New Labour Codes 2026: Employer Readiness Checklist

A 15 slide readiness checklist for employers in India, current as at September 2026.

The four labour codes commenced on 21 November 2025 and the draft Central Rules were published on 8 May 2026. Most compliance checklists still in circulation were written before that date and are now wrong on wage structure, overtime and gig worker coverage.

What this deck walks through:

1. The 50 per cent wage definition and what it does to provident fund, gratuity and cost to company
2. Working hours of 8 in a day and 48 in a week, overtime at twice the ordinary rate, and the 144 hour quarterly ceiling
3. The 90 day and 120 day thresholds that pull gig and platform workers into social security
4. Annual health check-ups for workers above the age of 40
5. Gratuity after one year of service for fixed term employees
6. Single licence and single registration in place of filings under 29 separate laws
7. A 12 point action checklist to work through before the rules are notified

Every figure is sourced from the codes or the draft Central Rules, and the sources are listed on the final slide.

Put together by the compliance team at Digiliance in Gurgaon, Haryana. Background on the changes: https://digiliance.in/new-labour-codes/statutorychanges

Transcript

1. India's New Labour Codes 2026: Employer Readiness Checklist A 12-point compliance checklist for Indian HR, payroll and plant teams Digiliance | Labour law compliance software since 2006 | 83 acts, 416 rules, 28 states and union territories | https://digiliance.in
2. Where Things Stand Today Effective Date The four labour codes took effect on 21 November 2025. The Central Rules under them were notified on 8 May 2026. This is live law, not a proposal. Scope of Change The four codes replace 29 existing central labour laws. Source: Press Information Bureau, Ministry of Labour and Employment.
3. The Four Codes 1 2 Code on Wages, 2019 Industrial Relations Code, 2020 Consolidates laws relating to wages, bonus, and minimum Governs trade unions, conditions of employment, and wage across all sectors. industrial disputes. 3 Code on Social Security, 2020 4 Covers provident fund, gratuity, ESIC, maternity benefit and Occupational Safety, Health and Working Conditions Code, 2020 gig workers. Sets standards for safety, health and working conditions across establishments.
4. The Change That Moves Your Payroll Cost: The 50 Per Cent Wage Rule The Rule Excluded from Wages Basic pay, dearness allowance and House rent allowance retaining allowance together must Overtime be at least 50 per cent of an employee's total remuneration. Where they fall short, the shortfall is reclassified as wages. Effect Commission Employer provident fund and pension contributions Gratuity Retrenchment compensation A higher wage base raises Travel allowance provident fund contributions, Reimbursement of work calculated at 12 per cent of wages, and raises gratuity liability. expenses
5. Working Hours and Overtime 8 48 Hours per Day Hours per Week Normal working day limit Weekly ceiling on working hours 2x 144 Overtime Rate OT Cap per Quarter Overtime is paid at twice the ordinary rate Maximum overtime hours per quarter Minimum wage is fixed as a daily rate, then converted to an hourly rate by dividing by 8, or a monthly rate by multiplying by 26.
6. Appointment Letters Are Now Mandatory Every worker must receive a written appointment letter in the prescribed format with the prescribed particulars. This is the most common gap found in Indian establishments, and it is now a statutory requirement rather than good practice. Issuing appointment letters in the prescribed format is no longer optional. Non-compliance is a statutory breach under the new codes.
7. Gratuity for Fixed-Term Employees What Has Changed Before After Gratuity after 5 years of service Gratuity after 1 year under contract Fixed-term employees qualify for gratuity after one year of service under the contract, not five. Action Required Review every fixed-term contract on your books and re-provision accordingly.
8. Gig and Platform Workers Gig and platform workers are brought inside social security coverage. 1 2 Registration Workers register through an Single Aggregator Threshold Aadhaar-based government 90 days with a single portal. aggregator triggers eligibility. 3 Multiple Aggregator Threshold 120 days across multiple aggregators triggers eligibility. If you engage delivery, field or platform workers, you are now in scope.
9. ESIC and Health Pan-India Coverage ESIC coverage is extended pan-India. Hazardous Processes Coverage is mandatory for establishments with even one employee engaged in hazardous processes. Annual Health Check-Up Employers must provide a free annual health check-up to every worker above the age of 40.
10. Women at Work Night Work Permitted Women are permitted to work at night and in all types of work across all establishments. Conditions Apply The Central Rules set the conditions that apply to employing women on night shifts. Put those safeguards in writing before you roster anyone.
11. Contractors and Multi-State Operations Single Licence for Multi-State Contractors A contractor operating in more than one state can hold a single licence. Action for Principal Employers Principal employers should re-collect contractor documentation against the new licensing position rather than assuming old registrations carry over.
12. What Gets Simpler Single Registration PAN-India Single Licence Single registration replaces multiple overlapping filings across A single PAN-India licence replaces the patchwork of state-by- different acts and authorities. state licences previously required. Single Return Universal Minimum Wage A single return replaces multiple overlapping filings, reducing Every worker now has a statutory right to a minimum wage, administrative burden significantly. regardless of sector or establishment type.
13. The 12-Point Readiness Checklist 1 Restructure salary Restructure salary so basic, DA and retaining allowance reach 50 per cent of total remuneration. 2 Re-forecast PF and gratuity cost Re-forecast provident fund and gratuity cost against the new wage base. 3 Issue appointment letters Issue appointment letters in the prescribed format to every worker. 4 Re-provision gratuity for fixed-term staff Re-provision gratuity for fixed-term staff at one year. 5 Map working hours and overtime Map working hours and overtime against the 8 and 48 hour limits. 6 Build an overtime register Build an overtime register that tracks the 144 hour quarterly cap. 1 Register gig and platform workers Register gig and platform workers and track the 90 and 120 day thresholds. 2 Confirm ESIC coverage Confirm ESIC coverage, including any hazardous-process headcount. 3 Schedule annual health check-ups Schedule annual health check-ups for all workers above 40. 4 Document night-shift safeguards Document night-shift safeguards before rostering women on nights. 5 Re-verify contractor licences Re-verify contractor licences under the single-licence position. 6 Move to single registration, licence and return Move to single registration, licence and return, and retire the old filings.
14. How Digiliance Helps Digiliance is a labour law compliance software platform used by more than 500 organisations since 2006. Compliance Calendar Document Repository Compliance calendar mapped to your registrations and states. Document repository for licences, registers, challans and returns. Task Ownership Alerts Task ownership, so every filing has a named person and a due Alerts for minimum wage revisions and statutory changes. date. Contractor Compliance Module Comprehensive Coverage Contractor compliance module for vendor documents and Covering 83 acts, 416 rules and 28 states and union territories. audits.
15. Sources and Contact Sources Contact and Further Reading Press Information Bureau releases of 21 November 2025, Read more on the new labour codes and statutory changes: Ministry of Labour and Employment https://digiliance.in/new-labour-codes/statutorychanges Central Rules notified 8 May 2026 Website: https://digiliance.in Code on Wages 2019 Code on Social Security 2020 Industrial Relations Code 2020 Occupational Safety, Health and Working Conditions Code 2020 Digiliance, by Spectra Outsource Solutions Pvt. Ltd., Gurgaon, Haryana