The BIS (Conformity Assessment) Amendment Regulations 2026: What Changed, Who It Hits and What to Do About It

On 25 February 2026 the Bureau of Indian Standards quietly rewrote the rulebook that governs how manufacturers and importers get and keep the right to use the ISI mark. The Bureau of Indian Standards (Conformity Assessment) Amendment Regulations, 2026 amend the parent Bureau of Indian Standards (Conformity Assessment) Regulations, 2018 which has since June, 2018 governed the grant continuation suspension and cancellation of licences to use the Standard Mark and of certificates of conformity. Nothing in the amendment touches the underlying statute. What it does touch is the machinery. The fee a licensee pays and when it falls due how long a licence lasts before renewal what happens the moment payment lapses and a reconceived Scheme-II that lets a new category of applicant reach the certified market without a full factory audit.

This piece works through the statutory foundation the amendment rests on, sets out precisely what has changed and then goes further than a straight compliance digest would. It asks who actually benefits who carries more risk than before and where the framework still looks unsettled.

1. The Statutory Architecture Behind the Amendment

BIS draws its authority from the Bureau of Indian Standards Act 2016f which repealed the 1986 statute of the same name and established the Bureau as a body corporate under the Department of Consumer Affairs. Section 12 empowers the Bureau to notify a conformity assessment scheme for any goods article process system or service. Section 13 empowers the Director General to grant a certificate of conformity or a licence to use the Standard Mark subject to conditions and fees “as determined by regulations.” Section 16 lets the Central Government direct compulsory use of the Standard Mark for scheduled goods. This is the constitutional basis of the Compulsory Registration Scheme and contravening the resulting licensing requirement carries criminal exposure under Section 17 read with Section 29.

Two subordinate instruments give these sections their operative content and it’s worth being precise about which is which because practitioners sometimes conflate them. The Bureau of Indian Standards Rules 2018 were made by the Central Government under Section 38 and deal with the Bureau’s internal governance plus Rule 15 which sets out the procedure for amending individual Indian Standards. The Bureau of Indian Standards (Conformity Assessment) Regulations, 2018 on the other hand were made by the Executive Committee under Section 39 read with Sections 12 and 13 with the Central Government’s prior approval. It’s this second instrument, the licensing and certification machinery, that the 2026 amendment revises.

2. Origin Authority and Scope of the 2026 Amendment

The 2026 Amendment Regulations were published in the Gazette of India Extraordinary Part III Section 4 under File No. BS/XI/11/01/2025-26 and came into force the same day. They were made by the Executive Committee under the same statutory authority as the parent Regulations. Rather than build an entirely new certification pathway the amendment restructures the existing machinery around three axes: the financial discipline attached to holding a licence or certificate the duration for which that authorisation runs and the procedural architecture of the ten conformity assessment schemes set out in Schedule-II of the 2018 Regulations.

A corrigendum also dated 25 February 2026 and updated through the following months refined the validity provisions. The corrigendum corrects the validity language reflected in the table below and forms part of the applicable regulatory text. It carries the same legal force as the principal amendment and must be read together with it, not treated as a separate or optional document.

3. What Changed at a Glance

That table tells you what changed. It doesn’t on its own tell you what any of it means for a business trying to plan around it. That’s really the harder question and the one the rest of this piece tries to answer.

Legal change versus practical consequence

4. The Detailed Changes Validity

Licences and certificates issued under the amended framework can now run for up to five years on initial grant and be renewed for further periods of up to five years. Before the amendment the typical cycle was two years. On its face this is a straightforward relief measure. Fewer renewal applications and less repeated paperwork. Whether it functions that way in practice depends entirely on what happens in the years between grant and renewal. That brings us to the annual obligations that the extended validity period does nothing to relax.

Annual Fees and Production Statements

Regulations 5 and 13 now require the fee to be paid annually and in advance at grant and then for every year the licence or certificate continues. Regulations 6 and 14 require an annual production statement filed alongside the fee within whatever timeline the applicable scheme prescribes.

Neither obligation existed with this degree of structure before. A licensee used to thinking in terms of a biennial renewal now needs to think in terms of an annual due date full stop.

Suspension and Cancellation

This is where the amendment gets its teeth. Regulations 8 and 16 set out a 90 day suspension window running from the due date of an unpaid fee. Pay a Rs 5,000 late fee within that window and the suspension is cured. Let the window close without paying and cancellation follows. Compare this to the general regime which retains a 21 day notice requirement for non-financial grounds. That notice requirement is expressly dispensed with for non-payment since Regulations 8 and 16 already supply their own procedure. There’s no informal grace period built in here. The clock starts on the due date not on some later date when BIS gets around to writing a reminder letter.

