Is CCTV Needed for Factory Licence Renewal? State by State
Do you need CCTV to renew a factory licence in India? No. As of 15 Oct 2026, none of the eight state and central licence forms and checklists we read asks about cameras. CCTV reaches a licence by two other routes. One is the conditions for women working at night. The other is Karnataka's public-safety rules for large establishments.
Last checked: 15 Oct 2026
By the Mama Editorial Team. Not legal advice.
Verified against
- OSH Code, 2020, ss.119 and 143 (Gazette of India, 29 Sep 2020). OSH (Central) Rules, 2026, G.S.R. 345(E) of 8 May 2026: r.3 and Form-I, r.58, r.83 (Gazette of India).
- Gujarat OSH Rules, 2025, No. GR/2025/76/FAC/142021/68396/M3, Gujarat Gazette Extraordinary, 12 Jun 2025: rr.45, 75–77 and Form 33. Read on a third-party copy of the Gazette.
- Uttar Pradesh OSH Rules, 2026, No. 962/XXXVI-03–2026-1903305, 27 Aug 2026, English translation in the UP Gazette Extraordinary: rr.76, 115–117 and Form-45. Read on a third-party copy of the Gazette.
- Maharashtra Factories (Second Amendment) Rules, 2025, No. FAC 2025/CR No. 117 (Part-1)/Labour-4, Maharashtra Gazette Extraordinary, 3 Oct 2025: new Form 1, rr.8 and 102-B. Read on a third-party copy of the Gazette.
- Draft state OSH Rules: Maharashtra, Gazette Extraordinary, 30 Apr 2026, Form-XIV (copy); Haryana, Memo No. 2/27/2026-2Lab of 4 May 2026, Form-29 (copy); Karnataka, No. LD 245 LET 2021 of 23 Jan 2026, r.91 and Form I-B (copy); Telangana, preliminary notification for the Telangana Gazette of 31 Jan 2026, which replaces the 2022 draft, r.107 and r.68 (copy); Tamil Nadu, TN Gazette, 11 Apr 2022 (copy).
- Tamil Nadu DISH: the inspection checklist under the Factories Act and TN Factories Rules (179 questions); G.O.(MS) No. 145 of 31 Aug 2017 (preliminary notification proposing online Form No. 2); SRO A-29/2019 (renewal for up to 15 years).
- Karnataka Public Safety (Measures) Enforcement Rules, 2018, No. HD 426 SST 2017 of 28 Jun 2018: rr.2, 4, 5 and 10. Read on a copy hosted by an industries association.
- Checked 15 Oct 2026. Five state labour portals did not respond, so those texts were read in the copies linked.
State by state: does the renewal form ask for CCTV?
| Jurisdiction | Instrument and status (15 Oct 2026) | Renewal form | CCTV asked on the form? | Where CCTV does appear in the same text |
|---|---|---|---|---|
| Central (central-sphere units only) | OSH (Central) Rules, 2026, final | Form-I registration on Shram Suvidha; the licence forms in these Rules are for contractors | No | r.83(d): on the way to facilities, for women before 6 a.m. or after 7 p.m.; r.58: "Closed Circuit Television monitoring" of the crèche |
| Gujarat | Gujarat OSH Rules, 2025, final | Form 33, "Application for New/Renewal of license", 10 items (r.77) | No | Not in these Rules (r.45 has no CCTV clause); Gujarat's 2025 Factories ordinance named night-shift CCTV |
| Uttar Pradesh | UP OSH Rules, 2026, final, in force on publication | Form-45, 17 items, plus a Form-43 stability certificate (r.117(2)) | No (item 17 asks for the fire NOC's validity) | r.76(e): on the way to facilities, for women at night |
| Maharashtra | Maharashtra Factories Rules, 1963, as amended 3 Oct 2025; OSH Rules at draft stage | Form 1, filed electronically, also used for renewal (r.8) | No | r.102-B(f): "CCTV surveillance with recording facilities for at least forty-five days" for women at night |
| Maharashtra (draft) | Draft OSH Rules, 30 Apr 2026 | Form-XIV, Part B (factory) | No | Draft r.24(b): on the way to facilities |
| Haryana (draft) | Draft OSH Rules, 2026, memo of 4 May 2026 | Form-29 (r.83(2)) | No | Not in the draft (r.50 defers to State notification); Haryana's 2025 factory notification names CCTV |
| Karnataka (draft) | Draft OSH (Karnataka) Rules, 2026 | Form I-B; online auto-renewal on paying fees, up to fifteen years (draft r.91) | No | Not in the draft; via the 2023 night-shift amendment (45 days) and the 2018 Public Safety Rules (next section) |
| Tamil Nadu | TN Factories Rules, 1950 (renewal in Form No. 2, r.7); OSH Rules at 2022 draft stage | DISH inspection checklist, 179 questions | No | Nowhere in the checklist or in the 2022 draft |
| Telangana (draft) | Draft OSH (Telangana) Rules, 2026, Gazette date 31 Jan 2026 | Form-XXII online (draft r.107); licence valid while the annual fee is paid, 1 to 10 years at a time | No | Draft r.68(e): on the way to facilities, for women at night |
Each "No" is a checked negative: "CCTV" is absent from the form or checklist named (checked 15 Oct 2026). In the five states without final OSH rules, the older factory rules continue during the transition "to the extent they are not contrary to" the Code (OSH Code s.143(3)).
