Ritika manages regulatory compliance for an electrical appliance manufacturer in Noida. Her company was preparing to execute a supply order worth approximately ₹1.8 crore when the procurement team asked for an updated copy of its BIS licence.
The licence was due to expire in 74 days.
At first, Ritika expected the renewal to be a routine online filing. However, the production statement showed 1,26,400 manufactured units, while the sales and dispatch records accounted for only 1,21,850 units. Another 2,100 units had been rejected during quality checks, 1,450 units had been supplied as warranty replacements and 1,000 units remained in finished stock.
The review also found that 2 laboratory instruments would lose calibration validity before the renewal date. A newly launched product model had entered production but was not clearly included in the existing BIS licence scope.
The company separated the matter into 3 compliance activities – renewal of the existing licence, reconciliation of production data and inclusion of the new model. The calibration certificates were updated, the quantity statement was corrected and the application was filed within the prescribed period.
This example explains why businesses engage a BIS Certificate Renewal Consultant in India. Renewal is not limited to paying a fee or extending an expiry date. It involves checking production quantities, product scope, testing facilities, calibration records, marking-fee liability and continued compliance with the applicable Indian Standard.
The company, employee and commercial figures in this case study are illustrative. The compliance issues are based on commonly observed BIS renewal challenges.
BIS certificate renewal is the process through which a manufacturer continues its authority to use the BIS Standard Mark on products covered by an existing licence.
The term “BIS certificate” is commonly used by businesses, although the regulatory approval may technically be a licence or registration under a particular conformity assessment scheme. The renewal route depends on whether the approval falls under Scheme I, Scheme II or the Foreign Manufacturers Certification Scheme.
A renewal application also confirms that the manufacturer continues to meet the applicable Indian Standard. The company must maintain its manufacturing facilities, quality-control systems, testing equipment, calibration records and product-marking practices throughout the licence period.
The main BIS renewal routes include:
A licence expiry can affect production planning, dispatches, vendor approvals, tenders and market access. Filing the application close to the expiry date leaves little time to correct technical or financial discrepancies.
Production reconciliation alone can take several weeks when the figures recorded by the factory, finance department, dispatch team and GST system do not match. The business may also need additional time to renew calibration certificates, obtain test reports or implement an amendment to the applicable Indian Standard.
The renewal review should therefore begin before the formal application window. A preparation period of approximately 90 to 120 days gives the compliance team enough time to identify and correct material gaps.
Early preparation helps the manufacturer verify:
The Bureau of Indian Standards notified the BIS Conformity Assessment Amendment Regulations, 2026 on 25 February 2026.
Under the amended Scheme I framework, a licence to use the Standard Mark may initially be granted for up to 5 years. It may also be renewed for a further period of up to 5 years. Required fees remain payable annually in advance.
The revised Scheme II framework also permits an initial licence period of up to 5 years and renewal for a further period of up to 5 years. A longer licence period does not remove the obligation to maintain continued conformity or complete annual compliance activities.
Manufacturers should separately track:
The 2026 amendment introduced a clearer annual-continuation mechanism. The annual fee must be paid in advance, together with the required production statement, by the applicable due date.
Where the annual fee and production statement are not received by the due date, operation of the licence may remain suspended for 90 days. If the manufacturer regularises the matter during that period, a late fee of ₹5,000 applies.
Failure to submit the annual fee and production statement during the 90-day suspension period can result in cancellation of the licence. Payment alone may not remove a suspension if another technical non-compliance or sample failure remains unresolved.
The important numerical controls are:
| BIS route | Renewal requirement | Filing timeline | Main documents | Principal risk |
|---|---|---|---|---|
| Scheme I – ISI Mark | Renewal through Form XII | Preferably 2 months before validity date | Form XII, production statement, self-compliance report and fee records | Expiry, suspension or marking-fee shortfall |
| Scheme II | Renewal through Form VI | 3 months before expiry | Form VI, production report, payment details and scope information | Registration lapse or rejection |
| FMCS | Form XII with foreign-manufacturer records | Begin preparation 90-120 days before expiry | Production records, consignee details, marking fees and bank guarantee | Import and market disruption |
| Annual continuation | Annual fee and production statement | Before the applicable due date | Payment receipt and production details | 90-day suspension and cancellation |
| Scope extension | Separate inclusion application | Before marking the additional model | Test report, model details and technical documents | Unauthorised marking |
The Scheme I renewal guideline states that the application should be made through the BIS portal in Form XII, preferably 2 months before the licence validity date. It also requires the relevant production statement and self-compliance report.
