The order is signed, the roof is surveyed and the layout is nearly frozen. Then the factory’s safety officer asks whether the fire office and the factory inspector have cleared the array. The EPC has no clear answer, because no single document says what applies to a solar array on a factory roof.
This guide is for the Indian EPC working on a C&I factory rooftop. It covers the fire and factory side only. For the electrical approval itself, read our CEIG drawing approval guide first. This post does not repeat it.
Quick answer. No document we opened names rooftop solar as a trigger for a fire NOC. Fire approval attaches to the building, and factory approval attaches to the factory premises. Treat the array as a change to a building that already holds, or needs, both. Ask the fire office and the factory inspector in writing before the layout is frozen, and lock that layout before the CEIG submission.
Does rooftop solar on a factory need a fire NOC?
We could not find a state that requires a fire NOC specifically for rooftop solar in any document we could open. We read the fire law of two states, Maharashtra and Gujarat. We also read Part 4 of the National Building Code 2016, the CEA safety regulations 2023 and the factory law. None of them names rooftop solar as a trigger.
That is not the same as “no approval needed”. Fire approval is tied to the building, by occupancy and size. A factory shed that holds a fire certificate, or needs one, carries conditions about access, escape routes and fire equipment. An array changes the roof those conditions describe.
The NBC speaks to this directly. Clause 3.2.7 of Part 4 says an existing building need not comply with the code unless it is altered. On alteration it says “it shall be necessary to obtain permission of the Authority for such alteration consistent with fire hazard”. Whether a roof array counts as an alteration is the Authority’s call. So the working rule is simple: ask, and keep the reply on file.
What do the Maharashtra and Gujarat fire laws say?
Both laws work on the building, not on the equipment fitted to it. The table lists what we read and what each text says about rooftop solar.
| State and document | Who is covered | What it asks for | Names rooftop solar? |
|---|---|---|---|
| Maharashtra Fire Prevention and Life Safety Measures Act, 2006 (Maharashtra Act III of 2007), Law and Judiciary Department text modified up to 7 May 2013 | Owner or occupier of a building classified in Schedule I, which includes industrial buildings (Group G) | Section 3(1): provide and maintain the fire installations listed in Schedule I. Section 3(2): no completion certificate unless Schedule I is met. Section 3(3): a licensed agency certificate to the Chief Fire Officer, plus a maintenance certificate in January and July | No |
| Gujarat Fire Prevention and Life Safety Measures Regulations, 2023 (Gazette Extra No. 348, 13 December 2023) | Buildings listed in the Third Schedule of the 2021 amendment Rules (we did not open that schedule) | Fire safety plan approval tied to development permission (regulation 5.1). Fire safety certificate before occupancy (5.3). Certificate valid three years (5.7). The owner certifies that no alteration was made without approval of the competent authority (Annexure 13) | No |
Three details matter for a factory roof.
- Maharashtra, industrial buildings. Note 14 under Schedule I says its table is for small-scale industry units. For other industries the requirements “will have to be worked out” on the relevant Indian Standards “and also in consultation with the local fire authorities”. So for a larger factory, the local fire office sets part of the list.
- Gujarat, old NOCs. Regulation 5.8 treats a building with a No Objection Certificate as holding a fire safety certificate. The measures behind that NOC are checked again. A fire NOC on file is therefore still the starting document.
- Gujarat, renewal. Regulation 7.6 lets the fire safety officer reject a renewal if the owner has not kept to the certificate. Our reading is that an array which blocks a roof exit or an access route the certificate relied on is a risk at that point. The regulation does not say this in so many words.
Two cautions. The Maharashtra text is the 2013 consolidated copy, and later amendments may exist. Gujarat amended its Act in 2021 and replaced its regulations in 2023. Check the current text on the state portal before you quote either. We did not open the fire laws of Tamil Nadu, Karnataka or any other state for this post, so nothing here applies to them.
When does the factory inspector have to approve?
The factory side has just changed, so the law you cite matters.
Section 6 of the Factories Act, 1948 let a state require previous written permission. This covered the factory site and “the construction or extension of any factory”. If no order came within three months of a registered-post application, permission was deemed granted (section 6(2)). An explanation says adding plant or machinery is not an extension if it does not reduce the clear working space or worsen the environment.
