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What an IEM is, and who files one

India abolished licensing for most industries in July 1991. The Ministry of Industry’s notification S.O. 477(E) of 25 July 1991, issued under the Industries (Development and Regulation) Act, 1951, exempted most manufacturing from the industrial licence and put a filing in its place: the Industrial Entrepreneurs’ Memorandum. A company planning a plant in a delicensed industry tells DPIIT what it intends to make, where, in what quantity and with what investment, and receives an acknowledgement at once.

That acknowledgement is not a licence, a clearance or an approval. DPIIT describes it as issued for statistical purposes and limited post facto checking, and says it cannot be read as permission to run an industrial activity unless the plant also complies with every central and state law, regulation and court direction that applies to it. Only a short list of industries still needs a full industrial licence instead, on grounds of safety, health or security: alcoholic drinks, cigars and cigarettes, aerospace and defence electronics, industrial explosives, and a few hazardous chemicals (hydrocyanic acid, phosgene, isocyanates and their derivatives).

Size decides who files. Since 1 April 2025, under DPIIT’s Press Note 1 (2025 Series), an IEM is for undertakings with more than ₹125 crore of investment in plant and machinery or more than ₹500 crore of annual turnover; the earlier limits were ₹50 crore and ₹250 crore. DPIIT raised them to match the Ministry of MSME’s notification S.O. 1364(E) of 21 March 2025, which widened the definition of a medium enterprise. Units below the limits are micro, small or medium enterprises, which register on the Ministry of MSME’s Udyam portal instead of filing an IEM.

Filing Part A does not commit a company to build anything, so the two lists together show which declared plants were reported as built, not which were built. A company that drops a project can ask DPIIT to cancel the acknowledgement: under an office memorandum of 2 January 2024, it sends a request on its letterhead, signed by an authorised officer, with a copy of the original IEM and the reasons, and the cancellation is approved by an Additional or Joint Secretary. None of the files DPIIT published records which memoranda were cancelled.

Because DPIIT published both lists company by company, it is possible to follow individual filings from intention to production. This blog read all of them, 57,821 Part A lines and 14,091 Part B lines, into one register that anyone can search: the IEM Register search page. The page shows, for every Part A filing, whether a Part B was ever found, and has a filter for filings with no Part B.

Year by year: did the filings reach production?

Of the 48,485 memoranda filed from 2001 to 2018, 7,078 (15%) are cited by number in a later Part B list. Another 4,097 have no Part B citing them, but the same company filed a Part B after the filing date; counting those as well gives 23%, an upper estimate, because a company with several projects can report one and not another. On the wider count, the share rises over time, from 19% for filings made in 2001–2006 to 24% in 2009–2015 and 36% in 2016–2018.

Part A memoranda are counted once even when they list several products. “Reached Part B” adds both kinds of match. Filings from 2020 onwards have had less time to report production, and the Part B lists stop in August 2024, so their shares will understate the final outcome. Source: DPIIT monthly IEM lists, parsed by this blog.

Where both dates are known, the median gap between filing Part A and starting production is 0.9 years, and 68% of matched plants started within two years. In 2,268 of the 12,781 matched cases the production date printed in Part B is earlier than the Part A filing: the memorandum was filed after the plant was already running, which the rules allow but which means the “intention” was a formality.

The low share has two explanations that the lists cannot separate. Some plants were never built: filing Part A does not oblige a company to build anything, and DPIIT says the acknowledgement is not a clearance. Others were built but never reported: Part B depended on companies filing it, and nothing in the published lists shows what happened to filings with no Part B. Counting each Part B line once, 3,574 of 12,961 cite a Part A memorandum that is not in the register: 712 of them cite memoranda filed before 2001, and the rest either print no readable number and date or refer to Part A lists that are missing or could not be read.

Which states follow through

Taking only filings from 2001–2018, which have all had at least six years to report, the share that reached Part B varies widely by the state where the plant was to be built.

States with at least 400 filings. A state is where the plant was proposed, as printed in the list. Source: DPIIT monthly IEM lists, parsed by this blog.

