Staying Open Under GRAP and CAQM Rules in Delhi NCR

Every winter, businesses in Delhi NCR face the same uncertainty: when air quality worsens, the Graded Response Action Plan kicks in, and construction sites, factories, DG sets, vehicles and brick kilns may be restricted or shut at short notice. GRAP is administered by the Commission for Air Quality Management in National Capital Region and Adjoining Areas, set up under the CAQM Act, 2021, which also issues standing directions that apply all year, on industrial fuels, DG sets, construction dust, and more. Non-compliance leads to closure orders, environmental compensation, and prosecution or penalties under the CAQM Act.

On 28 September 2026, the Commission revised GRAP. The revised schedule has 48 actions across the four stages, with 25 at Stage I, 8 at Stage II, 10 at Stage III and 5 at Stage IV. Actions on DG sets were moved to Stage I, Sonipat was added to the districts where older BS-III petrol and BS-IV diesel light vehicles are restricted at the higher stages, and monitoring of construction sites through the dust portal was extended beyond municipal limits, with the 500 square metre threshold for registration unchanged. This page explains how GRAP works, the CAQM standing directions that matter most, how to plan for the season, and how to respond to closure orders.

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GRAP and CAQM at a glance

How GRAP is triggered

GRAP is not triggered automatically on a single day's reading. A sub-committee of the Commission reviews the air quality and the forecasts from the India Meteorological Department and the Indian Institute of Tropical Meteorology, and issues an order invoking a stage, usually in advance when deterioration is forecast. Actions of the earlier stages continue when a higher stage is invoked, so Stage III includes all Stage I and II actions. When air quality improves, the Commission revokes the higher stage, often keeping the lower stages in force.

Orders are published on the Commission's website and widely reported, and implementing agencies, including state pollution control boards, municipal bodies, development authorities, traffic police and district administrations, are responsible for enforcing them. For a business, the practical point is to follow the Commission's orders day by day during the season, rather than relying on news reports, because the exact list of permitted and prohibited activities is in the order.

Construction under GRAP

Construction and demolition are the most affected activities. At Stage I and II, sites must follow dust control measures: screens, covering of materials, water sprinkling, anti-smog guns on larger sites, covered transport, and registration and self-monitoring on the dust portal for sites of 500 square metres or more. At Stage III, non-essential construction and demolition activities are banned across NCR, with exceptions for specified projects such as those of national importance, railways, metro, airports, hospitals, sanitation and certain linear public projects, subject to dust norms. At Stage IV, the ban widens to cover linear public projects such as highways, roads, flyovers, power lines and pipelines.

Even during a ban, some activities such as plumbing, interior work, electrical work and carpentry that do not create dust may be permitted. Builders should read the order closely. Sites found working in breach face closure, environmental compensation and seizure of equipment. Under the September 2026 revision, the Commission extended dust portal monitoring to sites beyond municipal limits, closing a gap that allowed peri-urban sites to escape scrutiny. See construction dust compliance.

Industry, fuels and closure

For industry, the most important CAQM rules apply all year, not only under GRAP. The Commission has banned coal and other unapproved fuels for industrial, domestic and miscellaneous uses across NCR, subject to limited exceptions, and published a list of approved fuels. Industries in areas with piped natural gas have been required to switch to gas. Units running on unapproved fuels are routinely closed during inspection drives regardless of their consent.

Under GRAP, additional restrictions apply at higher stages, including closure of industries in certain sectors that are not running on approved fuels and restrictions on specified activities such as brick kilns, hot mix plants and stone crushers. Units with valid consent and approved fuels are usually allowed to continue, but must be ready to show compliance quickly when inspection teams arrive. Keep fuel invoices, consent copies, monitoring reports and online monitoring data accessible at the gate.

DG sets after the 2026 revision

Diesel generator sets have long been restricted in NCR under CAQM directions, which require larger gensets to be converted to dual fuel or fitted with approved emission control devices, and limit their use to emergencies and essential services. The September 2026 revision of GRAP moved the DG set actions to Stage I, so these restrictions now apply from the earliest stage of the winter season, not only when air quality turns very poor. Housing societies, malls, offices, hospitals and factories should therefore have compliant backup power arrangements in place before the season begins. See DG set emission norms.

How to prepare for the season

If you receive a closure order

Closure orders during GRAP are often issued on the spot by inspection teams or through directions of the board or the Commission. They usually take effect immediately. The first step is to comply with the order while preparing a response, because continuing in breach makes the position much worse. Then gather evidence: the consent, the fuel records, the dust control measures, photographs taken that day, and portal data. If the closure was based on a mistake, for example treating an exempt activity as prohibited, or a unit on approved fuel as using coal, apply promptly to the authority that issued the order for revocation, with the evidence.

Where the authority does not act, or the order is clearly beyond the direction, legal remedies are available, including before the High Court. In many cases, a prompt, well-documented application leads to revocation within days. Environmental compensation demands that follow closure should be checked against the rates and the period of violation. See closure notice reply.

Time and typical cost

Our fees are agreed in writing at the start, stage by stage. They are not linked to the outcome.

GRAP stages and common business impacts

Documents usually needed

Laws that apply

How we work

We are a litigation and advisory practice led by Advocate BK Singh, with offices in Dwarka (New Delhi) and Vaishali (Ghaziabad). This is what you can expect:

• Pre-season planning: so you know what continues at each stage.
• Standing compliance fixed: fuels, DG sets and dust.
• Fast response to closures: with evidence and revocation applications.
• Compensation demands checked: rates and period.
• Written fee terms: agreed stage by stage, never linked to the outcome.

Mistakes we see under GRAP