For Scheme II, the renewal application is made in Form VI and must be submitted 3 months before expiry. The renewed licence is issued in Form VII.
A BIS Certificate Renewal Consultant in India first identifies the exact regulatory scheme under which the licence was issued.
This step is important because Scheme I, Scheme II and FMCS do not follow identical documentation or fee structures. Filing the wrong form or treating a model-inclusion request as a routine renewal can delay the case.
The consultant then compares the existing licence against the company’s current manufacturing activities. Every licensed model, variety, grade, brand and manufacturing location should be checked.
The review normally covers:
A consultant can coordinate documentation and filing, but the manufacturer remains responsible for accurate declarations and continued product conformity. Renewal approval remains with BIS.
Scheme I generally applies to products licensed to carry the ISI Mark.
The renewal application is filed through Form XII. The manufacturer must also provide production information for the relevant operative period and a self-compliance report.
According to the BIS Scheme I renewal guideline, the production statement should be authenticated by a chartered accountant or cost accountant. The document should mention the professional membership number, manufacturing-unit details and actual production quantity.
The Scheme I renewal file may include:
The exact document list may differ according to the product, Indian Standard, product manual and licence history.
The production statement is one of the most important parts of a Scheme I renewal.
The figures should be checked against production registers, sales invoices, GST records, dispatch records and finished-goods inventory. The manufacturer should also separately identify rejected units, warranty replacements, samples and exports.
For the first operative year, the 2025 BIS renewal guideline refers to the production statement for the first 9 months. For subsequent operative years, it refers to the last 3 months of the previous operative year and the first 9 months of the current operative year.
For example, a factory may record 2,40,000 units during the reporting period, but the internal breakup may show:
The business should determine the correct regulatory treatment of each category before finalising the production statement and marking-fee calculation.
The self-compliance report confirms that the manufacturing unit continues to operate according to the licensed conditions.
The report covers organisational changes, brand information, manufacturing processes, testing infrastructure, raw-material control, implementation of the latest Indian Standard and closure of previous BIS instructions.
It also requires confirmation that in-house test equipment remains calibrated and in proper working condition. Where testing is subcontracted, supporting laboratory and test-report information may be required.
Before filing, the quality team should verify:
Fresh product testing is not automatically required in every routine renewal. It may become necessary where the standard, critical components, product design or model has changed, or where previous conformity cannot be established.
A 120-day internal schedule allows different departments to complete their responsibilities without waiting until the final application date.
The compliance team should coordinate with finance, production, quality control, laboratory staff, management and the authorised signatory.
| Time before expiry | Renewal activity | Responsible team | Risk controlled |
|---|---|---|---|
| 120 days | Review licence, product scope and Indian Standard | Compliance and technical teams | Incorrect scope or outdated standard |
| 105 days | Reconcile production, GST and dispatch records | Finance and operations | Incorrect production statement |
| 90 days | Prepare Scheme II application, where applicable | Compliance team | Missing the 3-month filing requirement |
| 75 days | Review laboratory and calibration status | Quality team | Expired calibration |
| 60 days | Submit Scheme I application, preferably | Authorised applicant | Late renewal |
| 45 days | Monitor portal observations | Compliance team | Delayed query response |
| 30 days | Confirm fee and document completeness | Finance and compliance teams | Outstanding dues |
| 15 days | Review licence status and dispatch controls | Management | Unauthorised marking |
| Expiry date | Confirm continued licence validity | Authorised signatory | Production and sale disruption |
The Scheme I guideline recommends submitting Form XII preferably 2 months before the validity date. Scheme II requires Form VI 3 months before expiry.
Scheme II follows a specific fee structure under the 2026 amendment.
The application fee, annual licence fee and renewal application fee are ₹1,000 each. An annual processing fee of ₹25,000 applies per application for grant and continuation of the licence.
Where an application contains more than 1 test report, an additional ₹20,000 is charged for every extra test report. A renewal requested for more than 2 years attracts ₹25,000 for each additional year, payable annually in advance.
| Scheme II fee category | Amount |
|---|---|
| Application fee | ₹1,000 |
| Annual licence fee | ₹1,000 |
| Renewal application fee | ₹1,000 |
| Annual processing fee | ₹25,000 |
| Each additional test report | ₹20,000 |
| New model, variety or scope extension | ₹30,000 |
| Specified service request | ₹5,000 |
The amendment provides processing-fee concessions until 31 May 2029:
From 1 June 2029, the specified processing-fee concession for micro, small and medium enterprises becomes 20 percent. Eligibility must be supported by valid documents.
