GRAP Stage 1 to 4: What Changes at Each Level

Every October, somewhere between Dussehra and Diwali, a number on a government dashboard starts climbing and within days, half of Delhi-NCR’s rulebook changes with it. Construction sites go quiet. Diesel trucks get turned back at the border. A generator that ran without comment in September can get physically welded shut in November. None of this happens by ministerial announcement or a new law passed in Parliament. It happens automatically, the moment the region’s Air Quality Index crosses a threshold written into a document most residents have never read: the Graded Response Action Plan, or GRAP.

GRAP is not one rule. It’s four stacked rulebooks, each one triggered by how bad the air actually gets, and each one adding restrictions on top of the last rather than replacing them. Understanding it stage by stage not as a vague “pollution emergency” but as a specific, escalating checklist is the difference between reacting to headlines and knowing exactly what changes for your home, your business, or your generator before it’s announced on the news.

This guide walks through GRAP the way it’s actually built: as a ladder, with four rungs, each one defined by a trigger, a set of newly banned activities, a set of things that stay legal, and an enforcement reality that’s often messier than the official order suggests.

What GRAP actually is (and who runs it)

GRAP was first notified in January 2017, on the directions of the Supreme Court, as Delhi-NCR’s answer to a recurring problem: air quality crises were being handled with ad-hoc, panicked announcements an odd-even scheme here, a construction ban there with no consistent trigger and no consistent rollback. GRAP replaced that improvisation with a rulebook: specific AQI bands, specific pre-approved actions, and critically a body responsible for pulling the trigger.

Since 2021, that body is the Commission for Air Quality Management in National Capital Region and Adjoining Areas (CAQM), a statutory authority created under its own Act of Parliament, which absorbed the plan from its predecessor, the Environment Pollution (Prevention and Control) Authority (EPCA). CAQM doesn’t just enforce GRAP it owns the schedule, revises it, and decides when each stage is invoked or revoked based on both real-time AQI readings and, since a significant 2022 revision, forecasts from IITM Pune and IMD for the following two days. That shift to forecast-based invocation matters: Stage III and IV can now be imposed before the AQI actually breaches the threshold, if models say it’s about to.

GRAP has also been revised more than once since its creation, and the direction of travel has consistently been toward tightening it. The most recent overhaul, notified by CAQM on 21 November 2025, pulled several measures including active discouragement of diesel generator use one full stage earlier than before, precisely because earlier versions of GRAP were seen as reacting too late in the pollution curve. Everything below reflects that revised schedule; if you’re reading this well after publication, treat the AQI bands as stable but double-check the specific action list against CAQM’s official GRAP page, because sub-clauses do get amended between winters.

One more thing worth saying plainly: GRAP applies to Delhi-NCR not to India. It covers Delhi, Gurugram, Faridabad, Ghaziabad, Gautam Buddh Nagar (Noida), and the wider NCR districts. If you run a business in Mumbai, Bengaluru, or Pune, none of the stage-wise restrictions below apply to you directly, though your state’s pollution control board almost certainly has its own DG set and construction norms — a comparison we’ve built out separately in State-Wise Pollution Control Norms for DG Sets Compared and Delhi vs Mumbai vs Bangalore: DG Set Rules Compared.

How the trigger works

GRAP’s four stages map to the National AQI’s own severity bands, but only the top four of them:

Stage	Air quality description	AQI range
Stage I	Poor	201–300
Stage II	Very Poor	301–400
Stage III	Severe	401–450
Stage IV	Severe+ (Emergency)	450 and above

If you’ve never checked how that number is actually built from raw pollutant readings, our explainer on how AQI is calculated in India covers the sub-index and “worst pollutant” logic CPCB uses useful background before the stage breakdown below, since GRAP’s entire architecture rests on that single composite number.

Stages are cumulative going up (Stage III means Stage I and II restrictions are all still active, plus new ones) and are revoked in reverse CAQM typically waits for sustained improvement across several days, not a single good reading, before stepping a stage down. That asymmetry surprises people: AQI can dip below 400 for a day and Stage III measures often stay in force, because a single day’s improvement doesn’t guarantee it holds.