Certificate of Conformity Holders

Before the amendment the compliance architecture leaned toward licence holders. CoC holders sat somewhat outside the annual fee suspension and cancellation regime. Regulations 13 14 16 18 and 19 now extend the identical regime to them. If your business holds certificates of conformity rather than or in addition to Standard Mark licences none of the relief described above should be read as applying only to the licence side of the house.

5. Scheme-II: From Assessment to Self Declaration

Of everything in this amendment Scheme-II is the change most likely to actually alter how a business goes to market. It’s also the one that repays the closest reading.

Scheme-II existed but it operated as an assessment based registration route with a processing fee of Rs 50,000 per application payable yearly.

Scheme-II now runs on self declaration of conformity. A Type C assessment under Schedule-I. The applicant submits Form-I for each product separately a conformity undertaking on Form-II supported by third party test reports and an affidavit on one of three forms depending on whether it’s a manufacturer with an Indian branch a brand owner or nominee or a domestic manufacturer. A foreign manufacturer has to go one step further and nominate an Indian representative on Form-IV. Schedule-II classifies all ten conformity assessment schemes by whether a site visit is required. Schemes I IV V IX and X require one while Schemes II and VII do not. The processing fee under Scheme-II drops to Rs 25,000 payable yearly in advance.

Why it matters. No factory visit and half the fee is a meaningful reduction in the friction of getting certified particularly for products that don’t commercially warrant the cost of a full audit. That’s a genuine efficiency gain and it’s the headline the Bureau will presumably want businesses to take away.

The residual risk. But here’s the thing a headline doesn’t capture. Self declaration doesn’t mean no scrutiny. It means scrutiny moves. BIS retains market surveillance and third party sampling as its check on what’s been self declared. So Scheme-II doesn’t really lower the total amount of compliance work a manufacturer needs to do. It shifts that work from an ex-ante factory assessment done once before certification to an ex-post reliance on the integrity of the manufacturer’s own test reports documentation and internal controls checked later and unpredictably through surveillance. A manufacturer with weak internal quality controls may find that what looked like a lighter compliance route turns into a bigger enforcement exposure the first time a surveillance sample fails. Whether BIS deploys that surveillance with real rigour or whether Scheme-II becomes the path of least resistance for products that would actually benefit from closer scrutiny isn’t something the regulatory text can answer. It’ll be answered by how BIS allocates enforcement resources over the next few years. That’s precisely the kind of thing that doesn’t show up in a Gazette notification.

6. Scheme-I: What Remains Assessment Heavy

Scheme-I is the route by which most ISI marked products get certified and it keeps its on site factory assessment. What’s changed around it is the fee and testing architecture. The Minimum Marking Fee is now split. 50 percent is payable at application and the remaining 50 percent at grant of licence subject to a defined refund clause. Testing costs run through one of two arrangements. Option-1 where the applicant bears the testing cost directly or Option-2 where a verification sample is tested as a surveillance sample. Applicants under the Foreign Manufacturers Certification Scheme are routed to Option-1. None of this reduces the substantive burden of Scheme-I. It restructures when and how the money moves not whether the factory gets inspected.

7. MSME and Start-Up Concessions

Under the revised Scheme-II micro enterprises and start-ups get an 80 percent concession small enterprises get 50 percent and medium enterprises get 20 percent. This tiered structure holds until 31 May, 2029. From 1 June, 2029 onward a uniform 20 percent concession applies across the board to all MSMEs under Scheme-II. Eligibility for these concessions draws on definitions from the Micro Small and Medium Enterprises Development Act 2006 and the Income-tax Act 1961/2025. Neither statute is touched by the 2026 Regulations but both determine whether a given applicant actually qualifies. Get the classification wrong and the concession claimed may not hold up.

8. Foreign Manufacturers Brand Owners and Indian Representatives

The Scheme-II documentation requirements draw sharper lines around who’s actually applying. A domestic manufacturer files one affidavit form. A brand owner or nominee files a different one. A manufacturer operating through an Indian branch files a third. A foreign manufacturer has an additional step: nominating an Indian representative on Form-IV. For an importer bringing in

a foreign manufactured product the practical question becomes who in this chain actually carries the compliance obligation day to day. Is it the foreign manufacturer the nominated Indian representative the brand owner or the importer itself? The regulation assigns roles. A supply contract still has to assign responsibility between them.

