Permits in Practice: Evidence from Six Small‑Business Members in India

Submission details

Symbol: RC/RT/2026/S.2

Kind: Submission

Author: The Secretariat

Submitting group: India Permit Evidence Group, comprising six consenting Red Tape Council members in India. Members remain anonymous and are not identified by their businesses.

Subject: Member evidence relevant to RT-001, the proposed Small Business Impact Standard.

1. Purpose and limits of the submission

1. This submission places member-reported permit experiences before the Red Tape Council and the Founders Assembly. It focuses on how application processes affect small businesses in practice: the number of steps, repeated document requests, uncertainty about timing, and the cost of waiting. It is not a legal opinion about any particular permit, nor a finding about the conduct of a named authority.

2. The six members consented to publication of their accounts in anonymized form. The Secretariat has removed personal and business identifiers. References below to a municipal office, licensing desk, or inspection unit describe the members’ accounts; they do not identify a specific public body. The submission does not allege misconduct by any named official or organization.

3. The evidence is qualitative and limited. Members described their own applications and shared records they held, including application acknowledgments, payment receipts, portal status screens, inspection notices, and follow-up correspondence. The Secretariat has not independently authenticated those records or contacted the offices concerned. Figures below are member-reported amounts and time periods, not audited estimates.

4. For comparability, rupee amounts are shown with indicative US-dollar equivalents using a fixed reporting convention of ₹83 to US$1. This convention is for this submission only; it is not a statement of the exchange rate on the date of any application or payment.

2. Evidence submitted by members

5. The group describes four application episodes. The accounts are presented as separate experiences, not as a statistically representative sample of India or of all permit applicants. The dates and amounts are those provided by the members. Where a member could not identify a precise date from a saved record, the sequence is described without treating an estimated date as exact.

6. Account A concerns a small food-production operation. The member reported submitting an application and supporting documents through an online service and saving the confirmation and fee receipt. A later request sought a document that the member believed had been uploaded with the application. The member resubmitted it and retained a screenshot of the new upload. The account does not establish whether the first upload failed, was inaccessible to the reviewing office, or was not accepted for another reason. The member’s concern was that the system did not make the status or the reason for the repeated request clear.

7. Account B concerns a small repair service. The member reported delivering a paper form and receiving a stamped acknowledgment. Follow-up required several visits because the member did not know whether the file was awaiting review, inspection, or another document. The member estimated that each visit took a substantial part of a working day, including travel and waiting. The Secretariat’s records contain no written service-time estimate.

8. Account C concerns a small retail operation. The member began on a digital portal and then received an instruction to provide a physical copy. The member described finding different document lists at different points in the process. The Secretariat’s records include the member’s copies of those lists, but do not establish which version was official or whether either was complete. The member paused rather than continue incurring costs without clarity about what would satisfy the application requirements.

9. Account D concerns a small workshop. The member reported that an inspection took place, but the subsequent status did not state a target date for a decision. The member’s estimate of ₹31,000 includes both direct costs and an estimate of time diverted from paid work. That estimate is therefore less readily comparable with the direct fees and expenses in the other accounts. It is included to show the member’s reported exposure, not as a verified economic loss.

10. Across the four accounts, members described uncertainty as a cost in its own right. It affected decisions about opening, scheduling staff, purchasing materials, accepting work, or making further trips to an office. The evidence before the Council is insufficient to calculate lost revenue, establish that an opening date was missed, or isolate the effect of a permit delay from other business conditions. This submission does not assign a monetary value to those wider effects.

11. The group’s records also illustrate a practical distinction between a delay and an unexplained delay. An applicant may accept that a review, correction, or inspection takes time. The difficulty described

here was being unable to identify the current stage, what action remained, who needed to act, or when the applicant should expect an update. Members considered a receipt or a portal entry insufficient when it did not answer those questions.

3. Relationship to the wider Red Tape Council evidence

12. As of 4 May 2026, the Red Tape Council had 40 members from 21 countries and 58 reports from 22 countries. The median amount at stake across the Council’s reported evidence was approximately US$6,380. India accounted for eight reports. These figures describe the Council’s evidence at that date; they are not national estimates and do not mean that all reports concern the same type of permit.

13. This group’s four process accounts form part of its member evidence and should not be added to the Council’s totals as new reports. The Secretariat records the group’s participation as six consenting members. The Council’s records do not permit a reliable calculation of how many of its 58 reports concern delays, repeated requests, or unclear service times.

14. The World Bank’s B-READY 2025 report covers 101 economies and reports an average of about 60 per cent “business ready”; its public-services scores are about 23 per cent below its regulatory-framework scores.¹ That cross-economy finding is relevant context for examining the gap between written requirements and the services through which businesses must comply. It is not evidence about the particular offices, applications, or experiences described in this submission.

4. Analysis against the five-part pattern test

15. The Council’s five-part test asks whether the issue is supported by Volume, Frequency, Consistency, Spread, and Corroboration. The test is applied to patterns, not to the character or performance of an individual office. The accounts below contribute evidence for review;

they do not establish that every permit process has the same problem. The Council’s overall RT-001 status remains three of five tests as of 4 May 2026.

1. Volume. The four accounts submitted here are small in number. They sit within a Council record of 58 reports from 22 countries, but the overall count does not establish how many reports concern the particular mechanisms described here. The account set is sufficient to identify questions for consultation, not to estimate prevalence. A stronger volume assessment would require consistently coded reports specifying permit type, stage, elapsed time, and whether a published service target existed.