Level 1 – Stage I: “Poor” (AQI 201–300)

Trigger: AQI sustained or forecast in the 201–300 band.

Who feels it first: Construction contractors, roadside eateries, municipal corporations, and after the November 2025 revision — anyone who depends on a backup diesel generator.

What’s newly restricted at this level:

• Strict enforcement of Pollution Under Control Certificates (PUCC) across RTO checkpoints, with fines under the Motor Vehicles Act for lapsed ones.
• Mandatory dust-control measures at every construction and demolition site covered material transport, no open storage of debris or sand, sprinkling at active sites.
• A ban on open burning of waste, leaves, and biomass, with municipal bodies required to deploy mechanical road sweeping and water sprinkling on identified dust hotspots.
• Coal and firewood use in dhabas, hotels, and open-air eateries is discouraged in favour of PNG, LPG, or electric alternatives.
• Under the November 2025 revision, government and municipal bodies must “ensure uninterrupted power supply to discourage the use of diesel generator sets” a measure that used to appear only from Stage II onward. In practice this means DISCOMs are directed to minimise scheduled outages in NCR during Stage I, precisely so residents and businesses have less reason to switch on a DG set at all.

What’s still allowed: Construction continues (with dust controls), private and commercial vehicles run without fuel-type restrictions, and diesel generators are legal to operate the emphasis at this stage is on reducing the reasons to use them, not banning them outright.

Enforcement reality: Stage I is the stage most residents never notice, because its measures are largely administrative — sweeping schedules, water tanker deployment, PUCC checks rather than visible bans. It’s also the stage that’s invoked and revoked most often through the October–January window, sometimes multiple times in a single season, as the AQI oscillates around the 300 mark.

Level 2 Stage II: “Very Poor” (AQI 301–400)

Trigger: AQI sustained or forecast in the 301–400 band, layered on top of Stage I.

Who feels it first: Facilities managers running DG sets for backup power, and government office staff in Delhi, Gurugram, Faridabad, Ghaziabad, and Gautam Buddh Nagar.

What’s newly restricted at this level:

• Diesel generator sets are banned outright, with exemptions only for emergency and essential services, unless the unit is running on a certified dual-fuel setup or is fitted with a CPCB-approved Retrofit Emission Control Device (RECD). This is the single most consequential line item in GRAP for any business that keeps a DG set as backup power, and we’ve broken down exactly which capacity bands need what — 19–125 kW, 125–800 kW, and above 800 kW each have different compliance paths in our dedicated post, GRAP Rules for DG Sets in Delhi-NCR.
• Staggered office timings kick in for government and municipal employees across the five core NCR districts — another measure the November 2025 revision moved down from Stage III, specifically to reduce peak-hour traffic congestion earlier in the pollution curve.
• Intensified parking fees in identified zones, meant to nudge commuters toward public transport, alongside increased bus and metro frequency.
• Stricter PUC enforcement at fuel-filling stations, with vehicles unable to fill fuel without a valid certificate in some enforcement drives.

What’s still allowed: Construction continues under Stage I dust rules (Stage II does not add a fresh construction ban), and BS-VI, CNG, and electric vehicles face no new restrictions.

Enforcement reality: This is where the gap between “on paper” and “on the ground” becomes visible. CAQM’s own data cited in the existing compliance literature suggests only around a fifth of DG sets in the organised sector had retrofit devices installed as of the last major count, against roughly 1.5 lakh units in organised commercial and industrial use and an estimated 40,000 more in the unorganised sector. Stage II is the stage where sealing drives against non-compliant generators typically intensify; if you want to understand what actually happens when an inspector finds an uncertified unit running, see What Happens When a DG Set Is Sealed for Non-Compliance.

Level 3 – Stage III: “Severe” (AQI 401–450)

Trigger: AQI sustained or, since the 2022 revision, forecast to reach the 401–450 band within 48 hours meaning Stage III can be imposed pre-emptively.

Who feels it first: Construction and demolition businesses, BS-III petrol and BS-IV diesel vehicle owners, and school-going children in hybrid-learning districts.