This Amendment Doesn’t Operate in Isolation

BIS certification is one layer in a stack not the whole stack. Manufacturers of goods notified under Section 16 (the Compulsory Registration Scheme population) remain bound by the relevant Quality Control Order and by whatever Customs and DGFT clearances condition import of those goods. Put simply: an Indian Standard sets the technical requirement BIS certification or registration confirms conformity with it a QCO makes that certification mandatory for the product category and Customs or DGFT clearances govern the actual movement of goods across the border. The 2026 amendment sits at the certification layer only. It doesn’t touch the Standard, the QCO or the customs requirement sitting above or below it.

A separate and considerably more routine BIS process runs alongside this one. The periodic revision of individual Indian Standards under Rule 15(1) of the BIS Rules 2018. A July 2026 notification for instance amended eight Indian Standards spanning categories from LPG cylinders to infant feeding bottles with a transition deadline of 19 January 2027. That’s a technical content track addressed to what the standard actually requires and it’s entirely distinct from the licensing framework this amendment reshapes. Licence holders shouldn’t conflate the two. Tracking your licence renewal date tells you nothing about whether the underlying standard your product certifies against has just been revised.

The broader consumer protection rationale for the Standard Mark also sits alongside the Consumer Protection Act 2019 and the Legal Metrology Act 2009. None of these statutes is amended by the 2026 Regulations. Each supplies context worth keeping in view.

What the Amendment Does Not Change

It’s worth being explicit about this if only to head off overreading a text this dense.

• The statutory foundation under Sections 12 and 13 of the BIS Act 2016 is untouched.
• The distinction between the ten conformity assessment schemes in Schedule-II remains.
• Compulsory certification or registration continues to apply wherever a QCO says it does.
• The underlying technical requirements of any given Indian Standard are unchanged unless separately amended under Rule 15(1).
• BIS’s surveillance and enforcement powers continue in full and if anything are more central to the framework than before given Scheme-II’s reliance on them.

10. Compliance and Enforcement Risk

11. Who Benefits and Who Carries More Risk?

Read one way this amendment moves toward ease of doing business. A five year validity cycle instead of a two year one cuts the frequency of full renewal filings. The Scheme-II processing fee is halved. The tiered MSME concessions put real relief behind the Bureau’s stated policy intent.

Read another way the amendment trades one burden for a different one. What was a heavier obligation once every two years is now a lighter but far more strictly enforced obligation every single year backed by an automatic suspension and cancellation mechanism that leaves almost no room for informal grace. A manufacturer with uneven cash flow may actually find a fixed annual due date harder to manage than an infrequent but predictable biennial renewal. The fee concessions don’t change that.

Scheme-II is the piece that resists sitting neatly on either side. It lowers the entry barrier for products that don’t commercially justify a full factory audit while BIS keeps market surveillance and third party sampling in reserve as the check on what’s been self declared. The corrigendum issued in the same period and updated in the months after confirms this. The framework was revised after its initial notification and stands as amended.

So here’s the sharper way to put the thesis. The 2026 amendment doesn’t simply liberalise or tighten the BIS certification regime. It reallocates compliance risk. It reduces how often a business has to go through formal renewal and it lowers the entry cost for certain applicants. In exchange it replaces those benefits with recurring annual financial and reporting obligations and particularly under Scheme-II a much greater reliance on the manufacturer’s own conformity controls and on BIS’s post certification surveillance. Whether that trade nets out as relief or as added burden isn’t a question the text answers uniformly. It depends on the specific licensee, the specific scheme and frankly on how disciplined the business’s own compliance calendar turns out to be.

There’s also a sharper legal question buried in the validity change worth stating plainly. Has the amendment genuinely extended regulatory continuity? Or has it simply extended the outer validity period while converting what used to be a periodically renewed authorisation into one that has to be annually maintained just to stay alive? The five year figure is the one that will get quoted. The annual fee is the one that will actually determine whether a licence survives to see it.

Practical Compliance Checklist

Existing licence and CoC holders

• Map every live licence and certificate against its annual fee due date.
• Confirm the production statement timeline that applies under your specific scheme.
• Diarise the five year validity milestone without treating it as licence to relax annual fee discipline in the meantime.
• Check whether any product you hold under Scheme-I could realistically move to Scheme-II going forward.
• Cross check whether any Rule 15(1) notification has touched the Indian Standard your product certifies against.

New applicants

• Decide between Scheme-I and Scheme-II on the merits not by default. Factor in the factory visit requirement, the fee difference and the surveillance exposure under Scheme-II.
• Line up third party test reports early if Scheme-II is the intended route.
• Build the annual fee and testing costs into the budget before the application goes in not after.
• Confirm MSME or start-up eligibility under the MSME Development Act 2006 and the Income-tax Act, 2025 before claiming a concession.

