teams may all be involved in different parts of the same regulatory change. If the system configuration says one thing while the rulebook says another, the organisation may still face implementation problems despite meeting an internal deadline. A final cross-functional review can therefore be more useful than simply checking whether individual tasks have been marked complete. Why the Words “Wherever Required” Matter One short phrase in the circular deserves attention. SEBI asks institutions to make amendments to their relevant byelaws, rules and regulations “wherever required.” That means the requirement is conditional. An institution should first determine whether its existing framework needs amendment. Where no amendment is needed, there is no reason to manufacture one simply because the circular mentions byelaws. Where an amendment is needed, however, the institution should make sure the regulatory text, internal procedures, and technical implementation remain aligned. This is the kind of distinction that is easy to miss when compliance teams work only from summaries instead of reading the circular itself. Communication with Market Participants Is Also Part of Implementation The move from September 1 to September 7 creates a simple but real communication issue. Some internal notices, compliance trackers or participant communications may already contain the original date. If those references remain unchanged, different teams or market participants may work with different assumptions. SEBI therefore directs relevant institutions to bring the circular to the notice of market participants, including investors, and publish it on their websites. The circular does not prescribe a special format for that communication. The focus is on making sure the revised position reaches the people who need to know about it. What Does the Extension Mean for AMCs and ETF Issuers? For AMCs, the extension is mainly a reason to check internal alignment. A practical review may include: Updating the implementation date in internal compliance records, Checking communications received from exchanges, Making sure trading and operations teams are working with September 7, Reviewing procedures that refer to the June circular, Confirming whether any internal documentation needs to be updated, and Monitoring exchange notices issued before implementation. These actions should be viewed as practical readiness measures unless a specific obligation arises under the underlying circular. The August 28 circular itself does not introduce a new licence, filing or certificate for AMCs. What Does It Mean for ETF Investors? For investors, the change is much simpler. The relevant ETF trading provisions will start six days later than originally planned. The circular does not say that ETFs will stop trading during this period. It does not cancel ETF products. It also makes no claim that the change will improve prices, returns, or liquidity. Investors should therefore treat the circular as an implementation update and rely on SEBI, exchange, and AMC communication for any operational details that affect trading. Is the Extension Good for the Market or Just More Compliance Work? The answer depends on the point of view. Area Where the Extension Helps What Still Needs Work Systems Gives more time for final checks Pending system changes still have to be completed Operations Allows more coordination Teams may still be under time pressure Legal Review Gives additional time to check rules and byelaws Necessary amendments cannot be skipped Compliance Allows records and plans to be corrected Underlying obligations remain Communication Reduces the risk of a rushed rollout Old September 1 references may still need correction Investor Awareness More time to communicate the correct date Mixed communication could still create confusion For institutions that were already close to completion, the extension should be useful. It provides a small buffer for final checks without changing the regulatory direction. At the same time, calling it major relief would be an overstatement. The underlying compliance work remains exactly where it was. A fair description is that the extension gives market institutions a short operational breathing space, not a reduction in their regulatory responsibilities. What Should Market Institutions Do Now? The immediate job is to make sure the revised date has been captured everywhere it matters. That includes compliance trackers, internal project plans and communication relating to the June framework. Relevant institutions should then review the status of: System implementation, Legal and regulatory changes, Required byelaw or rule amendments, Internal process updates, Staff communication, Member communication, and Website publication. The circular also makes it sensible to check whether different teams are working from the same version of the implementation plan. A change can appear complete on paper while gaps remain between legal, technology and operations teams. Compliance Readiness Checklist Action Who Should Review It Position Replace September 1 with September 7 in implementation records Relevant institutions Required to reflect revised regulatory position Put necessary systems in place Relevant MIIs Expressly directed by SEBI Review byelaws, rules and regulations Relevant MIIs Expressly relevant under circular Amend them where required Relevant MIIs Express SEBI direction Inform market participants Relevant MIIs Express SEBI direction Inform investors where relevant Relevant MIIs Express SEBI direction Publish/disseminate circular on website Relevant MIIs Express SEBI direction Coordinate legal, operations and technology teams Relevant organisations Recommended readiness control Monitor further regulatory communication Relevant stakeholders Recommended ongoing control Risks to Avoid During the Extension Period The most obvious risk is continuing to work with the old September 1 date. Another is assuming that because SEBI has given extra time, the June framework itself has been relaxed. That is not what the August circular says. Organisations should also avoid making unnecessary assumptions about requirements that are not written in the circular. For example, the extension does not create a new registration requirement, compliance fee, or penalty structure. A different kind of risk comes from internal communication. If one department updates its systems while another continues using an old procedure or notice, implementation can become inconsistent. The six-day extension is most useful when it is treated as time for checking these gaps. How Corpseed Can Help With SEBI Compliance Reading a regulatory circular is often the easy part. The more difficult question is deciding what actually applies to the organisation and what needs to change internally. Corpseed provides SEBI compliance consulting services and broader regulatory compliance services for businesses that need support in understanding and responding to regulatory requirements. Depending on the requirement, Corpseed can assist with: SEBI regulatory advisory services for understanding applicable circulars and regulatory changes, Regulatory interpretation services to separate direct legal requirements from operational recommendations, Compliance gap assessment to identify areas that may not match the latest regulatory position, Internal policy and procedure review, Regulatory documentation support, Implementation-readiness review, Compliance-process assessment, and Ongoing regulatory monitoring. For businesses operating in regulated financial or securities-market activities, securities market compliance consulting can also help bring legal, operational, and internal compliance teams onto the same page. The objective is not to create unnecessary compliance work. It is to identify what actually applies, what needs attention, and what does not. Corpseed does not guarantee regulatory approval, exemption, or a particular outcome. Professional support should be based on the business model, applicable regulations, and the specific SEBI requirement involved. Key Takeaways The circular issued by SEBI dated August 28, 2026 contains one significant modification. That is, the sections related to ETF trading which were contained in the circular dated June 15, 2026, shall come into effect from September 7, 2026 instead of coming into effect from September 1, 2026 as per the earlier circular dated June 15, 2026. SEBI has also asked relevant Market Infrastructure Institutions to prepare the necessary systems, amend rules or byelaws where required, inform market participants, and make the circular available through their websites. For exchanges and other affected institutions, the extra six days should therefore be used as a final implementation window, not treated as a cancellation of the earlier requirements.