Behind the filings with no Part B: which companies still exist

A filing with no Part B can mean the plant was never built, or that it was built and the owner never filed. The lists cannot say which. They can say whether the company behind the filing still exists. For Part A filings from 2017 to 2024 that have no Part B, the company name and plant state were matched against public company-registry pages and the global Legal Entity Identifier (LEI) register, which give each company’s Corporate Identification Number (CIN) and its status on the Ministry of Corporate Affairs register.

Of 7,488 such filings, 4,756 (64%) could be tied to a registered company. Of those, 4,604 (97%) are listed as Active and 148 (3%) are struck off, amalgamated into another company, in liquidation or in insolvency. The other 4 carry another status, such as inactive for e-filing.

No Part B: Part A filings with no Part B found. Identified: a company with the same legal name was found, on a public company page or in the LEI register, and its CIN is consistent with the filing. Struck off or merged: struck off, amalgamated, in liquidation, in insolvency or converted to an LLP. Filings whose company was not identified include firms and partnerships (which have no CIN), names the PDFs printed in fragments, companies that changed name, and names with no matching registry page. Filings from 2023 and 2024 have had little time to reach Part B, so their count includes projects still under construction.

The check separates the filings that can be set aside from those that cannot. A filing whose company has been struck off or merged away is unlikely to become a plant under that filing. A filing whose company is Active may or may not have been built: among 2017–2024 filings that did reach Part B and could be identified, 98% of companies are also Active, so being Active says little about whether a given plant exists. An earlier web check of 40 filings from 2017–2021 with no Part B found a plant or product line operating at the filed location for 19 of them, an announced or half-built project for 4, and an active company with nothing found on the project for 9.

Three sources of identification were used. 2,319 of the identified filings matched on legal name and on a registered office in the same state as the plant. 2,117 matched on legal name alone, because the registered office is in a different state from the plant, which is common for companies with plants in several states; these were accepted only where the company type in the CIN (private or public) agrees with the name. 320 came from the global Legal Entity Identifier (LEI) register, which records each holder’s CIN. Matches were dropped where the company was registered after the filing year (26 filings).

Every name-based match was then checked against the complete LEI register for India, about 170,000 companies that carry an MCA number. 12,668 of the 23,017 matched company records (one per company and plant state) hold an LEI and could be checked: 94% of the name-and-state matches and 84% of the name-only matches are the same company, and the rest point to a different company with the same name. 415 such filings were removed from the counts. Companies without an LEI, mostly smaller firms, cannot be checked this way and may carry a similar error, so treat any single company identification as a lead to confirm, not a fact. Status is as shown on the registry pages on 9 October 2026, not a certificate from the Ministry; the Ministry’s own open dataset on data.gov.in is labelled “data up to 3 November 2023” and so cannot show what has happened since.

Current Ministry record, filings from 2021. For the 1,726 identified filings from 2021 to 2024 with no Part B, each company’s current record on the Ministry’s register (status, date of last AGM, date of last balance sheet) was retrieved through a data service that reads the Ministry’s company master data. A record came back for 1,141 of them (66%), more often for recent filings because those were fetched first; the rest were not retrieved and are not counted as negatives.

Current record: a record was retrieved. Active and filing: status Active, an AGM held in 2025 or later and a balance sheet for FY2024-25 or later. Not Active: 12 amalgamated into another company, 2 struck off, 1 in insolvency.

Of the 1,141 records, 1,126 (99%) are Active and 1,081 (95%) are Active and still filing, which shows the company is still filing its accounts with the Ministry. It does not show the plant was built. 15 are not Active, and all of them had appeared as Active on the free company pages used above, so those pages lag the Ministry on recent mergers and strike-offs; the status shares in the first table should be read with that lag in mind.

How the register compares with DPIIT’s own totals

DPIIT’s last IEM Statistics Report, for August 2024, gives 1,185 Part A acknowledgements in 2022 and 1,267 in 2023, and 916 and 968 Part B acknowledgements. The register built from the monthly lists has 1,048 and 1,219 Part A memoranda for those years, and 755 and 846 Part B lines. Some of the gap is lines that could not be read reliably from the PDFs, and some may be acknowledgements that never appeared in a monthly list. Treat the register as most of the filings, not a complete count.