Foreign manufacturers brand owners and importers

• Confirm who’s nominated as the Indian representative on Form-IV and get that documented in the commercial agreement.
• Map the full chain (manufacturer representative brand owner importer) against Customs DGFT and QCO requirements not just BIS certification.
• Build a written responsibility matrix so that an annual fee default or a surveillance failure has a clear owner internally rather than becoming a dispute after the fact.

12. Compliance Timeline

13. Issues to Watch

A few questions this amendment raises but doesn’t fully settle.

• Annual payment against longer validity. As noted above the headline benefit of five year validity is at least partly offset by an annual payment obligation with a hard 90 day suspension trigger. Whether that nets out favourably depends on the licensee’s cash flow profile more than on the regulation itself.
• The corrigendum is binding law. It corrects the validity provisions of the principal amendment and applies with identical legal force. Compliance calendars must be built on the corrected text, not on the original notification alone.
• Self declaration liability. As Scheme-II shifts weight onto the manufacturer’s own conformity undertaking internal documentary controls test report integrity and product change management become more consequential than they were under an assessment based model not less. Scheme-II reduces regulatory friction at the front end. It may well increase the importance of internal compliance controls at the back end.
• Enforcement allocation. How rigorously BIS actually deploys surveillance and sampling under the new Scheme-II will determine in practice whether the self declaration route holds up as a credible certification pathway or becomes a known soft spot.

Key Takeaways

• Licence and certificate validity moves from a two year cycle to up to five years. That’s not the same thing as five years of reduced compliance work.
• Annual fees and annual production statements are now the operative discipline whatever the outer validity period says.
• Non-payment triggers a defined 90 day suspension window cured by a Rs 5,000 late fee. Miss that window and cancellation follows.
• Scheme-II shifts substantially toward self declaration. It cuts the processing fee in half and removes the factory visit for most applicants.
• MSMEs and start-ups get real tiered relief under Scheme-II but only until 31 May 2029.
• Scheme-I keeps its factory assessment and its testing burden largely intact.
• None of this changes obligations under the relevant Quality Control Order Customs or DGFT clearances. Rule 15(1) revisions to individual Indian Standards run on a completely separate calendar that manufacturers still need to track.

Conclusion

The 2026 Amendment Regulations rework the financial and temporal architecture of India’s Standard Mark licensing system without displacing its statutory foundation in Sections 12 and 13 of the Bureau of Indian Standards Act 2016. For a licence holder the task now is to recalibrate the compliance calendar around annual rather than biennial obligations; to weigh whether the revised Scheme-II offers a genuinely more efficient route to the Standard Mark than the traditional factory audit schemes given the surveillance exposure that comes with it; and to keep the separate far more frequent cycle of standard specific amendments under Rule 15(1) on its own tracking sheet distinct from the licensing calendar.

Done well this amendment should reduce the administrative friction of staying certified in India. Done poorly or simply ignored it turns what used to be an occasional renewal exercise into a recurring point of failure and a stricter one than before. The outcome will turn less on the text of the Regulations than on the discipline a business brings to meeting it.

Author: Navya Saxena, Associate

References

1. Bureau of Indian Standards Act, 2016 (Act No. 11 of 2016), https://www.bis.gov.in/wp-content/uploads/2020/12/BIS-Act-2016.pdf
2. Bureau of Indian Standards Rules, 2018, https://www.bis.gov.in/wp-content/uploads/2020/10/BIS-Rules-2018_amendments_Sep_15102020.pdf
3. Bureau of Indian Standards (Conformity Assessment) Regulations, 2018, https://www.bis.gov.in/wp-content/uploads/2019/03/BIS_CA_12032019.pdf
4. Bureau of Indian Standards (Conformity Assessment) Amendment Regulations, 2026, https://www.bis.gov.in/wp-content/uploads/2026/03/Gazette-Notification-1.pdf
5. Corrigendum — Amendment to the Bureau of Indian Standards (Conformity Assessment) Regulations, 2018, https://www.bis.gov.in/wp-content/uploads/2026/05/Gazette-Notification-28.04.26.pdf
6. Bureau of Indian Standards notification dated 21 July 2026, issued under Sub-rule (1) of Rule 15 of the Bureau of Indian Standards Rules, 2018, https://www.bis.gov.in/whats-new-notifications/?lang=en
7. Micro, Small and Medium Enterprises Development Act, 2006, https://www.msmediagra.gov.in/writereaddata/msmedact.pdf
8. Consumer Protection Act, 2019, https://ncdrc.nic.in/bare_acts/CPA2019.pdf
9. Legal Metrology Act, 2009, https://faolex.fao.org/docs/pdf/IND219897.pdf
10. Income Tax Act, 2025, https://www.incometaxindia.gov.in/documents/d/guest/income_tax_act_2025_as_amended_by_fa_act_2026-pdf