EV Traction Battery Pack Compliance – AIS-156, AIS-038 Rev.2 & IS 16893 - Standphill India
AIS-156 / AIS-038 Rev.2 · MoRTH Regime · ARAI / ICAT / NATRIP
Verified against AIS-156, AIS-038 Rev.2 (fourth revision August 2024), MoRTH notifications, AISC guidelines, IS 16893 (Parts 2 and 3) and CMVR framework – updated July 2026

EV Traction Battery Pack Compliance – AIS-156, AIS-038 Rev.2 & IS 16893

AIS-156 (L-Category) · AIS-038 Rev.2 (M/N Category) · Mandatory Since Dec 2022 · 4th Revision Aug 2024 · IS 16893 Cell Testing · NOT a BIS QCO Product

AIS-156 (2W/3W)
AIS-038 Rev.2 (M/N)
Mandatory Dec 2022
IS 16893 Cells
Not BIS QCO

Critical: EV Battery Packs Are NOT a BIS QCO Product – AIS Homologation Is the Mandatory Route

EV traction battery packs are mandatory under AIS-156 (L-category) and AIS-038 Rev.2 (M/N category) since December 2022 – through vehicle type approval under CMVR by MoRTH via ARAI/ICAT/NATRIP. This is NOT a BIS QCO or CRS product. A BIS certificate for an EV pack does not give AIS approval; an AIS certificate is not a BIS certificate. Getting this wrong has caused real compliance failures and customs problems for Indian EV players.

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About EV Traction Battery Packs – NOT a BIS QCO Product

EV traction battery packs power electric vehicles. They are among the most intensively regulated products in India's battery landscape – but the regulation flows through vehicle homologation under the Central Motor Vehicles Rules (CMVR), not through a BIS Quality Control Order or CRS registration. This distinction is critical, and getting it wrong is the most expensive compliance mistake in the Indian EV industry.

BIS certification does NOT satisfy AIS-156 or AIS-038 requirements. AIS approval does NOT satisfy BIS QCO requirements. They are issued by different authorities under different laws. A BIS certificate for an EV battery pack does not mean your vehicle is type-approved. An AIS certificate is not a BIS certificate. Both may be required simultaneously for different purposes.

The Compliance Map – What Applies to Your EV Battery

Complete EV Battery Compliance Picture

Traction battery pack (complete assembled pack): Mandatory AIS-156 (L-category: 2W/3W/quadricycles) or AIS-038 Rev.2 (M/N category: buses, trucks) – mandatory since December 2022 via CMVR type approval. Not a BIS QCO product.

Lithium cells inside the pack: IS 16893 (Parts 2 & 3) testing at NABL-accredited labs mandatory within AIS Phase 2 (since March 2023). Voluntary BIS ISI licence against IS 16893 also available – increasing OEM procurement demand.

Portable lithium cells/batteries (if separately supplied in portable-application scope): Mandatory IS 16046 (Part 2) CRS registration under MeitY.

BWMR 2022 EPR: Mandatory for all EV battery producers, importers and brand owners – CPCB registration and annual obligations.

ProductRegimeMandatory?Authority
EV traction pack (complete)AIS-156 (L-cat) / AIS-038 Rev.2 (M/N cat)Yes – since Dec 2022MoRTH via ARAI/ICAT/NATRIP
Lithium cells (within AIS)IS 16893 P2/P3 testing within AIS frameworkYes (part of AIS)AISC/MoRTH
Voluntary BIS for EV cellsIS 16893 ISI licenceVoluntary (OEM demand rising)BIS
Portable lithium cells (if applicable)IS 16046 (Part 2) CRSMandatoryMeitY / BIS
BWMR EPRBattery Waste Management Rules 2022MandatoryCPCB / MoEFCC

AIS-156 vs AIS-038 Rev.2 – Which Applies

Vehicle category determines which standard applies:

Vehicle CategoryAIS StandardVehicle TypesStatus
L-categoryAIS-1562-wheelers (e-scooters, e-motorcycles), 3-wheelers (e-autos, e-rickshaws, e-carts), quadricyclesMandatory since Dec 2022
M-categoryAIS-038 Rev.2Passenger vehicles with more than 8 seats (e-buses, mini-buses)Mandatory since Dec 2022
N-categoryAIS-038 Rev.2Commercial vehicles with electric powertrain (trucks, LCVs, HCVs)Mandatory since Dec 2022
4th RevisionAIS-038 Rev.2 (Aug 2024)All M/N category – updated requirements now in forceIn force for new approvals

What AIS-156 and AIS-038 Rev.2 Test on EV Battery Packs

The test regime covers the battery pack as a safety-critical vehicle component:

Thermal Propagation

Pack must contain thermal runaway to one cell/module without propagating further – the defining EV fire-safety test.

Overcharge / Overdischarge

BMS must cut off before dangerous limits – electrical abuse protection under automotive fault conditions.

Over-Temperature

BMS protects cells and pack from temperature extremes in all operating conditions including Indian summer heat.

