New Labor Codes 2025 Readiness Checklist

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New Labor Codes 2025 Readiness Checklist

Company Name:

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HR Head / Compliance Lead:

Target Readiness Date:

Code on Wages, 2019 Readiness

Review the new definition of 'wages' under Section 2(y) of the Code on Wages.

The Code on Wages, 2019 introduces a unified definition of 'wages' where allowances (HRA, conveyance, etc.) exceeding 50% of total remuneration are deemed wages. Analyse your current salary structure and ensure that the basic wages plus DA component is at least 50% of the gross remuneration to avoid reclassification.

Restructure CTC and salary components to comply with the 50% wages floor.

If allowances (HRA, special allowance, conveyance, etc.) exceed 50% of the CTC, the excess will be treated as 'wages' for PF, ESI, gratuity, and bonus calculations. Model the impact on employer cost and employee take-home pay and restructure salary components accordingly.

Prepare for a national floor wage and state minimum wages above the floor.

Under Section 9 of the Code on Wages, the Central Government will fix a national floor wage. No state can fix a minimum wage below the floor. Track the notification of the floor wage rate and assess impact on wage budgets, especially for low-wage categories and states with currently lower minimum wages.

Ensure overtime continues at double the ordinary rate.

Section 14 of the Code on Wages mandates overtime wages at twice the normal rate of wages. Verify that payroll systems calculate overtime correctly under the new definition of wages and adjust any overtime policies or cap mechanisms.

Update the wage payment timeline to comply with new provisions.

Under Section 17, wages must be paid by the 7th of the succeeding month (for establishments with fewer than 1,000 workers) or the 10th (for larger establishments). Ensure your payroll processing cycle can meet these timelines under the new Code.

Code on Social Security, 2020 Readiness

Understand the expanded scope of social security coverage.

The Code on Social Security, 2020 extends social security benefits to gig workers, platform workers, and unorganised sector workers. If your organization engages gig or platform workers (e.g., delivery partners, freelancers), plan for potential contributions to the Social Security Fund as notified by the Central Government.

Prepare for revised wage ceilings for EPF and ESI coverage.

The Code empowers the Central Government to revise wage ceilings for PF (currently INR 15,000) and ESI (currently INR 21,000) through notification without legislative amendment. Monitor notifications for any increase in these ceilings, which will expand the coverage pool and increase employer costs.

Plan for Aadhaar-based registration and compliance through a single portal.

The Code envisages a unified web portal for registration, filing returns, and making contributions for EPF, ESI, gratuity, and maternity benefits. Ensure Aadhaar linkage for all employees and prepare IT systems for API integration with the proposed unified portal.

Review gratuity provisions including eligibility for fixed-term employees.

Under the Code on Social Security, 2020, fixed-term employees are entitled to gratuity on a pro-rata basis even if they have not completed 5 years of continuous service. Assess the impact on gratuity provisioning for organizations that hire fixed-term contract workers.

Assess maternity benefit provisions under the Code.

The Code consolidates maternity benefit provisions (previously under the Maternity Benefit Act, 1961). Benefits include 26 weeks of paid leave for the first two children and 12 weeks for subsequent children. Ensure payroll systems are configured to handle maternity leave calculations under the new Code provisions.

Occupational Safety, Health and Working Conditions (OSH) Code, 2020 Readiness

Determine if the establishment is covered under the OSH Code.

The OSH Code, 2020 applies to establishments employing 10 or more workers (with power) or 20 or more workers (without power), mines, docks, and building and construction work. It subsumes 13 old Acts including the Factories Act, 1948 and the Contract Labor Act, 1970. Verify which provisions apply to your organization.

Prepare for a single registration instead of multiple Act-specific registrations.

The OSH Code introduces a unified registration for all covered establishments through an online portal. Organizations currently holding registrations under the Factories Act, Contract Labor Act, ISMW Act, etc. will need to migrate to the new unified registration system.

Review and update contract labor compliance provisions.

The OSH Code retains the requirement for registration of principal employers and licensing of contractors but introduces a threshold of 50 workers (instead of 20 under the Contract Labor Act). Review existing contractor arrangements and determine if any fall below the new threshold.

Ensure statutory welfare facilities meet the new Code's requirements.

The OSH Code mandates facilities like canteens (for 100+ workers), crches (for 50+ workers), first aid, adequate lighting, ventilation, and sanitation. Conduct a gap assessment of current welfare provisions against the Code's requirements and plan necessary upgrades.

