GRAP Stages Explained: What Businesses Can and Can't Do

The Commission for Air Quality Management invoked GRAP Stage II across Delhi-NCR on 2 November 2026, after Delhi's 24-hour average AQI reached 324 at 4 pm. At 7 am on 4 November, the city reading was 373, up from 331 the day before. Of 59 reporting stations, all 59 were above 200, 54 were above 300, and 21 were above 400. Punjabi Bagh stood at 452.

Stage III begins at 401. Stage IV begins above 450.

A separate order is also in force, and it is the one that changes work tomorrow. On 30 October 2026, acting under Section 12 of the CAQM Act 2021, the Commission ordered restrictions on dust-generating demolition and outdoor construction activities across the entire NCR, along with up to 50 percent physical office attendance in Delhi and five districts, applying from 5 to 20 November 2026. That order is anticipatory, based on November air quality data from 2018 to 2025, and it is not a GRAP stage invocation.

That is the first thing to understand here. Measures that look like Stage III can arrive without Stage III, through a direction with its own dates and geography, so reading the stage one will not tell you what applies to your site.

The operational question, then, is what a site, a fleet and a shift roster do when either the stage or a direction changes, usually at short notice, and whether anyone can later show what was done. That last part ends up in a BRSR filing, and the indicator numbers are at the end of this article.

The Four Stages And Their Triggers

One rule governs how to read all of it: the stages are cumulative. A Stage III order does not replace Stage I and II obligations; it adds to them, so the Stage dust and fuel conditions are still live during a Stage IV week.

Stage I plus expanded measures took effect across the region on 1 November 2026, including limits on the entry of non-BS-VI vehicles registered outside Delhi and enforcement of the "No PUC, No Fuel" rule. Stage II followed on 2 November.

What The September 2026 Revision Changed

The schedule in force is headed Revision 29.09.2026, approved at the 30th meeting of the Full Commission on 28 September 2026 and announced the following day. It includes 48 actions: 25 in Stage I, 8 in Stage II, 10 in Stage III, and 5 in Stage IV. If your compliance matrix predates it, it is for vehicles put on the road unlawfully.

The essential commodities exemption for older goods vehicles is gone. The exemption that previously covered BS-IV and below goods vehicles carrying essential commodities was removed for light and medium goods vehicles at Stage III and for trucks and heavy goods vehicles at Stage IV. Any continuity plan that assumed an essential-goods consignment could move on an older vehicle needs to be rewritten.

Measures moved down into Stage I. Actions on diesel generator sets and on the entry of BS-IV and below buses from NCR and adjoining states moved to Stage I, and repeated actions on dust control, municipal solid waste management and transport were merged into Stage I as well.

Sonipat was added. The restriction on BS-III petrol and BS-IV diesel and below four-wheeler light motor vehicles now names Sonipat alongside Gurugram, Faridabad, Ghaziabad and Gautam Budh Nagar: a five-district list, not four.

Three smaller changes complete it. A minor relaxation under Stage III Action 1 permits work including repairing potholes; restrictions on diesel BS-IV and below light and medium goods vehicles registered outside Delhi were set out explicitly under Stage III; and each stage's Citizens' Charter gained further do's and don'ts.

Separately, the Commission amended Directions 11 to 18 of 11 June 2021 on dust control at construction and demolition sites, so that web portal monitoring now reaches eligible projects beyond municipal limits, including urban areas, controlled areas and highway corridor zones. The 500 square meter threshold is unchanged, so what widened is where registration is required, not which projects it catches by size.

Construction And Demolition

The restriction starts earlier than most site managers expect, and it starts with paperwork.

At Stage I, construction and demolition work is not permitted on projects with a plot size of 500 square meters or more that are not registered on the relevant state or Delhi government web portal. Registration is therefore a Stage I precondition, not a formality, and a project unregistered when Stage I is invoked is unlikely to fix it quickly.

At Stage II, inspections to enforce dust control measures at C&D sites intensify. Nothing new is prohibited; the probability of being checked rises.

Stage III is where work stops. Strict restrictions apply across NCR to dust-generating activities, including earthwork, piling, demolition, brick and masonry work, and road construction. Exemptions are category-based rather than discretionary and cover railway, metro, airport, hospital, defense, linear public projects, and sanitation work.

