Starting a clinic
Shop and establishment registration for clinics in India What seven state Acts say about a doctor's clinic, and what follows once you hire staff.
The shop act licence often comes up when a clinic opens a current account or a landlord asks for paperwork. It is a state labour law, and each state answers the clinic question differently. We read the Acts of seven states and quote what each says.
Published · Last reviewed · 11 min read
- Maharashtra, Gujarat and Uttar Pradesh name the "establishment of any medical practitioner" in their Acts. All three moved the full-registration threshold to twenty workers from late 2025 (Maharashtra and Gujarat from ten, by Ordinance). Below it, Maharashtra and Gujarat ask for an online intimation within 60 days; the Uttar Pradesh Act does not apply at all.
- Delhi and Telangana define a commercial establishment by any "trade, business or profession" and set no staff threshold for registration. A clinic registers within 90 days of opening in Delhi and within 30 days in Telangana. Karnataka exempts "offices of legal practitioners and medical practitioners in which not more than three persons are employed".
- Shop act registration is about the people you employ: working hours, a weekly off, leave and records. It does not replace clinical establishment registration under the health law or the municipal trade licence.
Whether a doctor's clinic needs shop and establishment registration depends on the state and on how many people the clinic employs. In Delhi and Telangana a clinic is a "commercial establishment" because it carries on a profession, and it registers whatever its size. In Maharashtra, Gujarat and Uttar Pradesh the Act names clinics expressly but keeps full registration for larger employers (twenty workers since the 2025 changes), and in Karnataka a doctor's office with three or fewer employees is exempt. The table below gives the answer for each state we checked, with the section to quote.
Is a doctor's clinic an "establishment" under the Shops Act?
Each state has its own Act, run by its labour department. A clinic is not a shop, so the question is whether the definition of an establishment reaches a profession. The newer Acts say so in plain words. Section 2(4) of the Maharashtra Shops and Establishments (Regulation of Employment and Conditions of Service) Act, 2017 says an establishment "includes establishment of any medical practitioner (including hospital, dispensary, clinic, polyclinic, maternity home and such others)". Gujarat's 2019 Act, section 2(c)(i), uses the same words. Uttar Pradesh added an almost identical clause to its 1962 Act in 2026. Older Acts get there through the word "profession": Delhi's 1954 Act, section 2(5), covers "any premises wherein any trade, business or profession ... is carried on", and Telangana's 1988 Act, section 2(5), does the same.
On exemptions and thresholds the states split. The count is of people you employ for wages: receptionist, nurse or compounder, attendant, cleaner. The doctor who owns the clinic is the employer, not a worker. Maharashtra's Act also leaves out "a member of the family of an employer" (section 3(13)), and Uttar Pradesh's leaves out "members of the family of an employer" (section 3(1)(f)).
State by state: does your clinic have to register?
| State | Shops Act | Does a clinic register? | Threshold and deadline | Where to apply |
|---|---|---|---|---|
| Maharashtra | Act of 2017 | Yes, clinics are named in s. 2(4) | 20 or more workers: registration within 60 days (s. 6). Fewer than 20: online intimation within 60 days (s. 7). Ordinance of 1 Oct 2025 raised 10 to 20; replacing Bill not confirmed passed | Labour Department, Labour Management System (lms.mahaonline.gov.in) |
| Gujarat | Act of 2019 | Yes, clinics are named in s. 2(c)(i) | 20 or more workers: registration within 60 days (s. 6). Fewer than 20: online intimation within 60 days (s. 7). Ordinance raised 10 to 20 from 16 Dec 2025; replacing Bill not confirmed passed | Labour department Inspector; check the state labour portal |
| Uttar Pradesh | Act of 1962, amended by U.P. Act 12 of 2026 | Yes, if 20 or more employees (s. 2(4)(ii), s. 3(1)(g)) | 20 or more employees: apply on the departmental web portal within six months of starting (s. 4-B). Fewer than 20: Act does not apply | Labour department web portal |
| Delhi | Act of 1954 | Yes, a profession is a commercial establishment (s. 2(5)) | No staff threshold in s. 5. Statement within 90 days of the establishment starting work (s. 5(5)) | Delhi Labour Department, Chief Inspector of Shops and Establishments |
| Telangana | Act of 1988 | Yes, a profession is a commercial establishment (s. 2(5)) | No staff threshold. Within 30 days of starting work (s. 3(1)). Fee by number of employees, from ₹100 for none | Labour Department, labour.telangana.gov.in (Form I online) |
| Karnataka | Act of 1961 | Not if the doctor's office employs 3 persons or fewer (s. 3(1)(e)) | Larger clinics: within 30 days of starting work (s. 4(3)); certificate valid 5 years (s. 4(4)) | Labour department Inspector of the area |
| Tamil Nadu | Act of 1947, amended 2018 and 2021 | Check with the Inspector (see below) | 10 or more workers: registration within six months of starting (s. 3). Fewer than 10: intimation within six months (s. 3-A) | Labour department Inspector |
Maharashtra and Gujarat: clinics are named, small clinics file an intimation
Both Acts follow one model. As enacted, section 1(3) applied the whole Act to establishments "employing ten or more workers" and only section 7 to smaller ones. Section 6 asks a larger establishment to apply for registration "within a period of sixty days" of starting business; section 7 asks a smaller one to "give an intimation of having commenced the business" online in the same sixty days, and receive a receipt.
