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Two cities can post nearly identical looking heat advisories on the same afternoon: a colour-coded alert, a helpline number, a reminder to drink water and avoid the midday sun. In one city, that alert was triggered automatically because a local temperature and humidity threshold, built from years of that city’s own mortality data, was crossed the night before. In the other, someone in a municipal office copied last year’s document, changed the date, and pasted the same numbers a neighbouring state used. Both cities can now claim, on paper, to have a Heat Action Plan. Only one of them actually has an early warning system.
This distinction, between a plan that acts and a plan that merely exists, is the real story behind India’s heat governance boom, and winter, when most cities quietly revise these documents before the next summer, is exactly when it is worth asking which kind a city actually has.
From one city to 250-plus
India’s Heat Action Plans trace back further than most people assume. Odisha adopted the country’s first heatwave response plan in 1999, a year after a heatwave killed more than 2,000 people in the state, as reporting on the plans’ origins has documented. But the template that spread nationally came from Ahmedabad, whose 2013 city-level plan, built after a 2010 heatwave tripled the city’s daily death rate, became the National Disaster Management Authority’s model for the rest of the country. From that single plan, the network has grown to more than 250 city and district-level HAPs spread across 23 heat-prone states, according to figures the government presented to Parliament in 2025 and cited in a 2026 NRDC India assessment of the network. Down To Earth separately put the count at over 130 cities as of May 2026, citing on-the-ground campaigners rather than government tallies, a gap that itself hints at how loosely the number is tracked.
What a real early warning trigger looks like
On paper, every HAP is supposed to follow NDMA’s national guidelines for preparing heatwave plans. A genuine plan defines a local heat threshold rather than borrowing a national default, ties that threshold to a graded, colour-coded alert system-the way Delhi’s Disaster Management Authority does, triggering department-wise action once a threshold is crossed, identifies which groups like outdoor workers, the elderly and slum residents are most exposed through an actual vulnerability assessment, names a funding source rather than leaving it to departments to find money on their own, and assigns legal or institutional authority so agencies are obligated, not merely encouraged, to act.
What a nationwide review actually found
The most rigorous test of that gap so far came from the Centre for Policy Research, which in 2023 ran the first independent, criteria-based review of India’s HAPs. Its report, How Is India Adapting to Heatwaves?, scored 37 plans for city, district, and state-level, drawn from 18 states against 22 criteria covering hazard definition, vulnerability, solutions, and outcomes. The results, reported at the time by ThePrint, were stark. Only 10 of the 37 plans defined a locally derived temperature threshold at all, with the rest relying on a single national criterion applied uniformly regardless of a city’s humidity, night-time temperatures, or duration of heat exposure.
Only two plans, Bhubaneswar’s and Rajkot’s, carried out an actual vulnerability assessment identifying who was most at risk and where. Just 11 of the 37 even discussed where money would come from, and eight of those simply instructed departments to self-allocate from existing budgets rather than naming a dedicated fund. Not one plan cited the legal source of its own authority, which the report warned reduces any real incentive for overstretched departments to comply once a heatwave is actually underway. There was, and still is, no central public repository where all of India’s HAPs can be found, checked, or compared, so it remains unclear how many are updated on a real annual cycle versus how many are simply refiled.
Heat-intentional versus heat-incidental
A useful way researchers now describe the gap is the difference between measures that are heat-intentional and those that are heat-incidental. Tree planting drives, water kiosks, and shaded bus shelters often already exist for other civic reasons, beautification, water supply schemes, transport upgrades, and simply get folded into a city’s heat narrative rather than being designed from the ground up around who actually bears the worst of the heat. That is the analysis offered in the same NRDC India assessment, which also points out that most HAPs operate only at the city level, missing the fact that exposure can vary by several degrees between one ward and the next, and that street vendors, domestic workers, and women in informal work are routinely named in vulnerability lists without any measure actually being designed for them.
What has actually improved by 2026
Three years on from the CPR review, some of the gaps it flagged are closing, unevenly. Delhi’s plan now runs on graded alerts that trigger coordinated department action rather than a single blanket warning. Rajasthan, Tamil Nadu, and Telangana have all formally declared heatwaves a state-specific disaster, which unlocks State Disaster Response Fund money for relief rather than leaving departments to find it elsewhere, an option Carbon Copy’s reporting on HAP financing has tracked as one of the few real financing fixes to emerge since 2023. Kerala has pushed HAP design down to the panchayat level, with one of the country’s first village-level plans in Kozhikode’s Moodadi Grama Panchayat.
Maharashtra has set up a dedicated Centre of Excellence for Heat Resilience and Sustainable Cooling with NRDC, intended to give HAP design ongoing technical backing rather than a one-off document. And the 16th Finance Commission has recommended adding heatwaves to India’s official list of notified disasters, a change that would open up national disaster funds that heat currently cannot draw on at all.
None of this closes the underlying gap. Environmental campaigners quoted by Down To Earth in mid-2026 described most of India’s HAPs as still functioning largely as guiding documents on paper, particularly for outdoor workers and informal settlements, a description that lines up closely with what CPR’s harder data showed three years earlier.
Why this is worth checking now, not in April
Most Indian HAPs are nominally revised annually, and the revision window typically falls over winter, well before the NDMA and IMD’s joint pre-summer preparedness push begins in earnest each February and March. A plan that has not added a real vulnerability assessment, a locally defined threshold, or a named funding line by the time that push begins is unlikely to add one once heatwave season is already underway. For readers, journalists, and local officials wanting to check where their own city stands, the CPR review’s own four questions still hold up as a quick test: does the plan define its own local threshold rather than borrowing a national one, does it name specific vulnerable groups through an actual assessment rather than a general list, does it say where the money is coming from, and can you actually find a current, dated copy of it online.
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