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Environmental Law Guide

GRAP Stages Explained: What Changes at Each Stage

What GRAP Stage I, II, III and IV mean for construction, factories, DG sets and vehicles in Delhi NCR, what changed on 28 September 2026, and how to plan.

Written by the environmental law practice of Advocate BK Singh, which acts before the pollution boards, environment authorities and the National Green Tribunal.

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Last reviewed: October 2026

Every winter in Delhi NCR, news reports announce that "GRAP Stage III" or "Stage IV" has been invoked, and businesses scramble to understand what they can and cannot do. GRAP, the Graded Response Action Plan, is a schedule of actions that the Commission for Air Quality Management triggers as air quality worsens. It sorts measures into four stages linked to the Air Quality Index, and when a higher stage is invoked, the actions of the lower stages continue.

On 28 September 2026, the Commission revised GRAP. The revised schedule has 48 actions: 25 at Stage I, 8 at Stage II, 10 at Stage III and 5 at Stage IV. Actions on diesel generator sets moved to Stage I, Sonipat was added to the districts where older BS-III petrol and BS-IV diesel light vehicles are restricted at higher stages, and monitoring of construction sites through the dust portal was extended beyond municipal limits. This guide explains each stage in plain words and what it means for construction, industry, buildings and vehicles. For compliance planning, see NCR, GRAP and CAQM compliance.

StagesI (AQI 201-300), II (301-400), III (401-450), IV (above 450)
Actions48 in total after the 2026 revision (25, 8, 10, 5)
ChangesDG set actions moved to Stage I
Who decidesCommission for Air Quality Management

हिंदी में सारांश

GRAP (ग्रेडेड रिस्पॉन्स एक्शन प्लान) दिल्ली NCR में वायु गुणवत्ता बिगड़ने पर CAQM द्वारा लागू किए जाने वाले कदमों की सूची है, चार चरणों में: स्टेज I (AQI 201-300), स्टेज II (301-400), स्टेज III (401-450) और स्टेज IV (450 से ऊपर)। 28 सितंबर 2026 के संशोधन में कुल 48 कार्रवाइयाँ हैं; DG सेट की पाबंदियाँ अब स्टेज I से शुरू होती हैं, सोनीपत को पुराने वाहनों की पाबंदी में जोड़ा गया है, और नगर सीमा के बाहर के निर्माण स्थलों की भी डस्ट पोर्टल निगरानी होगी।

In short

The four stages

Stage I: Poor

AQI 201 to 300. Baseline measures on dust, waste burning, DG sets and vehicles.

Stage II: Very Poor

AQI 301 to 400. Tighter dust and DG set measures, parking and traffic steps.

Stage III: Severe

AQI 401 to 450. Non-essential construction and demolition banned; older vehicles curbed.

Stage IV: Severe Plus

AQI above 450. Truck entry curbs, wider construction ban, emergency steps.

Cumulative

Each stage includes the actions of the stages below it.

2026 changes

48 actions; DG sets from Stage I; Sonipat added; dust monitoring beyond city limits.

The baseline

Stage I: Poor air

Stage I is invoked when the AQI is forecast to be in the poor range, 201 to 300. It includes baseline measures that apply across NCR: enforcement of dust control at construction and demolition sites and registration of sites of 500 square metres or more on the dust portal, a ban on open burning of waste, enforcement of pollution under control rules for vehicles, mechanised sweeping and water sprinkling on roads, and checks on industrial fuel use. Under the 2026 revision, actions on DG sets, which earlier began at Stage II, now begin at Stage I. Buildings and factories relying on diesel gensets must therefore comply with the CAQM directions on gensets from the start of the season. See DG set rules in Delhi NCR.

Tightening

Stage II: Very poor air

Stage II applies when the AQI is forecast in the very poor range, 301 to 400. It adds stricter enforcement of dust control, more intensive road cleaning, higher parking fees to discourage private vehicles, more public transport, and targeted action at pollution hotspots. Industries not running on approved fuels face strict action, and authorities step up inspection of construction sites. For most businesses, Stage II means more inspections rather than outright bans, but sites and units that are not compliant are more likely to be closed.

Bans begin

Stage III: Severe air

Stage III is invoked when the AQI is forecast in the severe range, 401 to 450. The key measure is a ban on non-essential construction and demolition activities across NCR, with exceptions for specified categories such as projects of national importance, railways, metro, airports, hospitals, sanitation and some public linear projects, subject to dust norms. Non-dust-generating works such as interior finishing, plumbing and electrical work are often permitted. BS-III petrol and BS-IV diesel light motor vehicles are restricted in Delhi and specified NCR districts, which under the 2026 revision now include Sonipat. Brick kilns, hot mix plants and stone crushers face restrictions, and state governments may decide on online classes and work from home.

Emergency measures

Stage IV: Severe plus

Stage IV applies when the AQI is forecast above 450. It adds a ban on the entry of trucks into Delhi except those carrying essential goods or running on CNG, electricity or BS-VI diesel, a wider construction ban that extends to linear public projects such as highways, roads, flyovers, power lines and pipelines, restrictions on diesel medium and heavy goods vehicles registered in NCR, and decisions by governments on closing schools for physical classes and allowing staff to work from home. Industries not on approved fuels in sectors such as those without clean fuel options may be shut. Stage IV is meant to be rare and short.