Both states then raised the threshold by Ordinance. Maharashtra's Bill No. LXXXIX of 2025, introduced on 8 December 2025 to replace an Ordinance of 1 October 2025, substitutes "twenty" for "ten" in sections 1, 6 and 7 from that date. Gujarat Bill No. 1 of 2026 (published 11 February 2026, replacing Ordinance 3 of 2025) does the same from 16 December 2025. We could not confirm from a primary source whether either Bill has passed, so check the Act in force on the state labour portal. For a typical single-doctor clinic with fewer than ten workers the answer is the same under either figure: an online intimation, not full registration.
A Maharashtra registration is valid for the period requested, "subject to a maximum period of ten years", and is renewed online at least thirty days before expiry (section 6(3)). In Gujarat it stays in force "till the change in ownership or nature of business takes place" (section 6(3)). Skipping the Maharashtra intimation is punishable "with a fine of rupees one thousand" (section 7(3)).
Uttar Pradesh: covered since November 2025, from twenty employees
Until 2025 the Uttar Pradesh Act did not apply to "establishments for the treatment or care of the sick, infirm, destitute or mentally unfit" (section 3(1)(e)). U.P. Act 12 of 2026 (assented on 1 January 2026, deemed in force from 19 November 2025) omits that clause, adds the "establishment of any medical practitioner (including hospitals, dispensary, clinic, polyclinic ...)" to the definition of commercial establishment, and adds section 3(1)(g) so that the Act has no application to "shops or commercial establishment employing less than twenty employees".
The new section 4-B asks every owner "where twenty or more employees are working, within six months of the commencement of such business" to apply "on the departmental web-portal". A complete application gets "automatic registration". Where a business falls under another government department's regulation, the applicant also files an affidavit that it complies with that department's rules.
Delhi and Telangana: every clinic registers
Delhi's Act has no worker threshold for registration. Section 5(1) asks "the occupier of every establishment" to send the Chief Inspector a statement with the prescribed fee, and for a new establishment the ninety days run from "the date on which the establishment commences the work" (section 5(5)). The certificate "shall be prominently displayed at the establishment and shall be renewed at such intervals as may be prescribed" (section 5(3)). We found no clinic exemption in the Act text we read; the Schedule of exemptions under section 4 can be changed by notification.
Telangana's section 3(1) gives a new establishment thirty days "from the date on which the establishment commences its work". The certificate is displayed "at a prominent place", is deemed granted if no adverse order comes within thirty days, and runs "upto the 31st day of December following" (section 3(2), (3)). The Labour Department's checklist says the online application is Form I, there is "No requirement of renewal, only Annual fee to be paid", and the fee depends on staff numbers:
| Employees | Fee |
|---|---|
| 0 | ₹100 |
| 1 to 5 | ₹500 |
| 6 to 10 | ₹1,000 |
| 11 to 20 | ₹2,000 |
| 21 to 50 | ₹5,000 |
The annual fee is due from 1 November to 1 December, with 25% added from 2 to 31 December and 50% after. The checklist asks for a photograph of the Telugu name board, a list of employees, the rent or sale deed and the employer's ID. Telangana's section 73(2) relieves "hospitals or other institutions for treatment or care of the sick" only from sections 7 and 15, not from registration.