Where cameras do reach your licence
Route 1: women working at night. Five of the texts above tie CCTV to women working before 6 a.m. or after 7 p.m., not to the licence. These are the Central r.83, UP r.76, Maharashtra r.102-B, and the Maharashtra and Telangana (2026) drafts. UP r.76(g) gives the Inspector-cum-Facilitator at least seven days to verify the arrangements. Among these texts, only Maharashtra sets a retention period: 45 days. Gujarat, Haryana and Karnataka set their night-shift camera conditions in separate instruments (Karnataka also 45 days); see the state-by-state night-shift tracker.
Route 2: Karnataka's Public Safety Rules. The 2018 Rules count a Factories Act licence as a "License" (r.2(1)(g)). Rule 10(2) says the Licensing Authority "shall, at the time of renewal of license, ensure that the establishment is implementing the public safety measures". Those measures include CCTV at entry and exit points and parking up to fifty yards, running 24x7, with 30 days' storage (r.4). Rule 5(2) asks for "renewal of license" to be enclosed with Form No. 16. This applies only to establishments that the Supervisory Committee has identified (r.9(1)). Thresholds and the similar Andhra Pradesh and Telangana Acts are on the public safety Acts page.
Not a route: the central crèche rule. Central r.58(xxvi) binds only central-sphere establishments; for a private factory the State is the "appropriate Government" (OSH Code s.2(1)(d)(ii)).
What the OSH Code changed at renewal
- Your old licence runs out, then you apply afresh. Under s.119(5), a factory licence issued under a repealed law is valid "for the period for which it was issued" and "shall have to be obtained afresh after its expiration".
- 45 days to decide. Otherwise the licence is deemed issued (s.119(4)).
- Renewals can now run for ten years or more. Gujarat r.77 allows ten consecutive years at up to ten times the annual fee, though its Form 33 still says "not exceeding two years". UP r.117 and Maharashtra's 2025 Form 1: up to ten years. Tamil Nadu (SRO A-29/2019) and the Karnataka draft (r.91): up to fifteen.
- The papers that matter at renewal are not cameras. UP asks for a stability certificate with each renewal. Its form also asks for the fire NOC's validity and whether annual returns were filed. Fire rules by state are on the Fire NOC page.
Worked example: a UP renewal in ₹
Assume a UP plant with 400 workers and 300 kW installed. The fee row is "101 to 500" kW and the column is "301 to 500" workers (UP r.116(2), checked 15 Oct 2026).
| Item | Basis | Amount (₹) |
|---|---|---|
| Licence fee, one year | r.116(2) table | 10,000 |
| Renewal for 10 years | years × one-year fee (r.117(3)) | 1,00,000 |
| Late fee, if filed less than 30 days before expiry | 25% extra (r.117(4)) | 25,000 |
| CCTV line item on Form-45 | none in the form | 0 |
What breaks in a factory
- The inspector sees cameras anyway. Cameras on the routes to facilities are a condition of women's night work; a gap is a night-shift finding, not a renewal one.
- Recorders overwrite. Maharashtra's 45 days outlasts many recorders. Size the disks with the storage calculator.
- Placement. Cover corridors to washrooms and changing rooms, never the inside. Footage of workers is personal data, so post a DPDP worker notice.
What to ask the licensing office
- Has the State notified final OSH rules? If so, which form replaces the old licence form, and what is the renewal window?
- In Karnataka: has the Supervisory Committee identified your plant under the Public Safety Act? If yes, the renewal will need the public-safety return and Form No. 16.
- National picture: the OSH Code explainer.
Where Mama fits
Mama reads a factory's existing cameras over RTSP/ONVIF and tells the owner each morning, in plain language, where machine hours were lost yesterday. People are counted only in aggregate. To check whether your cameras can do this, leave an email or phone in the form below.
FAQ
Is CCTV mandatory for a factory licence in India?
No. The licence and renewal forms we read for Gujarat, UP, Maharashtra, Haryana, Karnataka, Tamil Nadu, Telangana and the Centre do not ask for it (checked 15 Oct 2026). CCTV becomes a condition when women work at night. It also applies to establishments identified under a state public safety Act, such as Karnataka's.
What documents are needed for factory licence renewal?
It depends on the state. UP: Form-45 online, 30 days before expiry, with a Form-43 stability certificate and the fee (r.117(2)). Gujarat: Form 33, 60 days before expiry (r.77). Maharashtra: Form 1, electronically.
Do I need a new factory licence under the OSH Code?
Not immediately. A licence issued under the Factories Act stays valid until it expires. After that it must be obtained afresh under the Code (s.119(5)), in the form your State prescribes.