From 21 November 2025 the Occupational Safety, Health and Working Conditions Code, 2020 (the OSH Code) is in force. The PIB release of 21 November 2025 announced the four labour codes as effective from that date. The Gazette text of the Code (Act 37 of 2020) repeals the Factories Act in section 143(1). Section 143(3) treats earlier actions and rules as made under the Code, so far as they do not conflict with it. Section 79 of the Code carries the plan approval power forward, with a deemed permission after 30 days when an application goes in electronically.
Gujarat is the one state where we read the new rules. The Gujarat Occupational Safety, Health and Working Conditions Rules, 2025 (Gazette Extra No. 87, 12 June 2025) replace the Gujarat Factories Rules, 1963. Two rules bear on a roof array.
- Rule 69, approval of plans. No factory building or premises may be “constructed, reconstructed, extended or taken into use” without written permission. The Chief Inspector-cum-Facilitator of factories gives it. The application is electronic and carries plans to scale that show escape routes, aisles and passage-ways.
- Rule 70, certificate of stability. A Form 32 certificate must be submitted after a factory building is “constructed, re-constructed, altered, repaired or extended”. It is also due when machinery or process is added. A competent person signs it with the load calculations. A fresh certificate is also needed after every extension, alteration, repair or addition of plant.
Neither rule names solar. Our reading is that an array on an existing roof does not obviously trigger plan approval. It is not clearly a construction or an extension. The stability rule is wider. A roof that now carries array load has been altered in the sense the rule uses. We would file the certificate anyway, and our rooftop structural safety certificate guide shows what it must contain.
That is a reading, not a ruling. Ask the factory inspectorate which rule set applies in your state, the old factory rules or new OSH rules. Ask whether it wants a plan, a certificate or both.
What do the NBC and the CEA regulations say about roof access?
Neither document gives a rooftop solar setback in metres. Here is what each does say.
NBC 2016 Part 4, Fire and Life Safety. Clause 1.2 applies the Part to high-rise buildings and to special buildings. These include industrial and storage buildings with floor area above 500 m² on any one or more floors. We read the text from the Internet Archive copy of NBC 2016 Volume 1, which is the BIS publication. We searched Part 4 for solar and photovoltaic terms and found none. The Archive text is machine-read, so a miss is possible. Confirm in your own BIS copy.
NBC Part 3 (Development Control Rules and General Building Requirements) does mention solar. Clause 21.2.1 asks plots of 500 m² and above to install solar PV. It leaves “required provisions in the building bye-laws and mechanism for required clearances and approvals” to the Authority. The building bye-laws, not the code, set the clearance.
CEA safety regulations 2023. Regulation 121(1) is the one firm roof rule. It asks for “clear pathways of minimum seventy five centimetre in width with hand rails for roof access and emergency exit” on rooftop systems. It also asks for walkways between rows for cleaning. The inverter goes “in the periphery of the building and as near as the solar panel”. DC cable must be UV protected or in UV-protected pipe. Regulation 121(4) requires fire detection and automatic suppression to “comply with the relevant standards” without naming one. We read the Gazette text through the Internet Archive capture of the CEA-hosted PDF, because the CEA address did not load.
So the only fixed number is 75 cm with handrails. Anything wider comes from the fire office’s comments on your building, the building bye-laws and, for insured plants, the insurer.
Which drawings does each reviewer want?
Each reviewer reads a different sheet. The third column shows only what the text we read asks for. The fourth column is our recommendation for a rooftop array.
| Sheet | Who reads it | What the text we read asks for | Our recommendation for the array |
|---|---|---|---|
| Roof layout plan to scale | Fire office, factory inspector | Gujarat fire regulation 5.1: building plans showing the location of fire measures. Gujarat OSH rule 69: plans showing escape routes, aisles and passage-ways | Show array blocks, 75 cm pathways with handrails, roof exits and stairs, and existing roof objects such as skylights and vents. Dimension the walk from each stair to the far edge of each array |
| Section and elevation at roof edge and stair | Factory inspector | Gujarat OSH rule 69: elevations and cross sections of buildings | Show handrails, parapet and any level change between roof zones |
| Isolation and equipment plan | Fire office, Electrical Inspector | CEA 121(1)(v) and (viii): disconnects at accessible points. CEA 38(3)(i): emergency isolating device at the point of supply | One sheet that marks every DC isolator, AC isolator, inverter and the building isolating device, with a legend a fire officer can read in a minute |
| Single-line diagram | Electrical Inspector | Per the state CEIG process | Use the same isolator labels as the isolation plan, so one name means one device. See the SLD glossary entry |
| Stability certificate with load calculations | Factory inspector | Gujarat OSH rule 70: Form 32 signed by a competent person | Make sure the array and ballast or fixing loads are named in the calculation |
| Fire equipment points | Fire office | CEA 121(4): detection and suppression per relevant standards | Show existing extinguisher points near each roof access and ask the fire office what it wants on the roof |
| One-page change summary | All three | Not asked for | State what the array adds to the roof, in a short note, so each reviewer sees the same facts |
If the layout sheet and the isolation sheet are weak in your file, the Solar Rooftop Detailed Engineering Design service can help. It prepares the layout with setbacks and walkways, the electrical drawings and the structural report. The fire and factory filings stay with the owner and the licensed agency or architect of record.
