Act No.24 of 2026 has been enacted and published, but its own Section 1(2) says it comes into force only on a date notified by the State Government.
we need an explicit Government notification/rule/clarification bringing private healthcare establishments/service-sector hospitals within the Single Desk framework if that is the policy intention.
“Under the substituted Section 13 of the AP Fire Service Act, 1999, as amended by the AP Omnibus (Speed of Doing Business) Act, 2026, a hospital attracts the Provisional Fire NOC requirement when its height is 15 m or more or when the floor area exceeds 500 sq.m on any one or more floors, subject to the other statutory triggers. The provision does not prescribe a blanket Fire NOC requirement for every hospital irrespective of size.”
Is it enough to revoke the GO148 of MOH 7-12-2021, WHICH ENFORCES FIRE NOC FOR EVERY HOSPITAL IRRESPECTIVE OF SIZE.?
Not by itself. If the objective is to create a legally durable exemption/simplification for small hospitals in Andhra Pradesh, revoking the 2021 GO alone would leave several other legal and administrative layers in place.
The key point is that the 2026 AP Omnibus (Speed of Doing Business) Act has now created a much stronger legal route for a threshold-based fire-safety regime. Its amended Fire Services framework makes the Fire NOC trigger dependent on factors including 15 m height, 500 sq.m floor area, basements and other specified categories—rather than simply the fact that a building is a hospital. ()
What IMA AP should seek
I would frame the demand as five linked actions, rather than simply “revoke GO 148”:
Withdraw/rescind the 2021 GO to the extent it mandates Fire NOC for every hospital irrespective of size.
Issue a fresh AP Government clarification under the amended Fire Services framework stating that a hospital below 15 m and with no floor exceeding 500 sq.m does not require a Fire NOC merely because it is a hospital, provided no other statutory trigger applies.
Make the distinction explicit between “Fire NOC” and “Fire Safety.”
No NOC should not mean no fire-safety obligations. Fire prevention, extinguishers, alarms, emergency exits, evacuation arrangements, electrical safety and maintenance should remain mandatory.Notify ≤20-bed hospitals as a proportionate/risk-based category, with additional requirements triggered by ICU/OT, basement, hazardous activities, height, floor area, etc.
Synchronise the Health, Fire, Municipal and Building authorities so that the same hospital is not subjected to contradictory requirements under different orders.
Why this is legally stronger
The argument should not be:
“Small hospitals should be exempted from fire safety.”
It should be:
“Fire-safety obligations shall remain mandatory; however, a separate Fire NOC should not be required where the statutory threshold for Fire NOC is not attracted.”
That distinction is important.
The 2021 AP policy was reported as making fire-safety certification mandatory for private hospitals. ( But the later statutory framework provides a basis for threshold-based regulation, including hospitals, rather than an automatic NOC requirement solely because the premises is a hospital.
I would therefore change the IMA memorandum
Instead of merely asking:
“Revoke GO 148.”
Use this legally safer demand:
“Rescind/modify G.O. No.148, dated December 2021, insofar as it requires Fire NOC for every hospital irrespective of size, and issue a consequential Government clarification aligning hospital fire-safety regulation with the amended Section 13 of the AP Fire Service framework: "Fire NOC shall be required where the statutory threshold or any other specified trigger is attracted; hospitals below the prescribed threshold shall continue to comply with all mandatory fire-prevention, life-safety, evacuation and maintenance requirements without being subjected to a separate Fire NOC solely by reason of being a hospital.”
This is substantially stronger than simply asking for withdrawal of GO 148.
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