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CAQM Direction 97: Demolition Receipts, the 200 m² Plot Threshold and NCR Dust Compliance

The declaration and demolition-receipt sequence under Direction 97, how the 200 m² plot test differs from dust-portal registration, and the latest regulatory context.

By Testa & TegmenPublished 12 min read
Contents
  1. What Direction 97 changes in the project sequence
  2. The 200 m² threshold includes an important condition
  3. Deposition and a receipt come before reconstruction
  4. Why the receipt matters again at the CC or OC stage
  5. The 5 km × 5 km grid is an infrastructure obligation
  6. Dust control continues alongside the paper trail
  7. The separate 500 m² dust-portal requirement
  8. The national rules and GRAP remain separate checks
  9. A practical file review before work progresses
  10. Frequently asked questions
  11. 1. Does the requirement include a plot of exactly 200 m²?
  12. 2. Should I use plot area or total built-up area?
  13. 3. Is a project below 500 m² exempt from Direction 97?
  14. 4. Will a demolition contractor’s payment invoice satisfy the receipt requirement?
  15. 5. Does the direction guarantee a facility within a five-kilometre radius?
  16. 6. Can projects outside municipal limits ignore the dust portal?
  17. 7. Does a receipt allow work during GRAP restrictions?
  18. Original documents: PDFs and official updates

Key takeaways

Who this is for: NCR project proponents, developers, architects, construction teams and environmental professionals

  • A plot of at least 200 m² must also meet the specified demolition condition for these declaration and receipt clauses.
  • The declaration precedes plan approval; deposition and a receipt precede construction or reconstruction.
  • CC/OC agencies verify the deposition receipt; a contractor invoice is not automatically receiving evidence.
  • The separate 500 m² portal framework has wider specified NCR geography after the September amendment; current GRAP orders remain a separate check.

For a qualifying redevelopment project in Delhi-NCR, demolition-waste documentation now belongs at the beginning of the construction programme. CAQM Direction No. 97 connects an estimated-quantity declaration, deposition at a designated receiving point or facility, and a receipt that the certificate-issuing agency must verify. Issued on 20 February 2026, the direction came into force on 1 April 2026.

Read the original direction.

The important threshold is plot area equal to or greater than 200 square metres, together with the specified demolition condition. A separate dust-portal framework uses a 500 m² plot threshold. In October 2026, readers also need the September extension of that portal framework and the revised Graded Response Action Plan (GRAP). These documents address connected risks but impose different checks.

What Direction 97 changes in the project sequence

The Commission for Air Quality Management in National Capital Region and Adjoining Areas (CAQM) issued Direction 97 under section 12 of the CAQM Act, 2021. Its operative framework concerns major Delhi-NCR cities having Municipal Corporations, including the New Delhi Municipal Council, and/or Development Authorities. The assigned responsibilities fall across project proponents, building-plan authorities, municipal bodies and certificate-issuing agencies.

The sequence matters. Before building-plan approval, an estimate is declared. Before construction or reconstruction begins, the relevant demolition material is deposited through the designated arrangement and a receipt obtained. Before a Completion Certificate or Occupation Certificate—CC or OC—is issued, the responsible agency verifies the deposition receipt.

This moves documentation across several project stages. Leaving the evidence with a demolition contractor until the final handover can make it harder to connect the initial declaration, actual material movement and certificate application. Maintaining that connection from the start is a practical response to the direction, rather than a new form prescribed by this article.

The 200 m² threshold includes an important condition

Paragraph 17(ii) requires building-plan approving authorities to obtain a declaration of the estimated quantity of demolition waste before approval for projects with plot area of at least 200 m², where demolition is required before construction or reconstruction. Both parts of that description matter: the land-area threshold and the demolition-related activity.

Exactly 200 m² is included. The measure is plot area, not the aggregate floor area across storeys. A project summary that substitutes “built-up area” changes the test. Similarly, describing this particular clause as a demolition declaration for every fresh construction project omits the condition in the text.

The estimate is prospective: it describes material expected from demolition. It should not be presented as proof that the material has already reached a facility. Teams should ask the approving authority which current format, supporting calculation and submission route it accepts; Direction 97 does not itself supply a universal estimation formula or a single national application screen.

An estimate that can be traced back to the project is more useful than an unexplained number. As an editorial preparation measure, retain its basis and the version submitted with the plan. If later records differ, preserve an explanation rather than silently replacing one figure with another. The applicable authority’s requirements remain the reference.

