Labour Codes Compliance Checklist for Employers (2026)

A Labour Codes compliance checklist for employers starts with five checks: map which Government’s rules apply to each site, count headcount per establishment against the 10, 20, 50 and 300 thresholds, re-test every salary band under the 50% wage rule, issue appointment letters to every employee, and update OSH registration on the Shram Suvidha portal. The four Codes have applied since 21 November 2025, the Central Rules were notified on 8 and 9 May 2026, and the EPF wage ceiling rose to ₹25,000 a month from 17 September 2026. Fix money owed to employees first.

Why employers need a written checklist now

The Codes replaced 29 central labour laws. Most employer failures since then are small process gaps, and each leads to claims with interest or penalties. For most private establishments the State Government is the “appropriate Government”, so state rules decide forms and returns. Where a state’s rules are pending, follow the self-executing provisions of the Codes and record what you followed.

The Labour Codes compliance checklist for employers, Code by Code

Foundations

• A “rules map” per site: appropriate Government and status of state rules under each Code.
• A headcount register per establishment and category (permanent, fixed-term, contract, apprentices, inter-state migrants) with twelve-month peaks, since most thresholds look back twelve months.
• A worker tag for each role. “Worker” under the IR Code excludes managerial staff and supervisors earning over ₹18,000 a month. Duties decide, not titles.

Code on Wages

• State minimum wage for every role; the 50% test run for every band (see the 50 percent wage rule guide).
• Deductions within 50% of wages (s.18(3)); fines only from a displayed list, within 3% (s.19).
• Statutory bonus for wages up to ₹21,000 a month, on ₹7,000 or the minimum wage if higher, paid within eight months of year end (s.39).

Code on Social Security

• EPF at 20 or more employees; newly covered staff enrolled under the ₹25,000 EPF wage ceiling. ESI at 10 or more employees for wages up to ₹21,000.
• Monthly match of deductions, challans and passbooks. Deducting PF and not depositing it carries 1 to 3 years’ imprisonment and a ₹1 lakh fine (s.133).
• Gratuity on the new wage base, pro-rata for fixed-term staff, paid within 30 days (s.56). Creche at 50 or more employees (s.67).

Industrial Relations Code

• Grievance Redressal Committee at 20 or more workers, deciding within 30 days (s.4).
• Standing orders at 300 or more workers (s.28).
• Notice of change and a 21-day wait before changing wages, hours, leave or shifts for workers (s.40).
• Retrenchment: notice, compensation and notice to Government (s.70), plus 15 days’ wages to the re-skilling fund within 10 days (s.83, Rule 37).

OSH Code

• Shram Suvidha registration in Form I within 60 days; existing establishments update particulars within six months of the OSH Central Rules (early November 2026).
• Appointment letters for every employee, with LIN and UAN (s.6(1)(f)).
• Overtime at twice the rate, with consent, capped at 144 hours a quarter (Rule 69); annual leave of one day per 20 days worked (s.32).

Registers, returns and the compliance calendar

No Labour Codes compliance checklist for employers is complete without registers. Registers under the Code on Wages (Central) Rules, 2026 are Form I (employees), Form IV (wages, overtime, fines, deductions), Form V (wage slip) and Form IX (attendance cum muster roll). They may be electronic and are kept five years from the last entry. Annual returns follow your appropriate Government’s notified forms and dates.

1. Monthly: wages by the 7th; EPF and ESI by the 15th; registers and PF reconciliation at month end; contractor challans checked before paying invoices.
2. Quarterly: overtime cap, thresholds, GRC pending list, contractor licences.
3. Annual: bonus, leave computation, health check-ups, POSH annual report, gratuity valuation.
4. Event-based: exit wages in two working days, gratuity in 30 days, notice of change 21 days before.

Common mistakes and a 90-day fix plan

Typical gaps that a Labour Codes compliance checklist for employers catches: treating a fixed “special allowance” as excluded from wages, keeping a “full and final in 45 days” policy, counting headcount for the company instead of each establishment, and relying on an old Factories Act licence without updating OSH particulars.

Example: Meridian Foods, a 140-employee unit near Indore, finds 31 loaders with wages between ₹15,000 and ₹25,000 outside EPF, no letters for contract-to-hire staff and a GRC that never met. Days 1 to 30: enrol and reconcile PF, update OSH particulars, issue letters. Days 31 to 60: rebuild the GRC and Internal Committee, check contractors. Days 61 to 90: load the calendar into the HRMS with owners. Take legal advice before any retrenchment, closure, strike response or pay cut. Employees’ side: PF and ESI rights of employees.

Frequently asked questions

What is the Labour Codes compliance checklist for employers in 2026?

It covers registrations, wage dates, the 50% wage definition, EPF and ESI deposits, gratuity, standing orders, notices of change, appointment letters, working hours and POSH. The Codes apply from 21 November 2025 and the Central Rules from May 2026. Employers must also enrol staff newly covered by the ₹25,000 EPF ceiling from 17 September 2026.

Are appointment letters compulsory under the Labour Codes?

Yes. Section 6(1)(f) of the OSH Code requires a letter of appointment for every employee in the prescribed format. Staff in service on 21 November 2025 were to receive letters within three months, so any gap is overdue.

Can a first labour law lapse be settled without prosecution?

Often. Under section 56 of the Code on Wages, offences punishable with fine only can be compounded at 50% of the maximum fine unless repeated within five years.

When must full and final settlement be paid under the new Labour Codes?

Wages due on removal, dismissal, retrenchment or resignation must be paid within two working days (Code on Wages s.17(2)). Gratuity is due within 30 days of becoming payable.

Quick quiz

To turn this Labour Codes compliance checklist for employers into a working calendar, see Labour Codes for HR Managers (₹599), a Lexfolio certificate of completion, not a professional qualification.

Sources

• Code on Wages, 2019: ss.17, 18, 19, 39, 50, 56; Code on Wages (Central) Rules, 2026
• Code on Social Security, 2020: ss.56, 67, 133; S.O. 5109(E), 17 September 2026
• Industrial Relations Code, 2020: ss.4, 28, 40, 70, 83; IR (Central) Rules, 2026
• OSH Code, 2020: ss.3, 6, 32; OSH (Central) Rules, 2026, Rule 69

This page is for education and general information, not legal advice for a specific case. Law as on 31 October 2026.