What’s newly restricted at this level:

• A ban on construction and demolition activities across NCR, with a defined exemption list — railway and metro projects, highways, national security and defence installations, hospitals and other health infrastructure, and a handful of other public-interest categories continue.
• BS-III petrol and BS-IV diesel four-wheelers are barred from plying on NCR roads, with enforcement concentrated at RTO checkpoints and major entry corridors.
• Stone crushers and mining-related activity are suspended.
• Under the November 2025 revision, government offices move to 50% in-person staffing, with the remainder working from home — a measure that was previously reserved for Stage IV.
• State governments retain discretion to shift physical classes for younger students to a hybrid model, though this is decided case-by-case rather than mandated uniformly across NCR.

What’s still allowed: BS-VI and electric vehicles continue to run without restriction, and DG sets that are already dual-fuel or RECD-certified stay operational, since Stage III layers on top of rather than replaces Stage II’s generator rules.

Enforcement reality: Stage III is where GRAP starts generating visible news coverage “GRAP-3 imposed in Delhi-NCR” headlines, traffic diversions at state borders, and a noticeable jump in enforcement checkpoints on roads like GT Karnal Road and the Delhi-Gurugram border. It’s also the stage most prone to whiplash: CAQM has, in recent winters, imposed and revoked Stage III within the same week as AQI readings fluctuate around the threshold, which is part of why compliance teams that manage generators or fleets across NCR increasingly track daily bulletins rather than relying on news reports.

Level 4 – Stage IV: “Severe+” / Emergency (AQI above 450)

Trigger: AQI sustained or forecast above 450 the “Severe+” category, and GRAP’s ceiling. As an example of how fast this escalates in practice, CAQM invoked Stage IV in Delhi-NCR on 18 January 2026 as readings pushed past this band, layering emergency measures on top of everything already active under Stages I–III.

Who feels it first: Truckers and freight operators, diesel LMV owners, and non-essential industrial units running on unapproved fuels.

What’s newly restricted at this level:

• Entry of trucks into Delhi is banned, barring those carrying essential commodities or providing essential services food, fuel, medicine, and similar categories are typically exempted by name in the CAQM order.
• A near-complete ban on diesel light motor vehicles, with exemptions narrowed further to essential and emergency services only; non-essential commercial diesel vehicles registered outside Delhi-NCR (from Haryana, UP, Rajasthan, and elsewhere) face additional entry restrictions at state borders.
• Construction and demolition activity is halted entirely, with the Stage III exemption list narrowed further.
• Industrial units not running on PNG, electricity, or other approved clean fuels are directed to shut down, with continuous-process industries (where a sudden stoppage would itself cause safety or environmental damage) handled through a separate protocol rather than a blanket shutdown.
• State governments are empowered to consider additional emergency measures at their discretion closing schools and colleges to physical classes, restricting non-essential government offices, and in some past winters, evaluating an odd-even vehicle scheme, though the last of these is invoked far less consistently than the others.

What’s still allowed: Emergency and essential services continue to operate across every category, gas-based and fully compliant CPCB-IV+ diesel generators keep running (CAQM’s Direction No. 76 specifically allows gas, dual-fuel, and new CPCB-IV+ diesel gensets to operate even through GRAP stages, without the time restrictions imposed on older units), and freight carrying food, fuel, and medicine moves without disruption.

Enforcement reality: Stage IV enforcement concentrates at NCR’s border checkpoints the Delhi-Gurugram border, DND/Chilla connecting Delhi and Noida, the Badarpur border, and GT Karnal Road where commercial vehicle checks intensify sharply. Stage IV is also, by CAQM’s own design, meant to be short-lived: it’s revoked as soon as sustained improvement pulls the AQI back into the Severe band, though “sustained” in practice has meant anywhere from a few days to a few weeks depending on the winter.