These Scheme II figures should not be treated as universal fees for every ISI or FMCS renewal. Scheme I charges can include product-specific marking fees, annual fees and other applicable dues.
Renewal continues the approved scope of the existing licence. It does not automatically authorise a new model, rating, grade, brand or manufacturing location.
A business introducing a new model should first check the applicable grouping guideline. The model may require a separate test report and inclusion application.
Under Scheme II, inclusion of a new model, variety or extension of scope carries a fee of ₹30,000 per application. Certain post-licence service requests, including changes in name, address, management, Indian representative, contact information or model withdrawal, carry a fee of ₹5,000 per request.
The manufacturer should separately manage:
Combining unrelated changes into a routine renewal application can create confusion and delay.
Foreign manufacturers generally need additional renewal documentation because the compliance arrangement includes an Authorised Indian Representative.
The BIS FMCS renewal page lists Form XII, month-wise production information, complete consignee addresses, applicable marking-fee payment and an extended performance bank guarantee.
The performance bank guarantee should extend 6 months beyond the licence-validity period. A renewal application made after licence validity is also accompanied by a ₹5,000 late fee under the published FMCS guidance.
An FMCS renewal review should cover:
Foreign manufacturers should begin preparation at least 90 to 120 days before the relevant date because bank-guarantee extensions and document coordination may take additional time.
A large number of renewal issues begin with inconsistencies in company records.
The production quantity may not match the marking-fee calculation. The GST address may differ from the licence. The company may have changed its authorised signatory without updating the portal.
Technical issues can also delay renewal. Calibration certificates may have expired, the factory may not have implemented a revised Indian Standard or previous sample failures may remain unresolved.
Common query triggers include:
The objective should not be to file the quickest application. It should be to submit an application supported by accurate and verifiable records.
A suspended, expired or cancelled licence can prevent the manufacturer from lawfully using the BIS Standard Mark.
The business may also face interrupted dispatches, rejected purchase orders, marketplace action or tender-related problems. For imported regulated products, an invalid or expired approval may also contribute to customs or documentation delays.
Section 29(3) of the BIS Act, 2016 provides penalties for contravention of Section 17. The punishment may include imprisonment for up to 2 years or a fine of not less than ₹2 lakh for the first contravention and not less than ₹5 lakh for the second and subsequent contraventions. The fine may extend to 10 times the value of the affected goods, or both imprisonment and fine may apply.
Potential risks include:
These consequences are not triggered by every documentation error. The legal outcome depends on the nature of the non-compliance, licence status and action taken by BIS.
Green Permits assists manufacturers, importers and foreign brands with structured BIS licence-renewal preparation.
The process begins with a review of the existing licence, expiry date, applicable scheme and product scope. The team then examines production records, fee calculations, testing documents and unresolved compliance issues.
Support may include:
Green Permits assists with application preparation and regulatory coordination. The authority to grant, renew, suspend or cancel a licence remains with BIS.
BIS renewal should be treated as a structured compliance project rather than a simple certificate-extension activity.
The 2026 framework allows an initial validity of up to 5 years and renewal for up to another 5 years under the relevant schemes. However, annual fees, production reporting, testing controls and continued conformity remain mandatory. Failure to complete annual requirements can lead to a 90-day suspension, a ₹5,000 late fee and possible cancellation.
Beginning the renewal review 90 to 120 days before expiry gives the manufacturer time to correct production discrepancies, update calibration certificates, address product changes and prepare accurate supporting records.
A BIS Certificate Renewal Consultant in India can coordinate the process and reduce avoidable filing errors. The manufacturer must still ensure that every declaration, test record and production figure submitted to BIS is complete and accurate.
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Under the 2026 Scheme I and Scheme II provisions, a licence may initially be granted for up to 5 years and renewed for a further period of up to 5 years. Annual compliance requirements continue during the licence period.
The Scheme I renewal guideline recommends filing Form XII preferably 2 months before the validity date. Starting the internal review 90 to 120 days earlier is advisable.
The Scheme II renewal application must be filed in Form VI 3 months before the licence expires.
Non-receipt of the annual fee and production statement by the due date can result in suspension for 90 days. Regularisation during that period requires the applicable dues and a ₹5,000 late fee. Continued default can result in cancellation.