Prepare for annual health examinations for employees in hazardous processes.

Under the OSH Code, employers engaged in hazardous processes must arrange free annual health examinations for workers. Identify if any of your operations involve hazardous processes as defined in the Code and set up health examination protocols.

Update appointment letters for fixed-term employees under the OSH Code.

The OSH Code formally recognises fixed-term employment and mandates that fixed-term workers receive the same wages, hours, allowances, and benefits (including gratuity on a pro-rata basis) as permanent workers performing similar work. Update appointment letter templates to reflect these entitlements.

Industrial Relations (IR) Code, 2020 Readiness

Review the revised thresholds for standing orders applicability.

The IR Code, 2020 raises the threshold for mandatory standing orders from 100 to 300 workers. If your establishment has between 100 and 300 workers, you may no longer be required to have certified standing orders, though it is advisable to maintain them voluntarily as good practice.

Understand new requirements for hire-and-fire with government approval.

Under the IR Code, establishments with 300 or more workers must obtain prior government permission before lay-off, retrenchment, or closure (raised from 100 under the old Industrial Disputes Act). Establishments with fewer than 300 workers gain more flexibility in workforce adjustments.

Prepare for the revised trade union recognition framework.

The IR Code introduces a statutory framework for trade union recognition. A trade union with 51% or more membership will be recognised as the sole negotiating union; if none qualifies, a negotiating council of unions with more than 20% membership will be formed. Assess your trade union landscape against these new criteria.

Update the grievance redressal mechanism with the Grievance Redressal Committee.

Under Section 4 of the IR Code, every establishment with 20 or more workers must have a Grievance Redressal Committee comprising equal representation of employer and workers (with at least one woman if the establishment employs women). Constitute or reconstitute the committee as required.

Understand the 14-day strike and lockout notice requirements.

Under the IR Code, workers in all industrial establishments (not just public utility services) must give a 14-day advance notice before going on strike. Similarly, employers must give 14 days' notice before a lockout. Review and update your employee relations policies to reflect this change.

Plan for the reskilling fund contribution upon worker retrenchment.

Under Section 83 of the IR Code, when a worker is retrenched, the employer must contribute an amount equal to 15 days of the worker's last drawn wages to the Worker Re-Skilling Fund. Update your separation cost models and HR budgets to include this new obligation.

Implementation & Change Management

Conduct an impact assessment of all four labor codes on current HR policies.

Map every provision of the four Codes (Wages, Social Security, OSH, IR) against your existing HR policies, employment contracts, payroll configurations, and compliance processes. Identify gaps, cost implications, and areas requiring policy changes. Engage external labor law consultants for a comprehensive assessment.

Update HRIS and payroll systems to accommodate the new wage definition.

Work with your HRIS/payroll vendor to reconfigure wage components, contribution calculations (PF, ESI, gratuity, bonus), and reporting formats. Test the new configurations thoroughly with pilot payroll runs before the Codes come into effect.

Revise employment contracts and offer letters to reflect Code provisions.

Update standard employment contracts, offer letters, and appointment orders to incorporate fixed-term employment clauses, revised notice periods, the new wage structure, and other provisions mandated by the four Codes. Have the updated templates reviewed by legal counsel.

Train HR, payroll, and compliance teams on the new labor codes.

Organise comprehensive training sessions for HR business partners, payroll administrators, and compliance officers on the key changes introduced by the four Codes. Cover topics such as the new wage definition, social security for gig workers, revised thresholds, and the unified compliance portal.

Communicate changes to employees and unions proactively.

Prepare employee communication materials explaining how the new labor codes affect salary structure, take-home pay, social security benefits, and working conditions. For unionised workplaces, engage with trade union leaders early to address concerns and negotiate transitional arrangements.

What Is a New Labor Codes 2025 Readiness Checklist?

A New Labor Codes 2025 readiness checklist is a preparatory guide for employers to align their HR policies, payroll systems, and compliance processes with the four new labor codes enacted by the Indian Parliament: the Code on Wages 2019, the Industrial Relations Code 2020, the Social Security Code 2020, and the Occupational Safety, Health and Working Conditions Code 2020. These codes consolidate and replace 29 existing central labor laws and introduce significant changes to wage structures, social security contributions, and working conditions.