At Stage IV, the C&D ban extends to linear public projects as well, including highways, roads, flyovers and pipelines. The exemption that protected those projects at Stage III disappears.

The 30 October order cuts across that sequence. From 5 to 20 November 2026, it restricts dust-generating demolition and outdoor construction across the entire NCR, exempting railways and metro, airports and inter-state bus terminals, hospitals, water supply and sanitation, national security and defense, and projects of national importance. Linear public projects, including highways, flyovers, power transmission, pipelines, and telecommunications, are not exempt. So a linear project permitted at Stage III is restricted in that window anyway.

Since the exemptions are defined by project type, and interior work and fit-out are not listed as dust-generating activities, you should have written justification for continuing any work before an inspector asks.

Diesel Fleets And Goods Vehicles

Vehicle restrictions tighten in a specific order, and they distinguish between where a vehicle is registered, its BS emission standard, and what it carries.

Stage I requires strict enforcement of national Green Tribunal and Supreme Court orders on over-aged diesel and petrol vehicles. From 1 November 2026, the region will limit entry of non-BS-VI vehicles registered outside Delhi, with specified exemptions.

Stage II restricts inter-state buses from NCR states from entering Delhi unless they run on electric, CNG, or BS-VI diesel.

Stage III brings three distinct measures. Strict restrictions on BS-III petrol and BS-IV diesel and below four-wheeler light motor vehicles in Delhi and the high-vehicle-density districts of Gurugram, Faridabad, Sonipat, Ghaziabad and Gautam Budha Nagar, with a narrow provision allowing persons with disabilities to ply such vehicles where the vehicle is specifically adapted and used only personally. It bans diesel BS-IV and below medium goods vehicles registered outside Delhi from entering Delhi, with equivalent restrictions on light goods vehicles registered outside Delhi and on Delhi-registered medium goods vehicles.

Stage IV stops the entry of trucks, meaning heavy goods vehicles, into Delhi. The only exemption stated is for LNG, CNG, electric and BS-VI diesel trucks, which are permitted to enter.

Note what is absent from both. The schedule states no exemption for essential commodities at either stage because that exemption was removed in the September 2026 revision. Fuel type and emission standard now decide the question, not cargo.

So exposure depends on fleet composition rather than route planning or cargo classification. Know in advance, by registration number, how many of your own and contracted vehicles are BS-IV or below and how many are registered outside Delhi. A fleet list with a BS standard column and a registration state column is the most useful document to have ready.

Diesel Generator Sets

DG sets are a Stage I matter, earlier than most operators assume and earlier than they used to be. The September 2026 revision moved the DG set actions down into Stage I, where they now sit as Action 18, requiring regulated operation of generator sets across all sectors in NCR in line with the Commission's Direction No. 76.

The regulation works by capacity band, written in kilowatts with the kVA equivalent alongside. That Direction regulates three bands: 800 kW (1000 kVA) and above; 41 kW (51 kVA) to under 800 kW; and 19 kW (23 kVA) to under 41 kW. Below that, portable sets under 19 kW (23 kVA) are generally not permitted at all, and are allowed only for prescribed emergency services.

Because this is Stage I, the restriction is live from the Poor category onwards, which in Delhi means most of the winter rather than its worst weeks.

Two things decide your position. Every set's nameplate rating in both kW and kVA, because the bands are written in kW and most procurement records are in kVA. And which loads you would defend as an emergency service, a narrower category than business continuity.

Staff Health And Working Arrangements

The working arrangements are the clearest stage-linked obligation and the health measures the least prescribed, which is the opposite of how most organizations prepare.

Staggered office timings apply at Stage II. At Stage III, offices may be allowed to run at 50 percent strength, with the rest working from home, at state or Delhi government discretion. Schools move to hybrid mode up to Class V at Stage III and extend to Classes VI to IX and XI at Stage IV, which matters to an employer because caring responsibilities shift across the workforce in the same week the office may halve.

For the current window, that discretion has already been exercised. Under the 30 October order, state government and private offices may operate with up to 50 percent of staff attending physically from 5 to 20 November 2026, across Delhi and the same five districts, excluding industrial establishments and essential services where the arrangement is not feasible. The carve-out determines whether the measure reaches your site.