Step by step

How to plan for GRAP

1

Map your exposure

Sites, gensets, boilers, fleets and kilns in NCR.

2

Comply with standing rules

Approved fuels, genset upgrades, dust portal registration.

3

Plan by stage

What continues, what stops and what needs permission at each stage.

4

Watch the Commission's orders

Read the actual order, not just the news.

5

Keep documents at hand

Consent, fuel invoices, genset certificates and portal records.

6

Respond fast to closures

Comply, gather evidence and apply for revocation.

Quick reference

Common impacts by stage

ActivityStage IStage IIStage IIIStage IV
Construction and demolitionDust norms enforcedStricter checksNon-essential work bannedWider ban incl. linear public projects
DG setsCAQM restrictions applyStricter enforcementContinuesContinues
Industry on unapproved fuelActionStrict actionStrict actionPossible shutdown of sectors
Older BS-III petrol and BS-IV diesel LMVsNormal rulesNormal rulesRestricted in Delhi and specified districts incl. SonipatRestricted
Trucks into DelhiNormal rulesNormal rulesNormal rulesEntry curbed except essential and clean fuels
A practical tip

Reading the order, not the headline

News reports often simplify GRAP orders, and businesses have closed or continued work wrongly as a result. Each stage is invoked by an order of the Commission's sub-committee, published on its website, and the schedule lists the exact actions and exceptions. Implementing agencies may issue their own orders. Before stopping or continuing an activity, read the Commission's order and the schedule. Where an activity is not clearly covered, take advice, and if you continue, keep evidence that your activity is permitted and dust-free.

Illustration

A site that read the order

Here's a made-up example. When Stage III was invoked, a Noida builder stopped all work on a nearly finished tower after reading news reports.

On reading the schedule, we advised that interior finishing, electrical and plumbing works that did not generate dust were permitted, while external plastering and cutting had to stop. The builder resumed permitted work with dust measures and records, and avoided a three-week delay.

Many agencies

Who enforces GRAP

GRAP is issued by the Commission for Air Quality Management, but enforcement is carried out by many agencies: the pollution control boards of Delhi, Haryana, Uttar Pradesh and Rajasthan, municipal corporations, development authorities, district administrations, traffic police and transport departments. The Commission's own flying squads also inspect. Each agency may issue its own orders to implement GRAP within its area. For a business, this means notices or closures may come from different bodies, and revocation applications must go to the body that issued the order. Keep a list of the agencies relevant to each of your sites.

GRAP is not the only rule

Standing directions all year

GRAP adds measures in winter, but CAQM's standing directions apply throughout the year: the ban on coal and unapproved fuels for industry in NCR, the requirements for DG sets, dust control at construction sites and registration on the dust portal for sites of 500 square metres or more, and the ban on open burning of waste. A unit or site that complies with these standing rules is far less exposed when GRAP stages are invoked, because most closures under GRAP are for breaches of these basic rules. Treat GRAP preparation as part of year-round compliance. See CAQM.

Planning grid

Preparing your business for each stage

StageConstruction siteFactoryBuilding with gensets
Stage IDust measures, portal registrationApproved fuel, controls runningCompliant gensets, logbook
Stage IIStricter dust checks expectedExpect inspectionsLimit genset use to permitted purposes
Stage IIIStop non-essential dust-generating workCheck sector restrictionsContinue compliance
Stage IVWider ban; check if your project is coveredPossible sector shutdownsContinue compliance
Quick checks

At the start of the season

  • Is every NCR site of 500 sq m or more registered on the dust portal?
  • Are all boilers and furnaces on approved fuel?
  • Are gensets converted or retrofitted as required?
  • Do you know which works can continue during Stage III?
  • Has someone been assigned to read each Commission order?
  • Do you know which agency to approach for revocation at each site?
FAQs

Frequently Asked Questions

What is GRAP?

A schedule of actions in four stages linked to the AQI, administered by CAQM for Delhi NCR.

What are the AQI ranges for each stage?

Stage I 201-300, Stage II 301-400, Stage III 401-450, Stage IV above 450.

What changed in September 2026?

48 actions in total, DG set actions moved to Stage I, Sonipat added to vehicle curbs, and wider dust monitoring.

Is construction banned at Stage III?

Non-essential construction and demolition are banned, with exceptions.

Can interior work continue during a ban?

Often yes, if it does not generate dust; check the order.

Do GRAP rules apply outside Delhi?

Yes, across NCR districts.

When do DG set restrictions start?

From Stage I after the 2026 revision.

Which vehicles are restricted?

BS-III petrol and BS-IV diesel light vehicles at higher stages in specified areas.

Who decides when a stage starts?

The Commission's sub-committee, based on forecasts.

What if my site is closed wrongly?

Comply, gather evidence and apply for revocation.

Planning for GRAP?

Send us your sites and operations. We will map what each stage means for you.

This page gives general information about environmental law as it stood when it was last reviewed. It is not legal advice on your case and does not promise any result. Environmental rules, EPR targets, GRAP measures and board procedures change often, so check the current position for your unit or project before acting.

Have a question about your own case?

A guide can only go so far. Send us the notice, the order or a few photos, and we'll tell you where you stand, which authority or NGT bench deals with it and when the next step is due, in plain words.

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