IPX7 Water Ingress

Pack enclosure must resist water ingress to at least IPX7 level under vehicle operating conditions including monsoon.

Mechanical Shock & Vibration

Structural integrity under vehicle dynamics – road shock, vibration and mounting loads on Indian roads.

Microprocessor BMS

Full microprocessor-based BMS with cell-level protections (overcurrent, overtemp, overcharge, overdischarge, balancing) – Phase 2.

EMC Testing

BMS electromagnetic compatibility per AIS-004 – Phase 2 requirement.

RFID Traceability

RFID or QR code on cells and packs for lifetime traceability – Phase 2 requirement feeding subsidy verification.

Earth Leakage Detection

Mandatory earth leakage detection at the on-vehicle charger interface – August 2024 revision.

Audio-Visual Warning

Mandatory warning system for thermal events – August 2024 revision.

The August 2024 Revision of AIS-038 Rev.2 – What Changed

AISC issued the fourth revision of AIS-038 Rev.2 in August 2024, now in force for new type approvals of M and N category vehicles:

  • Enhanced thermal propagation testing: updated test protocol based on global and Indian EV fire incident analysis
  • Four BMS temperature sensors minimum: increased from previous requirement
  • Active parallel circuit protection: specific protection requirements for active cell-balancing circuits
  • Earth leakage detection for charger: mandatory at the on-vehicle charger interface
  • Audio-visual thermal warning: mandatory in-vehicle warning triggered by BMS during thermal anomaly
  • EMC testing updated: BMS EMC per AIS-004 with updated specifications
  • RFID traceability refined: updated specifications for cell and pack RFID/QR marking

OEMs already type-approved under earlier AIS revisions: verify your approval certificate revision level and confirm with ARAI/ICAT whether updated testing is required for current or next production runs. We help navigate this.

IS 16893 – the Cell Standard Inside the AIS Framework

IS StandardWhat It Covers
IS 16893 (Part 2)Performance testing of lithium-ion cells for propulsion of electric vehicles (capacity, discharge, cycle life)
IS 16893 (Part 3)Safety requirements for lithium-ion cells for EV traction (abuse testing, thermal, mechanical, electrical)

From AIS Phase 2 (31 March 2023), IS 16893 Parts 2 and 3 testing at NABL-accredited labs is embedded as a mandatory requirement within AIS type approval. This is a testing obligation within the AIS framework – distinct from, but available alongside, the voluntary BIS ISI licence for EV cells. For international cell manufacturers supplying Indian EV OEMs, a voluntary IS 16893 BIS licence is increasingly demanded as a procurement qualification document.

AIS Homologation Process – Step by Step

1

Identify applicable AIS standard

AIS-156 for L-category (2W/3W), AIS-038 Rev.2 for M/N category, and the correct revision level. Confirm Phase 1 and Phase 2 requirements for your vehicle type.

2

Cell-level testing at NABL lab

IS 16893 (Parts 2 & 3) testing of the cells used in the pack at a NABL-accredited laboratory – mandatory within AIS Phase 2.

3

Pack-level testing at authorised agency

Complete traction battery pack testing at ARAI, ICAT, NATRIP or VRDE against all AIS-156 or AIS-038 Rev.2 requirements including thermal propagation, BMS verification, IPX7, mechanical tests, RFID.

4

Type approval application

Submit cell test reports, pack test reports, vehicle system description and BMS documentation to the testing agency for type approval under CMVR.

5

CMVR type approval grant

Testing agency issues Type Approval Certificate covering the vehicle including the battery system – required for registration and sale in India.

6

BWMR EPR registration

Register on CPCB portal for Battery Waste Management Rules 2022 EPR compliance – mandatory for producers and importers regardless of homologation status.

We coordinate the AIS process alongside the testing agency: preparing cell documentation, pack specifications, BMS technical dossiers, and managing the interface between cell suppliers, pack manufacturers and homologation agencies.

FAME / PM E-Drive Subsidy and Battery Compliance

  • Valid CMVR type approval under AIS-156 or AIS-038 Rev.2 is a hard eligibility condition for FAME-II and PM E-Drive subsidy
  • RFID battery traceability (AIS Phase 2 requirement) feeds into the subsidy verification portal mechanism
  • Make-in-India / ALMM frameworks specify minimum domestic value addition in the battery pack for government EV procurement
  • Temporary relaxation (January 2026 – January 2027): Ministry of Power has eased strict ALMM localisation for bidders using lithium-ion cells under ToT arrangements where domestic cell manufacturing is limited

Complete Compliance Snapshot

ItemDetail
L-category traction packAIS-156 – mandatory since December 2022; testing at ARAI/ICAT/NATRIP/VRDE. Authority: MoRTH.
M/N-category traction packAIS-038 Rev.2 – mandatory since December 2022; 4th revision August 2024 in force. Authority: MoRTH.
Lithium cells (within AIS)IS 16893 (Parts 2 & 3) testing at NABL labs – mandatory within AIS Phase 2 (since March 2023).
Voluntary BIS for EV cellsIS 16893 ISI licence – voluntary, available from BIS, OEM procurement demand increasing.
Portable lithium cellsIS 16046 (Part 2) CRS – mandatory if within portable-application scope (MeitY).
Homologation agenciesARAI, ICAT, NATRIP, VRDE – authorised under CMVR.
BWMR 2022 EPRMandatory – CPCB registration and annual obligations for producers and importers.
Subsidy complianceAIS compliance + RFID traceability required for FAME-II / PM E-Drive eligibility.
BIS roleVoluntary IS 16893 ISI for EV cells; mandatory IS 16046 CRS for portable lithium cells; NO mandatory BIS QCO on the complete EV pack.