What changed in October 2025

DPIIT moved every IEM service off its old G2B portal and onto the National Single Window System (NSWS). Its press release and the closure notice on the G2B portal say the same things:

• Part A acknowledgements, Part B filings and Part A amendments are now available only on NSWS. The G2B portal takes no new IEM applications, and old G2B logins do not work: every company has to register again on NSWS.
• A Part A filing pulls the plant address from the company’s GST registration, asks for NIC codes, item-wise capacity, investment, employment, turnover and the expected date of commercial production, and charges ₹1,000 for the first ten items plus ₹250 for each further block of ten.
• The system generates an e-signed acknowledgement that the company downloads from its NSWS dashboard and Entity Locker. DPIIT has always said an IEM acknowledgement is not a licence or a clearance: it only records that the unit is outside compulsory licensing.
• Part B is filed on NSWS after commercial production begins, with the actual start date, capacity and other details.

The October move came six months after DPIIT raised the size limits for filing (see above), so the NSWS register covers only units above the new, higher limits, unlike the lists for 2001–2024.

What would fix this

• DPIIT should publish the NSWS IEM register as an open monthly dataset on data.gov.in, in a machine-readable file: company, plant district and state, NIC code, item, capacity, proposed investment, filing date and acknowledgement number for Part A, and the cited Part A number for each Part B. The PDFs it posted until 2024 already made this information public; NSWS makes it easy to export.
• DPIIT should give every Part A a status (production started, still planned, withdrawn or lapsed), using the expected commencement date that NSWS now collects, and ask companies to update it once that date passes. Companies can already ask DPIIT to cancel an acknowledgement under its January 2024 procedure, but cancellations are not published, so today a filing that never became a plant looks exactly like one whose owner forgot to file Part B.
• The National Statistics Office (MoSPI) should link IEM acknowledgement numbers to the Annual Survey of Industries frame through GSTIN or CIN, so that whether an intended plant actually started producing can be checked from survey and tax records instead of from voluntary Part B returns.
• DPIIT should resume the monthly IEM Statistics Report that stopped after September 2024, with Part A and Part B counts, intended and actual investment by state and industry, so the series that ran from 2001 is not broken by the move to NSWS.

These are proposals from this blog, not recommendations any agency has adopted.

How the lists were read

DPIIT posts each month’s lists as PDFs in the SIA Statistics section of its website: “List of IEM Filed” for Part A and “List of IEM Implemented” for Part B. A catalogue of that library, built from the site’s own index on 7 October 2026, found 348 Part A and 348 Part B company-list files from January 2001 to August 2024: mostly monthly lists, plus financial-year compilations and some months posted twice under different document numbers. Nothing newer is in the library.

The layout changed several times. Until early 2018 the lists are line-printer reports with fixed columns; from 2017 they are ruled tables, and some years mix both. Plain text extraction loses the columns in many of these files, so every PDF was read twice: once for the words and their positions on the page, and once as plain text converted to Markdown. Whichever reading recovered the list’s numbered records was kept. Each line in the register keeps its DPIIT document number so it can be checked against the original PDF. Lines that appear in both a monthly list and a financial-year compilation are counted once.

To link the two parts, the matching uses what DPIIT prints: every Part B line cites the number and date of the Part A memorandum it implements. A Part A filing counts as “reached Part B” when a later Part B line cites its number and year. Where no number matches, a Part B line from the same company, dated after the filing, is shown separately as a weaker name-only match.

The company check added on 9 October 2026 works from the register’s own Part A lines with no Part B. Each company name is reduced to its legal name (Pvt, Ltd and punctuation normalised), and the matching public company page is read for its CIN and status. A CIN carries a two-letter state code and a company-type code; a page is accepted when the state code equals the plant state, or, where the registered office is in another state, when the company-type code agrees with the name. Companies not found are left unidentified, not guessed.

Sources and caveats

About this article: Researched, written and edited by Umashankar Triplicane Dwarakanathan, with AI research assistance; every figure is meant to trace to the primary source cited. See the Editorial Policy for how sourcing, AI use and corrections work.