Why HR Teams Need This Checklist

The new labor codes will fundamentally alter how wages are structured, how provident fund and gratuity are computed, how working hours and overtime are managed, and how establishments engage with contract labor and fixed-term employees. The redefinition of wages to ensure basic wages constitute at least 50% of total remuneration will impact take-home pay and employer costs across the board. This checklist helps HR teams prepare systematically rather than scrambling to comply after the codes are notified for implementation.

Key Areas Covered in This Checklist

This checklist covers the impact assessment of the new wage definition on salary structures and CTC components, recalculation of PF, ESI, and gratuity contributions under the revised wage base, alignment of working hours and overtime policies with the new codes, review of standing orders and employment contracts, fixed-term employment framework adoption, social security fund registration for gig and platform workers, and updated compliance reporting requirements. It also covers the transition roadmap from existing laws to the new code-based framework.

How to Use This Free Checklist

Use Hyring's free checklist generator to create a comprehensive New Labor Codes readiness checklist that maps the impact on your organization's payroll, policies, and compliance processes. The Detailed view provides section-by-section guidance across all four codes, while the Brief view focuses on the highest-impact changes. Download and share the checklist with your HR leadership, payroll vendor, and legal counsel to drive a coordinated preparation effort.

Frequently  Asked  Questions

What are the four new labor codes in India?

The four new labor codes are the Code on Wages 2019, the Industrial Relations Code 2020, the Social Security Code 2020, and the Occupational Safety, Health and Working Conditions Code 2020. Together, they consolidate 29 existing central labor laws into a simplified framework. The codes have been enacted by Parliament but require both central and state governments to notify the final rules before they become enforceable, and implementation is expected to be phased.

How will the new wage definition impact salary structures?

Under the Code on Wages, basic wages must constitute at least 50% of the total remuneration, meaning allowances like HRA, conveyance, and special allowances cannot collectively exceed 50% of the gross pay. This will increase the base on which PF, ESI, gratuity, and bonus are calculated, raising employer costs but also increasing employee social security benefits. Organizations that currently structure salaries with a low basic component will need to restructure their compensation significantly.

Will the new labor codes affect provident fund contributions?

Yes, since PF contributions are calculated on basic wages plus dearness allowance, the new wage definition requiring basic to be at least 50% of gross remuneration will increase the PF contribution base for many employees. This means both employer and employee PF contributions will increase in absolute terms. Organizations should model the financial impact on payroll costs and communicate changes to employees proactively.

What changes do the new codes bring to working hours and overtime?

The Occupational Safety, Health and Working Conditions Code allows flexibility in working hours with provision for a four-day work week, provided the total weekly hours do not exceed 48. Overtime limits are capped at 125 hours per quarter, and overtime must be paid at twice the ordinary rate. These provisions give employers more flexibility in scheduling while maintaining employee protections around maximum work hours.

How do the new codes affect fixed-term employment?

The Industrial Relations Code formally recognizes fixed-term employment across all sectors, allowing employers to hire workers for a specific duration based on seasonal or project-based needs. Fixed-term employees are entitled to the same wages, hours, allowances, and benefits as permanent workers doing similar work. Importantly, fixed-term employees are eligible for gratuity on a pro-rata basis even without completing five years of service.

What is the impact on gratuity under the new codes?

Under the Social Security Code, the gratuity calculation base will expand due to the revised wage definition, and fixed-term employees become eligible for pro-rata gratuity irrespective of their tenure. The qualifying period of five years continues for regular employees, but the broader wage base means the gratuity amount for all eligible employees will increase. Organizations should re-estimate their gratuity liabilities and adjust their actuarial provisions accordingly.

Do the new labor codes cover gig and platform workers?

Yes, the Social Security Code 2020 brings gig workers and platform workers under its ambit for the first time. The code provides for the creation of a Social Security Fund funded by contributions from aggregators and platform companies to provide benefits such as life and disability cover, health and maternity benefits, and old-age protection. This is a landmark inclusion that extends social security protections to India's growing gig economy workforce.

When will the new labor codes be implemented?

While all four codes have been passed by Parliament, their implementation requires both central and state governments to frame and notify the rules under each code. As of 2025, several states have published draft rules but the codes have not yet been universally notified for enforcement. Organizations should monitor notifications from the Ministry of Labor and Employment and their respective state labor departments for implementation timelines and begin preparation well in advance.
Adithyan RKWritten by Adithyan RK
Surya N
Fact Checked by Surya N
Published on: 3 Mar 2026Last updated:
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