Outdoor and semi-outdoor workers are the group GRAP does not protect directly. Security staff, drivers, loaders, housekeeping, and construction labor are exposed for full shifts at concentrations that trigger advisories for the general population. Among the measures reported in force this season is a request to residential welfare associations to provide electric heaters to security staff, which indicates the kind of measure expected and leaves the employer to design the rest.

A defensible package: shift rotation limiting continuous outdoor exposure in peak hours, respiratory protection rated for particulate matter rather than generic masks, indoor rest areas with filtration, and a recorded route for anyone reporting symptoms. Record the dates these were in place. The stage dates are public, so what you did on them is an answerable question.

Recording It In BRSR

Three places in the SEBI format, with exact indicator references.

Principle 6, Essential Indicator 6 asks for details of air emissions other than greenhouse gas emissions, in a prescribed format covering NOx, SO  and particulate matter, and whether an external agency carried out any independent assessment, evaluation, or assurance. GRAP moves what sits behind this: DG run hours change your diesel combustion figures, and a construction stoppage changes a site's profile for part of the year. If the number moved because of GRAP, say so, rather than leaving a reader to infer an efficiency gain that did not happen.

Principle 6, Essential Indicator 13 asks whether the entity complies with applicable environmental laws, regulations, and guidelines in India, and if not, requires details of all such non-compliance, including fines or penalties and the corrective action taken. An enforcement action, a shutdown notice, or an environmental compensation levy belongs here, and so does the corrective action, which is the part most filings treat thinly.

Principle 3 carries the workforce side: Essential Indicator 1 on measures for the well-being of employees and, separately, of workers, with 1(c) on spending; Indicator 10 on whether an occupational health and safety management system has been implemented; and Indicator 12 on the measures taken to ensure a safe and healthy workplace.

That split between employees and workers in Indicator 1 is the one to watch. The people most exposed in a Severe week are usually in the workers column, often contracted, and filing reports on air quality measures only for employees describes the wrong population.

What To Prepare Before The Stage Changes

Five documents, none of which can be produced at short notice: portal registration status for every site of 500 square meters or more; the fleet list with registration state and BS standard per vehicle, contracted vehicles included; the DG inventory with kW and kVA ratings, dual-fuel or retrofit status and a run-hour log with reasons; a staffing plan naming who decides and by when; and a dated record of the worker health measures actually in place.

Then one thing that costs an hour. Write down the dates each stage invoked and revoked this season, and the dates of every separate Direction, from the orders themselves rather than news coverage. The two run on different clocks, and the Direction is often what stopped your work. When the BRSR question arrives next year, that timeline is the spine of the answer, and nobody reconstructs it accurately in April.

Position as of 4 November 2026. GRAP stage measures are summarised from the Commission for Air Quality Management's published GRAP schedule headed Revision 29.09.2026, approved at the 30th meeting of the Full Commission on 28 September 2026, and from the Press Information Bureau release announcing those modifications; an earlier revision of 21 November 2025 is superseded, and commentary based on it remains in circulation. GRAP is amended from time to time,e and the operative text is the current CAQM schedule together with the specific invoking order or Direction, which can vary what applies, where and to whom. Measures imposed by Direction under Section 12 of the CAQM Act 2021, including the order of 30 October 2026 applying from 5 to 20 November 2026, operate independently of stage invocation and have their own dates, geography and exemptions. Air quality figures are as reported on 4 November 2026 and change hourly; stage invocation and revocation are decisions of the CAQM sub-committee and cannot be predicted from an AQI reading alone. Restrictions, exemptions and the districts covered differ between Delhi and other NCR areas and between stages, and several measures are expressed as state or central government discretion rather than automatic prohibitions, so whether a given activity is permitted at a given site is a question for the current order and the relevant authority. BRSR indicator numbers are from the SEBI reporting format as published; confirm against the version applicable to your reporting year. Nothing here is legal, regulatory, engineering,o r occupational health advice, and site-specific compliance and worker protection decisions should be made with qualified advisers.

Sources

Commission for Air Quality Management, Press Information Bureau, Commission for Air Quality Management, SCC Online, Business Standard, Securities and Exchange Board of India

This article is intended for general professional information and does not constitute legal, financial, or investment advice.