How do you design access and setbacks without a national number?
Start with the numbers you can cite, then add what the reviewers ask for.
- Draw the pathways before the modules. Put the 75 cm pathway from each roof exit to every inverter and isolator location first. Then place arrays in what is left.
- Keep each pathway continuous. A walkway that stops at a skylight or an equipment plinth is not an emergency route. Move the array, not the pathway.
- Make the walkway a walkable surface. On a sheet metal roof, a clear gap is not enough. Confirm with the structural engineer that the pathway can be walked on. Our tin shed solar design guide covers metal roofs.
- Ask for fire office comments in writing. A written reply that gives a roof-edge setback is a number you can design to.
- Tell the owner the kWp effect before approvals. Pathways remove module area. Our fire setback sizing walkthrough shows the arithmetic with US code dimensions, and the fire setback glossary entry defines the term. The method carries over even where the Indian dimensions differ.
For insured plants, the insurer may set its own array size and aisle limits. Our cold storage and warehouse guide reports the figures from one insurer’s roof PV data sheet. Treat those as insurer rules, not as fire office rules.
What should DC isolation show for firefighter safety?
The CEA text gives four isolation points and one gap.
- Combiner box disconnect. Regulation 121(1)(v) asks for disconnection switches or breakers in combiner boxes at a “readily accessible location”. Regulation 121(3)(iv) asks for isolation on the output circuit.
- AC isolation. Regulation 121(1)(viii) asks for a manual disconnection switch to isolate the system from the grid, outside the AC combiner box.
- Point of supply. Regulation 38(3)(i) asks industrial installations for an isolating device at the point of supply. It is fixed at most 1.70 m above ground and cuts supply to the building in an emergency.
- The gap. We searched the Gazette text for “rapid” and “firefighter” and found no rapid shutdown or firefighters’ switch rule. “Fire service” appears once, for displaying emergency contact numbers.
The gap matters because of how a PV array behaves. The IEA PVPS Task 12 report on photovoltaics and firefighters’ operations (April 2017) says PV systems “remain energized” in sunlight. They do so “even after a building’s connection to the grid has been disabled”. It also says DC conductors in a sunlit array stay energised after the main circuits are turned off. It reports calls for a firefighters’ switch in Australia, Germany and the United States. In the US that took the form of the rapid shutdown rule in NEC 690.12, as of the 2014 code the report describes.
So the building isolating device cuts supply to the building, not the live DC cable on the roof. Put that limit on the isolation plan, in plain words, for the fire officer.
Here is what to draw. It is design practice, not a legal requirement.
- A DC isolator at each inverter and where DC cable enters the building. Use the same label on the plan and on site.
- Short DC runs and inverters at the roof periphery, as regulation 121(1)(vii) asks, so less live cable crosses the roof. Our rooftop cable routing guide covers the routes.
- A note on the sheet that string cable stays live in daylight after every isolator is open.
- If the fire office asks for more, a module-level or string-level shutdown device is a design change. Check it with the inverter maker before you promise it.
In what order should the approvals run?