Deposition and a receipt come before reconstruction

Under paragraph 17(iii), the municipal or development authority must ensure that, in the qualifying cases, the project proponent deposits demolition waste at a designated collection point or storage/processing facility and obtains a receipt before taking up construction or reconstruction. Direction 97, paragraphs 17(ii)–(iv).

A transport booking and evidence of deposition answer different questions. A contractor’s invoice may show that a service was charged for; it does not, by itself, establish that a designated receiving arrangement accepted the material. Ask what evidence the receiving facility issues and what the approving authority will recognise.

Confirm the destination before scheduling removal. Check whether it is designated, whether it can receive the relevant material, and which applicable route the local authority requires. A name on a proposed collection-point list should not be treated as evidence that the facility is presently accepting loads. This article does not certify a directory of available facilities.

For a useful internal record, keep the project reference, movement records and receiving receipt together. Dates, quantities and receiving-party details help reconcile the handover where available. These are recordkeeping suggestions; the direction does not provide a mandatory receipt template containing every field mentioned here.

Why the receipt matters again at the CC or OC stage

Paragraph 17(iv) requires the agencies issuing CCs or OCs to verify the deposition receipt submitted by the project proponent before issuing the certificate. Paragraph 19 reinforces strict compliance by those agencies. The earlier receipt therefore has a later verification function; it is not merely a document for closing the removal contractor’s account.

Keep the original receipt and a legible backup within the project’s approval records. Make responsibility for obtaining and preserving it clear when assigning demolition and construction work. This helps prevent a change of contractor or project team from breaking the evidence trail.

Receipt verification is one requirement in the certificate process. It does not promise automatic issuance of a CC or OC, waive other approvals or regularise unrelated deficiencies. Readers should confirm the full submission requirements with the competent authority rather than treating one document as the entire completion file.

The 5 km × 5 km grid is an infrastructure obligation

Paragraph 17(i) directs Municipal Corporations and Development Authorities to establish collection points, intermediate storage and processing facilities in accordance with the national rules. It specifies at least one collection point within a 5 km × 5 km grid under their jurisdiction.

A grid is not a five-kilometre radius around every project. Nor does this clause, by itself, verify the location, capacity or operating hours of a particular receiving point. Those details need current confirmation from the responsible authority. The distinction is useful when preparing an actual removal route rather than a general compliance summary.

The same direction assigns municipal and development authorities responsibility for environmentally sound transportation and disposal. Paragraph 20 asks the NCR State Governments and Delhi government to ensure an integrated web portal, geotagging of collection/storage/processing locations and GPS tracking of C&D transport. It would be inaccurate to infer from this instruction that every intended system is already functional everywhere.

Dust control continues alongside the paper trail

Direction 97’s background recalls wind barriers, dust screens, sprinkling or mist, dust suppressants, covered materials and debris, and transport in covered vehicles. It also refers to the earlier anti-smog-gun direction. These are part of the existing dust-control framework; the document does not make a receiving receipt a substitute for physical control at the site.

Review the points where material is exposed: its storage, handling, loading and transport. A covered pile can become an uncovered load, and a completed document does not prevent dust during handling. The working arrangement should follow the material through each stage rather than stop at the site gate.

Do not invent a universal anti-smog-gun count from Direction 97. Its recital refers to Direction 69 and area-related deployment; the applicable equipment requirements should be checked against the relevant instrument and current local directions. Similarly, maintaining equipment on a list is different from using it effectively during the activity concerned.

The principle for project review is straightforward: the documents should describe an arrangement that exists, and the site arrangements should remain effective while work continues. An inspection photograph or a portal entry is a record of a particular point in time, not evidence that every later activity complied.

The separate 500 m² dust-portal requirement

Direction 97 recalls Directions 11–18 of 11 June 2021: registration of relevant C&D projects with plot area of at least 500 m² on State/Delhi portals, alongside video monitoring, fortnightly self-audit and air-quality monitoring arrangements. This is the dust-monitoring framework described in its recitals, rather than a new 500 m² threshold created by Direction 97.

The 29 September 2026 amendment extends that framework beyond municipal limits to eligible projects in specified urban, controlled, development, industrial-development, industrial and highway-corridor areas in NCR, as recognised under the applicable statutory or planning frameworks. It retains the 500 m² plot threshold and other provisions. Read the amendment, paragraphs 9–11.