Karnataka: small doctors' offices are exempt
Section 3(1) of the Karnataka Act says "Nothing in this Act shall apply to" a list that includes "(d) establishments for the treatment or care of the sick, infirm, or the mentally unfit" and "(e) offices of legal practitioners and medical practitioners in which not more than three persons are employed". A single-doctor clinic with a receptionist and an attendant falls in clause (e). A larger clinic should ask the labour inspector whether clause (d) covers it. If it registers, it has thirty days from the date "the establishment commences its work" (section 4(3)), displays the certificate, and renews it every five years (section 4(4)).
Tamil Nadu: ten workers and six months
After amendments in 2018 and 2021, the employer of "every establishment employing ten or more workers" applies "within a period of six months from the date of commencement of his business"; the certificate is issued within twenty-four hours or is "deemed to have been granted", and "shall be prominently displayed" (section 3). A smaller establishment gives an intimation within the same six months (section 3-A). Section 4(2)(a) takes "hospitals and other institutions for the treatment or care of the sick" out of only sections 7 and 13. The 1947 definitions were illegible in our copy, so ask the labour inspector whether a clinic is an "establishment" in Tamil Nadu.
How do you register or file the intimation?
- Count your workers on the day you open: everyone you pay wages to, full-time or part-time. Leave out yourself and, where the Act says so, family members.
- Read the row for your state above and decide whether you need full registration, an intimation, or nothing.
- Keep ready the clinic's name and address as on the board, the employer's ID, the rent agreement or ownership proof, a list of employees, and a photograph of the name board where the state asks for one. Our documents checklist for a new clinic has the rest.
- Apply on the state labour department's portal within the window: 30 days (Telangana, Karnataka), 60 days (Maharashtra, Gujarat), 90 days (Delhi) or six months (Uttar Pradesh, Tamil Nadu).
- Download the certificate or the intimation receipt, display the certificate where the Act asks for it, and diary the renewal or annual fee date.
- Update the labour department when the address, the owner or the staff count changes. Delhi asks for this within thirty days (section 6); Telangana within fifteen days (section 3(4)).
What does the Act ask of you once your receptionist joins?
The rest of each Act is about the people at your front desk: hours, rest and leave. These duties apply wherever the Act applies to your clinic, so check the threshold first.
| State | Daily and weekly hours | Weekly off | Leave |
|---|---|---|---|
| Delhi | 9 a day, 48 a week (s. 8) | 24 hours in a row (s. 17) | 15 days privilege after 12 months; 12 days sick or casual a year (s. 22) |
| Maharashtra | 9 a day, 48 a week; break after 5 hours (s. 12) | 24 hours in a row; compensatory off within 2 months (s. 16) | 8 days casual a year; 1 day per 20 worked after 240 days (s. 18) |
| Gujarat | 9 a day, 48 a week (s. 12) | 24 hours in a row (s. 16) | 7 days casual and 7 medical a year; 1 day per 20 worked after 240 days (s. 18) |
| Telangana | 8 a day, 48 a week (s. 16) | Not quoted here | 15 days after 240 days' service (s. 30(1)); 12 sick and 12 casual a year (s. 30(5)) |
Maharashtra's 2025 Bill and Gujarat's 2026 Bill raise the daily limit from nine to ten hours and the continuous stretch from five to six. Uttar Pradesh's new section 6 keeps nine hours a day and forty-eight a week, caps the day at eleven hours with overtime, and pays overtime at "twice the ordinary rate".
In practice: a written duty roster, a fixed weekly off, a leave register and an appointment letter, which Uttar Pradesh now requires for every employee (section 28-A(8)). If you run morning and evening OPDs, add up the receptionist's two shifts and check them against the daily limit and the spread-over. Our receptionist daily checklist covers the desk side of the day.
How is this different from clinical establishment registration and a trade licence?
| Registration | Law and department | What it is about | Who it applies to |
|---|---|---|---|
| Shops and establishments | State Shops Act; labour department | Employment: hours, weekly off, leave, wages, records | Depends on the state and the number of workers, as above |
| Clinical establishment | Clinical Establishments Act, 2010 or the state's own Act; health department | Permission to run a clinic: premises, staff, standards, records | Every clinic in a state where the Act applies, including a single-doctor clinic |
| Trade licence | Municipal Act; municipal corporation | Use of premises for a listed trade within city limits | Depends on the city's list of trades |
One does not stand in for another. Which clinical establishments law applies in your state is in our clinic registration guide. The municipal side, with the fire certificate, is in our post on fire NOC and trade licence for clinics, and the full sequence for a new clinic is in how to open a clinic in India.