Nothing in the texts we read fixes fire before CEIG. The order below is our recommended sequence, built around one rule. Regulation 45(6) of the CEA regulations bars connecting an alteration to an installation until it is approved or self-certified. A fire comment that moves an isolator after CEIG approval reopens the drawing. Lock the layout first.
| Step | Action | Owner | Why here | Period written in the text we read |
|---|---|---|---|---|
| 1 | Check building status: fire safety certificate or NOC, factory licence and approved plan, roof structure records | Factory owner | Tells you which approvals exist before you design to them | None |
| 2 | Draft the layout: pathways, inverter spots, isolator spots | EPC designer | Every later step reads this sheet | None |
| 3 | Structural check and stability certificate | Competent person | The array load must be in the calculation before the factory inspector sees it | None |
| 4 | Written query or plan filing to the fire office, with the layout and isolation sheets | Owner, with licensed agency or architect | Fire comments change pathways and so module count | Gujarat fire regulation 5.2: 21 days to scrutinise a fire safety plan filing. This is a building plan filing, not a solar filing |
| 5 | Written query to the factory inspector, with the stability certificate | Owner or occupier | Confirms whether plan approval, a certificate or both apply | Gujarat OSH rule 73: plans deemed approved if no reply in 30 days on a valid plan approval application |
| 6 | Revise the layout, SLD and general arrangement together | EPC designer | One revision, not three | None |
| 7 | Submit electrical drawings to CEIG where the state runs that step | Licensed contractor and signatory | The layout is now stable. See the CEIG drawing approval guide | State specific |
| 8 | Build | EPC | Approved drawings govern | None |
| 9 | Fire office re-inspection if it asked for one, then the Electrical Inspector’s site inspection | Owner and licensed contractor | See the CEIG inspection checklist | State specific |
Steps 4 and 5 can run in parallel. The periods in the last column are what those texts say about their own filings. They are not a forecast for a solar array, and no step in the table has a promised duration from us. Any late change to the SLD, such as a DISCOM export limit, reopens the same drawing. Our zero export design guide shows when that happens.
Where does Heaven Designs fit?
Heaven Designs prepares the layout, electrical and structural drawings for rooftop projects. It does not file with the fire office or the factory inspectorate for you, and this post does not suggest it does. The layout and isolation sheets in the table above are the part of the file we can build with you.
If you want to compare your sheets with a finished set, download the design samples. To discuss a factory roof, message the team on WhatsApp. For the full drawing package, see Solar Rooftop Detailed Engineering Design. You can also contact the team and say the state and building type, because the fire and factory rules differ by both.
FAQ
Is a fire NOC mandatory for rooftop solar in India?
We found no document naming it as a rule for rooftop solar. Fire approval is tied to the building. If the factory needs or holds a fire certificate, ask the fire office whether the array needs a fresh filing. Keep the reply in writing.
Does a factory need the Chief Inspector’s approval before rooftop solar?
Plan approval covers construction, reconstruction and extension of a factory. An array on an existing roof is not clearly any of these. A stability certificate is a wider duty in Gujarat, where it follows any alteration or addition of plant. Ask the inspectorate of your state which applies.
Is the Factories Act 1948 still the law?
The OSH Code, 2020 came into force on 21 November 2025 and section 143 repeals the Factories Act. State rules made under the old Act stay in force to the extent they do not conflict with the Code. Gujarat has notified new rules. For other states, check which rule set the inspectorate is using.
Does the NBC set setbacks for solar panels?
We found no solar provision in Part 4. Part 3 clause 21.2.1 leaves clearances and approvals to the Authority’s building bye-laws. The only fixed roof number we found is the 75 cm pathway with handrails in CEA regulation 121(1)(i).
Does India require rapid shutdown?
We found no rapid shutdown or firefighters’ switch rule in the CEA regulations 2023. A fire office may still ask for one for a given building. The US NEC 690.12 requirement is a US rule and does not apply here.
Source and review note
We opened and read the following on 31 October 2026. The CEA (Measures relating to Safety and Electric Supply) Regulations, 2023, notified 8 June 2023. The Factories Act, 1948 from the Ministry of Labour and Employment copy. The OSH Code, 2020 and the Gujarat OSH Rules, 2025. The Maharashtra Act from the Maharashtra Law and Judiciary Department. The Gujarat fire regulations, Gazette Extra No. 348. NBC 2016 Volume 1 from the Internet Archive.
We did not open several documents. These are the Gujarat Third Schedule of covered buildings, the Maharashtra rules under the Act, other states’ fire laws and a BIS paper copy of the NBC. We also did not open the factory rules of any state other than Gujarat. The Gujarat OSH Rules text came from a compliance publisher’s copy of the Gazette, read through an Internet Archive capture. Recheck the state texts before each client conversation and by 30 April 2027. This guide is engineering information, not legal advice, and a fire officer or inspector can ask for more than the texts above.