Being outside a municipal boundary is therefore not, by itself, enough to dismiss portal applicability. Check the project’s location against the relevant planning designation and authority. Conversely, the amendment should not be described as covering every rural parcel or as extending beyond NCR without qualification.

Consider a hypothetical 300 m² plot requiring demolition before reconstruction. It may meet Direction 97’s declaration-and-receipt condition without meeting the 500 m² portal threshold. This illustrates two different tests; it is not a complete exemption assessment. A project below either threshold must still examine other applicable requirements.

The national rules and GRAP remain separate checks

The Environment (Construction and Demolition) Waste Management Rules, 2025, carry a notification dated 2 April 2025 in the Gazette issue dated 4 April. They commenced on 1 April 2026, superseding the 2016 rules with the stated saving for earlier acts or omissions. These are different dates. A Direction 97 receipt alone does not establish compliance with every national-rule obligation.

Gazette, pages 1 and 19.

CAQM’s Direction 104, dated 29 September 2026, issued a revised GRAP schedule with immediate effect. Its annex includes dust-control requirements and stage-specific restrictions on C&D activities. Receipt or portal compliance does not override restrictions applicable to the proposed activity. Check the operative invocation order and local instructions on the day of work; this article does not state which stage is currently active.

Direction 104 and GRAP schedule.

For current context, CAQM’s 15 October release reports a 14 October inspection of road dust and C&D accumulations in Gurugram. It illustrates continuing oversight of material beyond individual site boundaries. It does not announce a new 200 m² threshold or prove a finding against every construction project. Dated inspection report.

A practical file review before work progresses

Use the following as an editorial preparation checklist, not an additional statutory form:

  1. Identify the plot area, proposed demolition and competent approving authority.
  2. Confirm the applicable declaration and its submission before plan approval.
  3. Verify the designated receiving arrangement and applicable transport route.
  4. Link actual deposition evidence to the project and preserve the receipt.
  5. Check portal applicability separately, including the September geographical amendment.
  6. Check current work restrictions and retain the records needed for CC/OC verification.

Where evidence is missing, record the gap and seek clarification from the responsible authority. Do not retrospectively describe a contractor payment as a facility receipt. Direction 97 warns that non-compliance may lead to penal action under section 14; this article does not assign a fine or determine liability in an individual case.

For related reading, see our HSPCB dust-portal guide and Knowledge Hub. Use the original instruments for the particular requirement and its current scope.

Frequently asked questions

1. Does the requirement include a plot of exactly 200 m²?

Yes. The direction says equal to or more than 200 m², subject to the specified demolition condition. The declaration concerns demolition required before construction or reconstruction. Preserve both qualifications when assessing the project.

2. Should I use plot area or total built-up area?

Use plot area for the thresholds discussed here. Adding floor areas across storeys changes the measurement. Other instruments can use different definitions, so check each requirement against its own text rather than transferring a number between regimes.

3. Is a project below 500 m² exempt from Direction 97?

The portal threshold does not replace the separate 200 m² demolition-related test. A smaller project can meet that condition. Being below a particular threshold also does not remove other dust, building or applicable environmental obligations.

4. Will a demolition contractor’s payment invoice satisfy the receipt requirement?

It should not automatically be treated as proof of deposition at a designated receiving point or facility. Obtain the appropriate receiving evidence and confirm the authority’s accepted documentation. A charge, a booking and a completed deposition are different records.

5. Does the direction guarantee a facility within a five-kilometre radius?

No. It specifies collection-point provision within a 5 km × 5 km grid. Confirm actual location, designation and availability with the authority. The infrastructure obligation is not a verified operating directory for a particular project.

6. Can projects outside municipal limits ignore the dust portal?

No blanket conclusion is justified. The September amendment extends the framework to eligible projects in specified NCR planning and development areas, retaining the 500 m² plot threshold. Check the applicable area classification and responsible authority.

7. Does a receipt allow work during GRAP restrictions?

No. Deposition evidence and permission to carry out an activity are separate questions. Check the current official order and any applicable conditions before proceeding. A receipt also does not guarantee automatic issue of a CC or OC.

Information checked as of 18 October 2026, 11:59 PM IST.

Original documents: PDFs and official updates

The first four references open the original PDFs; use your browser’s download or Save command for a copy. The other two references are official webpages. The review package includes backup copies of all four PDFs.

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