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Labour Codes in India

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Occupational Safety, Health and Working Conditions Code, 2020 in India

Implementation Steps for the Occupational Safety, Health and Working Conditions (OSH) Code, 2020 in India.The Occupational Safety, Health and Working Conditions Code, 2020 came into force on 21 November 2025. As of January 2026, the Code is operational, but full enforcement depends on final central and state rules (many states have draft rules, with implementation progressing). During transition, provisions from repealed laws may apply where needed.The Code consolidates 13 old laws, applying to establishments with 10 or more workers (including factories, mines, construction sites, plantations, and others). Employers must proactively comply to ensure safe workplaces and avoid penalties.


Key Implementation Steps for Employers

Description Timeline/Requirements Responsible Party
1. Register the Establishment
Apply electronically for single registration via the designated portal (replaces multiple old registrations). Existing establishments must update/register post-enforcement.
Within 60 days of Code applicability (or for new ones, from start). Late applications allowed with fees. Deemed approval if no response.
Employer (via online portal; registering officer appointed by Central/State Government)
2. Obtain Licenses (if applicable)
Single all-India license for contractors (valid 5 years) in sectors like contract labour or hazardous processes.
As prescribed; work-specific for contractors. Principal Employer/Contractor
3. Conduct Gap Assessment & Risk Evaluation
Assess workplace hazards (physical, chemical, biological). Identify risks and implement preventive measures.
Immediate/Ongoing; mandatory for hazardous sectors. Employer, with possible Safety Officer input
4. Appoint Safety Officers & Form Safety Committee
Appoint qualified Safety Officers in high-risk establishments. Form Safety Committees with worker/employer representatives.
For factories (500+ workers), mines (100+), construction (250+), or as notified. Employer
5. Provide Welfare Facilities
Ensure cleanliness, ventilation, drinking water, latrines (separate for genders/transgender), lighting, waste treatment, creche (if applicable), canteen, etc.
As per Central/State standards; ongoing. Employer (principal employer for contract workers)
6. Arrange Health Examinations & Training
Free annual health checks for eligible workers (e.g., hazardous roles or above certain age). Provide safety training and information. Issue appointment letters.
Annual for specified classes; on recruitment/ongoing training. Employer
7. Adhere to Working Hours & Leave
Limit to 8 hours/day, 48 hours/week (with overtime consent at double rate). Provide intervals, spreads, and annual leave.
Immediate compliance. Employer
8. Report Accidents & Diseases
Notify authorities of serious accidents/deaths or notifiable diseases. Maintain registers.
Immediately for serious incidents. Employer
9. File Single Return & Maintain Records
Submit unified annual/single return electronically (replaces multiple old returns).
As per rules; annually or as notified. Employer
10. Monitor State-Specific Rules
Align with final state rules (many states have drafts; some like Gujarat have finalised).
Ongoing; check state labour department portals. HR / Legal Team

Additional NotesEase of Doing Business Features: Single registration, license, and return; deemed approvals reduce delays.


Special Provisions: Enhanced protections for women (night shifts with consent/safety), migrants, contract, and fixed-term workers.


Penalties for Non-Compliance: Fines, imprisonment for serious violations; compounding options available.


Recommendation: Engage HR/legal experts, conduct internal audits, and train staff. Monitor Ministry of Labour & Employment website or state portals for final rules/notifications.


This structured approach ensures compliance, promotes worker safety, and minimises disputes under the new framework.


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