Contractors & audits

Labour Codes advisory services

The four Labour Codes replaced 29 central labour laws on 21 November 2025, with new penalties. We move your wage structure, contracts and HR policies across before a wage claim or inspection does it for you.

  • Wage structures under the 50% rule
  • Penalty exposure mapped and closed
  • PF, gratuity and bonus impact
  • State rules tracked as notified
Labour Codes advisory: still life
ISO 9001:2015 Reply in 2 working hours

The four Codes

Which old laws each Code replaced

All four Codes took effect on 21 November 2025. Central rules under each were notified on 8 May 2026, and the states are still notifying theirs. The fourth Code's full name is the Occupational Safety, Health and Working Conditions Code, 2020.

29→4

central labour laws, brought into 4 Labour Codes

4laws replaced

Code on Wages, 2019

  • Payment of Wages Act, 1936
  • Minimum Wages Act, 1948
  • Payment of Bonus Act, 1965
  • Equal Remuneration Act, 1976
3laws replaced

Industrial Relations Code, 2020

  • Trade Unions Act, 1926
  • Industrial Employment (Standing Orders) Act, 1946
  • Industrial Disputes Act, 1947
9laws replaced

Code on Social Security, 2020

  • Employees' Compensation Act, 1923
  • Employees' State Insurance Act, 1948
  • Employees' Provident Funds and Miscellaneous Provisions Act, 1952
  • Employment Exchanges (Compulsory Notification of Vacancies) Act, 1959
  • Maternity Benefit Act, 1961
  • Payment of Gratuity Act, 1972
  • Cine-Workers Welfare Fund Act, 1981
  • Building and Other Construction Workers' Welfare Cess Act, 1996
  • Unorganised Workers' Social Security Act, 2008
13laws replaced

OSH Code, 2020

  • Factories Act, 1948
  • Plantations Labour Act, 1951
  • Mines Act, 1952
  • Working Journalists and Other Newspaper Employees (Conditions of Service and Miscellaneous Provisions) Act, 1955
  • Working Journalists (Fixation of Rates of Wages) Act, 1958
  • Motor Transport Workers Act, 1961
  • Beedi and Cigar Workers (Conditions of Employment) Act, 1966
  • Contract Labour (Regulation and Abolition) Act, 1970
  • Sales Promotion Employees (Conditions of Service) Act, 1976
  • Inter-State Migrant Workmen (Regulation of Employment and Conditions of Service) Act, 1979
  • Cine-Workers and Cinema Theatre Workers (Regulation of Employment) Act, 1981
  • Dock Workers (Safety, Health and Welfare) Act, 1986
  • Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996

Grouping as published by the Press Information Bureau for the Ministry of Labour & Employment on 21 November 2025. Rules under each Code are framed by the Centre and by each state, so the detail can differ from state to state.

The cost of non-compliance

What the Codes charge for getting it wrong

The Codes replaced old penalties with new ones, most of them higher. These are the figures behind the changes we plan with you.

Exposure under the law

  1. Up to 10×

    the claim, as compensation

    01Wages below the new definition

    Paying less than due under the Code on Wages carries a fine of up to ₹50,000, and a wage claim can bring compensation of up to ten times the amount found due.

    Code on Wages, 2019, s.54(1)(a) and s.45(2)

  2. ₹1–10 lakh

    per contravention

    02Lay-off, retrenchment or closure without permission

    Where the Code requires government permission, acting without it carries this fine. A repeat can bring ₹5 lakh to ₹20 lakh or six months' imprisonment.

    Industrial Relations Code, 2020, s.86(1) and (2)

  3. ₹50,000–2 lakh

    plus ₹2,000 a day

    03Standing orders not submitted

    For an employer who fails to submit draft standing orders, or changes them outside the Code's procedure.

    Industrial Relations Code, s.86(10)

  4. Up to 1 year

    or a ₹50,000 fine

    04Gratuity not paid

    Failing to pay gratuity an employee is entitled to, including a fixed-term employee under the new rules.

    Code on Social Security, 2020, s.133(ii)

  5. ₹2–3 lakh

    plus up to ₹2,000 a day

    05Any other OSH contravention

    The general penalty for a contravention of the OSH Code, its rules or an order, payable by the employer or principal employer.

    OSH Code, 2020, s.94

Why NK One

Every filing, zero penalties.

Every change the Codes require of your wage structure, contracts, policies and filings is planned and completed on time, state by state, with a partner on the file.

  • Zero-penalty guarantee

    No late fees, no interest, no surprise demands on anything we file for you. Every due date is tracked by people who have done this for 20 years.

  • Direct partner access

    Since 2007, clients speak to the partners who run NK One, not a new compliance executive learning on your account.

By the numbers

What the Codes cut from the rulebook

The Ministry of Labour & Employment's own count, comparing the 29 earlier laws with the four Codes. Less paperwork does not settle the harder questions: the wage definition, the gratuity base and each state's rules still have to be worked out for your organisation.

Rules
351down from 1,436
Counted across the four Codes, against the rules framed under the 29 laws they replaced.
Forms
73down from 181
Fewer forms to file and keep, with compounding and improvement notices introduced for the first time.
Registers
8down from 84
The registers an establishment has to maintain. The Code on Social Security also requires records, registers and returns to be kept electronically.
Returns
1electronic return, in place of 31
Eight separate registrations, under laws such as the Factories, Contract Labour, ESI and EPF Acts, become one. Four licences become a single licence.

Before and after

What changes for employers

Six changes that reach payroll and HR first. Rules, and some limits, vary by state, so check your state's position before acting on any one of them.