DG sets across the ladder – the short version

Because generators are the single restriction most businesses ask about, here’s the compressed view across all four stages:

Stage	DG set status
Stage I	Legal to run; DISCOMs directed to minimise outages so there’s less reason to switch one on
Stage II	Banned for non-essential use, unless dual-fuel or RECD-certified; emergency services exempt
Stage III	Stage II rules continue unchanged; no new generator-specific restriction added
Stage IV	Stage II rules continue; only gas, dual-fuel, and CPCB-IV+ new diesel units are guaranteed uninterrupted operation

For the full capacity-band breakdown what a 25 kVA unit at a small clinic needs versus a 500 kVA unit at a commercial tower see GRAP Rules for DG Sets in Delhi-NCR, and for what this restriction pattern means financially for a business that can’t simply switch off its backup power, How GRAP Restrictions Affect Businesses Using DG Sets walks through the compliance economics sector by sector.

Three things people consistently get wrong about GRAP

“GRAP is a Delhi government scheme.” It isn’t. CAQM is a central statutory body with jurisdiction over the whole NCR, not just the Delhi government’s territory, which is why Gurugram, Noida, Ghaziabad, and Faridabad are bound by the same stage-wise restrictions even though they sit in different states.

“Once a stage is announced, it applies until winter ends.” Stages move both up and down through the season based on the rolling AQI and forecast it’s common for NCR to cycle between Stage II and Stage III multiple times between November and January, and even briefly touch Stage IV before dropping back, rather than climbing once and staying there.

“If my area’s AQI reading looks fine, I’m exempt.” GRAP is invoked NCR-wide based on the regional average and forecast, not hyperlocal readings. A pocket of NCR with a locally lower AQI doesn’t get carved out from stage-wide restrictions — the plan operates at the regional level by design, since pollution doesn’t respect ward boundaries. If you track AQI on your phone through the season, our guide to reading AQI apps correctly explains why a single locality’s number can diverge from the CAQM-cited regional figure that actually triggers a stage change, and our comparison of the best AQI monitoring apps for Indian cities is a good next stop if you want a more granular, location-specific read alongside the official trigger.

Why the ladder keeps getting steeper

The November 2025 revision wasn’t the first time CAQM tightened GRAP’s timing, and it’s unlikely to be the last. The pattern behind each revision is consistent: measures that were found to arrive “too late” in previous winters after the AQI had already spent days in a severe band get pulled one stage earlier. It reflects a broader shift in how North India’s winter pollution problem is understood: not as a single bad-air event to be managed reactively, but as a predictable seasonal pattern driven by a combination of factors stubble burning, vehicular load, construction dust, and a meteorological lid that traps it all close to the ground. If you want the science behind why this happens specifically to North India and specifically in winter, our explainer on why Delhi’s AQI spikes each winter covers the wind and inversion patterns that make GRAP necessary in the first place, and it’s also why Delhi consistently features among the most polluted cities in India through this window even as other metros see comparatively milder winters.

The health stakes behind the framework are also worth keeping in view GRAP’s escalating restrictions exist because sustained exposure at Severe and Severe+ levels carries real, measurable health costs, particularly for children; how air pollution affects children’s health lays out why that population bears a disproportionate share of the burden GRAP is trying to blunt.

Frequently asked questions

Does GRAP apply outside Delhi-NCR? No. GRAP is a CAQM instrument specific to the National Capital Region and adjoining districts named in its notification. Other Indian cities and states run their own, separately structured pollution control norms — see our state-by-state and city-by-city comparisons for how those differ.

Who decides when a GRAP stage is invoked or lifted? The Commission for Air Quality Management (CAQM), based on real-time CPCB AQI data and, since 2022, IITM/IMD forecasts for the following 48 hours.

Can Stage III or IV be imposed without the AQI having actually crossed the threshold yet? Yes this is the “forecast-based” provision added in the 2022 revision. If models predict the AQI will breach a stage’s threshold within two days, CAQM can invoke that stage pre-emptively rather than waiting for the number to actually cross the line.

Do all four stages’ restrictions apply once Stage IV is invoked? Yes. Stages are cumulative invoking Stage IV means Stage I, II, and III measures remain active simultaneously, with Stage IV’s additional restrictions layered on top.

Is there a fixed calendar window when GRAP applies? GRAP measures are AQI-triggered, not date-triggered, so technically a stage could be invoked at any time of year if readings warranted it. In practice, given North India’s meteorology, invocations cluster almost entirely between mid-October and mid-January.