2. Frequency. Members described more than one follow-up action in several accounts, including repeat document provision, visits, or requests for status information. The evidence does not establish a common rate of such events across applicants. Repeated activity within a single application is evidence of burden for that member; it is not by itself proof of a widespread recurring pattern. Future reporting should record the number and purpose of each repeat request and whether the requested information had already been supplied.

3. Consistency. There is a common feature in the accounts: applicants had difficulty determining the next step or expected completion time. The underlying processes differ, however. Some began online, one began on paper, and the described points of uncertainty include document handling, inspection scheduling, and post-inspection updates. The evidence therefore supports a shared question about process visibility, but not a conclusion that all cases arose from one cause or that a single remedy will address each cause.

4. Spread. All six members in this submission are in India, and the Council’s India figure is eight reports. This provides country-specific member evidence, but does not demonstrate geographic spread within India. The submission does not identify states, cities, permit categories, or authorities in a way that would support a regional comparison. The wider Council has reports from 22 countries, but the Council’s aggregate records do not show whether the same process problems recur across those countries.

5. Corroboration. Members described records including acknowledgments, receipts, portal screens, checklists, notices, and follow-up messages. Those records provide potential corroboration of parts of the sequence, but the Secretariat has not independently authenticated them. The accounts also lack a response from the relevant public bodies, a complete record of each application file, and a common measure of elapsed time. The evidence is therefore partially document-supported and not independently verified.

16. Taken together, these accounts justify asking whether applicants can obtain a clear, accessible record of requirements, status, responsible next steps, and expected timing. They do not justify a claim that every permit is delayed, that every repeated request is unnecessary, or that any particular office has breached a legal duty.

5. Local-law scope

17. The member accounts do not identify the precise permits, local jurisdictions, or statutory provisions governing each application. The Secretariat’s records for this submission contain no India-specific statute, regulation, municipal rule, or permit condition. The Secretariat therefore does not state what legal deadline, deemed approval rule, appeal route, or document requirement applies to any of these applications.

18. This limitation matters for the proposed “silence is consent” approach. The member evidence illustrates the cost of not knowing when a decision will be made, but it does not establish that consent by silence is legally available or suitable for every category of permit. Any future proposal to use such a deadline would need to identify the relevant legal authority, define excluded categories where public safety or other legal obligations require review, and specify how an applicant is notified of a pause or request for information. This submission makes no claim that an existing Indian law already provides for such a rule.

6. Recommendations for the draft

19. The India Permit Evidence Group recommends that the RT-001 draft turn the member experience into clear, measurable service expectations. The recommendations below are directed to a general standard for public processes affecting small businesses. They do not prescribe the content of any particular permit or override applicable law.

1. Require a small-business impact test for new or materially changed rules. The test should identify likely effects on very small firms, including application fees, document-preparation burdens, travel, staff time, and the consequences of waiting. It should explain which groups may face disproportionate effects and what evidence informed the assessment. Where reliable figures are unavailable, the assessment should state that limitation rather than imply precision.

2. Make the process and requirements findable in one place. Applicants should be able to locate the current checklist, fee, submission method, responsible office, stages, and contact route without reconciling conflicting versions. If a paper step remains necessary, the digital instructions should say so before an applicant begins and explain how the paper record links to the application.

3. Provide an acknowledgment that functions as a usable receipt. Acknowledgments should identify the application, date received, fee paid if applicable, the next expected stage, and a means to check status. Where an application is incomplete, the notice should identify the missing item and explain how to submit it. A system should distinguish a new requirement from a request to resend material already supplied.

4. Publish service times and report performance against them. Each process should state an expected time for initial completeness review and for the decision or next action. If the time is suspended because the applicant must respond or an inspection is required, the applicant should receive the reason, the action required, and a revised expected date. Published times should be accompanied by periodic performance information, including the share completed within the stated period.

5. Adopt a one-stop digital route where practicable, with accessible alternatives. A single route should permit submission, payment where applicable, status checks, document exchange, and receipt of notices. Digital delivery should not be treated as a solution if applicants must still make unannounced visits or repeat submissions. Where digital access is not suitable or available, a clearly described alternative should preserve acknowledgment and tracking.

6. Define any silence deadline carefully. A default rule should specify when the clock starts, what events pause it, what notice must be given, and what remedy follows if the authority does not act. The rule should operate only where the relevant legal framework permits it. The draft should require an express, reasoned extension where an application cannot be determined within the stated time, rather than allowing an unrecorded or indefinite pause.

7. Keep a record that can support review. Applicants should be able to see the date of each submission, request, inspection, and status change. This would make it easier for a business to plan and for a public body to identify recurring points of delay. Public reporting should use aggregated information and avoid exposing personal or commercially sensitive details.

8. Make the standard proportionate and testable. Implementation should begin with a defined set of processes, publish baseline measures, and invite feedback from small businesses. The measures should distinguish waiting time controlled by the authority from time awaiting applicant action, while showing both. A standard should not treat a nominal online service as one-stop if applicants still face disconnected steps.

7. Conclusion

20. The six members’ accounts point to a practical problem: an applicant may have submitted a form and paid a fee yet still lack a dependable answer about what happens next. The evidence is limited and does not establish a national pattern or a legal breach. It does provide concrete questions for the RT-001 consultation: are requirements consistent and visible, can applicants track their files, are service times published, and are extensions explained?

21. The Secretariat submits this evidence to inform the draft, not to resolve those questions in advance. The recommended standard should preserve local legal requirements while making process expectations visible, measurable, and usable for small businesses. The accounts may be tested further through consultation and through consistent collection of application-stage, timing, and document-request information.

Notes and sources

Sources

1. World Bank, B-READY 2025 report