Definition of wagesUnder the old ActsEach of the old Acts defined wages in its own way.Under the Labour CodesOne definition. Excluded components cannot exceed 50% of total pay, and the excess is added back as wages.
GratuityUnder the old ActsWorked out on basic pay and DA, which in many structures were a small part of total salary.Under the Labour CodesWorked out on the revised wage definition, so the base and the employer's liability can rise.
Fixed-term employeesUnder the old ActsGratuity only after five years of continuous service, as for other employees.Under the Labour CodesGratuity after one year of service under the contract, with wages and benefits on par with permanent staff.
Minimum wagesUnder the old ActsThe Minimum Wages Act covered only the scheduled employments.Under the Labour CodesEvery employee has a statutory right to minimum wages, and no state can fix them below the floor wage set by the Centre.
Standing ordersUnder the old ActsRequired from 100 workers.Under the Labour CodesRequired from 300 workers.
Contract labour (OSH Code, formerly CLRA)Under the old ActsThe Act applied from 20 contract workers, with a licence for each work order.Under the Labour CodesApplies from 20 contract workers. Contractors can hold an all-India licence valid for five years.

Where to start

Four areas to review first

These are the areas most employers have to act on early. They are not the whole list: what applies to you depends on your industry, workforce and the state rules in force where you operate.

An HR head and an advisor reviewing a salary structure printout together.
The effect of the new wage definition, worked out component by component.
  • The wage structure

    Of the four Codes, the Code on Wages moves salary cost fastest. Check how far your excluded allowances run above half of total pay, and what the excess adds to PF, gratuity and bonus.

  • Appointment letters

    The OSH Code requires an appointment letter for every employee, setting out the job, the wages and social security. Older letter formats need to be revised.

  • Contract labour

    Engaging contract labour now has to fit the OSH Code, including its approach to core and non-core activities. If a contractor fails to pay wages, the principal employer has to pay them.

  • Gig and platform workers

    The Code on Social Security covers gig and platform workers for the first time. Aggregators contribute 1 to 2% of annual turnover, capped at 5% of what they pay these workers.

Scope of service

Our advisory work, in four parts

From reading your documents against the Codes to the roll-out across every location.

A senior advisor presenting to an HR leadership team in a boardroom.
HR policies and wage structures read against the four Codes.
  1. File01

    Policy and contract review

    Your documents, read against the Codes and the notified rules.

    • HR policies, handbooks and employment letters audited in detail
    • The effect of the Codes on existing contracts and practices
    • A compliance report on alignment with the notified rules, and the amendments needed
  2. File02

    Wage structuring

    Where the Code on Wages costs money.

    • Financial effect of the revised wage definition on your pay structure
    • PF, gratuity and bonus impact, component by component, including exclusions
    • Remedial steps that reduce the cost and stay within the law
  3. File03

    Transition and roll-out

    From the gap analysis to the new framework in use.

    • Compliance gaps found during the move to the Codes
    • An implementation roadmap for your organisation
    • Payroll, compliance and HR processes aligned
    • Clear, compliant communication to employees
  4. File04

    State-wise applicability

    For organisations with more than one location or entity.

    • Applicability tracked from draft rules, notifications and timelines in each state
    • Consistent treatment across locations, entities and employee categories

FAQ

Questions about Labour Codes advisory

Can't find your answer? Ask us on WhatsApp and we'll reply within 2 working hours.

What are India's four Labour Codes?

The Code on Wages, 2019, the Industrial Relations Code, 2020, the Code on Social Security, 2020 and the Occupational Safety, Health and Working Conditions Code, 2020. Together they replace 29 central labour laws. All four took effect on 21 November 2025.

Are the Labour Code rules fully in force?

The Codes took effect on 21 November 2025, and central rules under all four were notified on 8 May 2026. States notify their own rules separately, and several are still doing so. The position can therefore differ from one state to the next.

How does the Code on Wages affect salary structures?

It sets one definition of wages across India. The listed exclusions cannot exceed 50% of total remuneration, and anything above that is added back to wages for statutory purposes. PF, gratuity and bonus are worked out on that figure, so many salary structures need review.

How do the Labour Codes change gratuity?

Gratuity is now worked out on the revised wage definition, including the 50% limit on exclusions. Where basic pay and DA are a small share of salary, the gratuity base and the employer's liability can rise. Fixed-term employees qualify after one year of service under the contract, instead of five years.

What does the Industrial Relations Code change for employers?

It covers union recognition, retrenchment, lay-offs, strikes and the settling of disputes. Standing orders now apply from 300 workers instead of 100. The limit for government approval of lay-off, retrenchment and closure has also risen from 100 to 300 workers, and states can raise it further.

What changes for contract labour under the OSH Code?

The contract labour provisions apply from 20 contract workers, as under the Contract Labour (Regulation and Abolition) Act. A contractor can hold an all-India licence valid for five years in place of a licence for each work order. The principal employer must provide welfare facilities to contract workers and pay their wages if the contractor does not.

What does a Labour Codes consultant do for us?

We interpret the Code requirements that apply to you, audit your HR policies and contracts, and run a gap analysis. We then build an implementation roadmap, covering wage restructuring, appointment letters, standing orders and contract labour where relevant. For our fee, send us an enquiry with your locations and headcount.

A calm office reception at dusk

Enquiry

Talk to a compliance expert

Share your states and headcount, and we will get back to you within 2 working hours.

Send an enquiry

A few details. We reply within 2 working hours.

We use your details only to reply to this enquiry. Privacy notice

Call WhatsAppEnquire