Questions
Does a single-doctor clinic need a shop act licence?
In Delhi and Telangana, yes, because the Acts cover any profession and set no staff threshold. In Maharashtra and Gujarat a clinic below the worker threshold (ten as enacted, twenty under the 2025 changes) files only an online intimation within 60 days. In Uttar Pradesh the Act does not apply below twenty employees, and in Karnataka a doctor's office with three or fewer employees is exempt.
Is the shop act certificate the same as clinic registration?
No. The shop act certificate comes from the labour department and covers your duties as an employer. Clinic registration comes from the health department under the Clinical Establishments Act or your state's own Act and covers whether the clinic may operate. The first depends on your state and staff count.
Does the doctor count as a worker?
No. The doctor who owns the clinic is the employer. The count is of people employed for wages, such as a receptionist, nurse, attendant or cleaner, and Maharashtra and Uttar Pradesh leave out the employer's family. If a second doctor is on salary, ask the labour inspector whether your state counts them.
What happens if the staff count crosses the threshold later?
Maharashtra, Gujarat and Tamil Nadu say that when the number of workers reaches the threshold, all provisions of the Act apply and the employer must obtain full registration. Keep a dated staff list so you can show when the count changed, and apply within the state's window.
Sources
- Maharashtra Shops and Establishments (Regulation of Employment and Conditions of Service) Act, 2017 (Mah. Act LXI of 2017), English translation published in the Maharashtra Government Gazette, 7 September 2017, sections 1, 2(4), 3, 6, 7, 12, 16, 18 (accessed 26 Oct 2026)
- Maharashtra Shops and Establishments (Regulation of Employment and Conditions of Service) (Amendment) Bill, 2025, L. A. Bill No. LXXXIX of 2025, Maharashtra Government Gazette, 8 December 2025 (accessed 26 Oct 2026)
- Gujarat Shops and Establishments (Regulation of Employment and Conditions of Service) Act, 2019 (Guj. 4 of 2019), Gujarat Government Gazette Extraordinary, 7 March 2019, sections 1, 2(c), 6, 7, 12, 16, 18 (accessed 26 Oct 2026)
- Gujarat Shops and Establishments (Regulation of Employment and Conditions of Service) (Amendment) Bill, 2026, Gujarat Bill No. 1 of 2026, Gujarat Government Gazette Extraordinary, 11 February 2026 (accessed 26 Oct 2026)
- Uttar Pradesh Dookan Aur Vanijya Adhishthan Adhiniyam, 1962, with the Uttar Pradesh Dookan Aur Vanijya Adhishthan (Sanshodhan) Adhiniyam, 2025 (U.P. Act 12 of 2026), English translation notified 2 January 2026, sections 2(4), 3(1), 4-B, 6, 28-A (accessed 26 Oct 2026)
- Delhi Labour Department, Delhi Shops and Establishments Act, 1954, sections 2(5), 4, 5, 6, 8, 17, 22 (accessed 26 Oct 2026)
- Telangana Shops and Establishments Act, 1988 (Act 20 of 1988), sections 2(5), 3, 16, 30, 73 (accessed 26 Oct 2026)
- Telangana Labour Department, procedure checklist for registration under the Shops and Establishments Act (accessed 26 Oct 2026)
- Telangana Labour Department, frequently asked questions (accessed 26 Oct 2026)
- Karnataka Shops and Commercial Establishments Act, 1961 (Karnataka Act 8 of 1962), sections 3, 4, 7, 12, 15 (accessed 26 Oct 2026)
- Tamil Nadu Shops and Establishments Act, 1947, with the Amendment Acts of 2018 (T.N. Act 27 of 2018) and 2021, sections 3, 3-A, 4 (accessed 26 Oct 2026)
This is operational guidance for clinics, not legal or tax advice. Confirm with your state authority, council or CA.
Drafted with AI assistance; every fact checked against the sources listed; reviewed by Shaurya Pratap Singh.