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Frequently Asked Questions

No - this is the most important distinction in EV battery compliance. AIS-156 is an Automotive Industry Standard enforced through vehicle type approval under the Central Motor Vehicles Rules (CMVR), issued by MoRTH and administered through ARAI, ICAT, NATRIP and VRDE. BIS certification is a separate product certification from the Bureau of Indian Standards under the BIS Act, 2016. They are issued by different authorities under different laws. AIS-156 does not satisfy BIS requirements, and BIS does not satisfy AIS-156. Both may be required simultaneously for different purposes.
AIS-156 covers L-category vehicles: two-wheelers (e-scooters, e-motorcycles) and three-wheelers (e-autos, e-rickshaws, e-carts), plus quadricycles. AIS-038 Rev.2 covers M-category (passenger vehicles with more than 8 seats - buses) and N-category (commercial vehicles - trucks, LCVs, HCVs). Both have been mandatory since December 2022, with Phase 2 requirements effective March 2023. The fourth revision of AIS-038 Rev.2 issued in August 2024 is now in force for new type approvals.
IS 16893 is the Indian Standard for lithium-ion cells for EV traction applications (aligned with IEC 62660). Part 2 covers performance testing; Part 3 covers safety testing. From AIS-156 Phase 2 (31 March 2023), NABL-accredited lab testing of cells per IS 16893 Parts 2 and 3 became a mandatory requirement within the AIS type approval process. BIS also offers voluntary ISI certification against IS 16893 for EV traction cells separately - increasingly demanded by OEM procurement as a supplier qualification document.
The August 2024 fourth revision of AIS-038 Rev.2 added: enhanced thermal propagation testing protocol, four BMS temperature sensors minimum, active parallel circuit protection requirements, mandatory earth leakage detection for on-vehicle charger, audio-visual warning for thermal events, updated EMC testing of BMS per AIS-004, and refined RFID traceability specifications. These requirements apply to new type approvals for M and N category vehicles.
No. EV traction battery packs must comply with AIS-156 or AIS-038 Rev.2 as a condition of vehicle CMVR type approval. A pack not covered by valid homologation cannot legally be fitted to a vehicle sold in India. Customs clearance of standalone packs for vehicle integration requires documentation of homologation status. Importers sourcing packs from overseas suppliers must ensure AIS compliance is in place before shipment.
IS 16893 testing at NABL-accredited labs is mandatory within the AIS Phase 2 framework - this is a testing requirement embedded in AIS homologation, not a separate BIS licence. However, BIS offers voluntary ISI licences against IS 16893 for EV traction cells. For international cell manufacturers supplying Indian EV OEMs, a voluntary IS 16893 BIS licence is increasingly demanded as an OEM procurement document providing traceability and independent quality verification beyond the AIS test report.
The authorised testing agencies for AIS homologation are: ARAI (Automotive Research Association of India, Pune), ICAT (International Centre for Automotive Technology, Manesar), NATRIP (National Automotive Testing R&D and Innovation Centre), and VRDE (Vehicle Research and Development Establishment, Ahmednagar). ARAI is most commonly used for EV battery homologation. These agencies test packs and vehicles against AIS-156 and AIS-038 and issue the type approval under CMVR.
FAME-II and its successor PM E-Drive subsidy schemes require valid CMVR type approval under AIS-156 or AIS-038 Rev.2 as a hard eligibility condition. RFID battery traceability required under AIS Phase 2 feeds into the subsidy verification mechanism. Make-in-India and ALMM frameworks impose domestic content requirements on batteries in government-supported EV procurement. The Ministry of Power granted a temporary one-year relaxation from strict ALMM localisation requirements (January 2026 to January 2027) for bidders using lithium-ion cells under ToT arrangements.
Yes. EV battery producers, importers and brand owners must register under the Battery Waste Management Rules, 2022 (BWMR) on the CPCB portal for Extended Producer Responsibility. Annual collection and recycling obligations, prescribed labelling and periodic returns apply. EV batteries represent a significant future waste stream and CPCB is increasingly focused on compliance in this segment.
Non-compliant EV battery packs mean the vehicle cannot obtain CMVR type approval, which means the vehicle cannot be legally registered or sold in India. For subsidy-eligible vehicles, non-compliance results in disqualification from FAME-II/PM E-Drive benefits. Customs may detain packs where homologation documentation is incomplete or absent. For EV OEMs, non-compliance means their entire vehicle programme is blocked from market access.

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