“India’s Four Labour Codes Come into Force (21 Nov 2025): A New Era for Worker Rights and Business Compliance”

Introduction

On 21 November 2025, the Government of India officially implemented four landmark labour codes – namely 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 – thereby consolidating 29 existing central labour laws.

Reform.exe — Government of India

This reform marks one of the biggest overhauls of India’s labour‐law regime since independence. It is aimed at simplifying compliance, boosting worker welfare, aligning with modern work forms (gig, platform, contract), and strengthening India’s “Aatmanirbhar” labour ecosystem.

In this article I will break down:

  1. Why the reform was required (context)
  2. Key features of the Codes (what changes)
  3. Implications for companies, directors, workers
  4. Viewpoints – opportunities and challenges
  5. Practical compliance checklist for companies
  6. My commentary for you (as CS/Company Law professional)
  7. Conclusion

1. Why Reform Was Necessary

  • Many existing labour laws in India date back to the pre-independence or early post‐independence era (1930s-1950s), when work-contexts, forms of employment, industrial structure, regulatory burden were very different.
  • A large number of laws were fragmented: overlapping roles, multiple registers/licenses/returns, different definitions across statutes. This created compliance burden for employers, as well as gaps in protection for many workers.
  • The world of work has changed: rise of gig/platform work, fixed‐term/contract workers, migration across states, women participation, new sectors (digital/AV) etc. The old laws were not uniformly equipped to deal with these shifts.
  • From an ease-of-doing-business and formalisation perspective, the Government desired a streamlined, uniform labour‐law ecosystem. According to a report, with these reforms the formal share of workforce could rise significantly (e.g., an estimate: additional 7.7 million jobs, 1.3% unemployment drop).

  • Thus the consolidation into four Codes seeks to modernise regulatory architecture, reduce complexity and expand protection.

2. Key Features of the Four Labour Codes

Here is a breakdown of each Code and what the major changes are (with special focus on corporate/CS/boardroom relevance).

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Laws Unified

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% Workforce with Social Security

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% Drop in Unemployment (Expected)

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Million Jobs to be Created

a) Code on Wages, 2019

  • Consolidates: Payment of Wages Act, 1936; Minimum Wages Act, 1948; Payment of Bonus Act, 1965; Equal Remuneration Act, 1976.
  • New/Enhanced elements:
    • A statutory right to minimum wages for all workers (across industries/regions) – moving beyond “scheduled employment” concept.
  • Establishment of a National Floor Wage that states cannot go below.
  • Mandatory written appointment letter (for transparency and proof of employment terms).
  • Timely payment of wages, prohibition of unauthorised wage deductions etc.
  • Equal remuneration for equal work – including gender neutrality and inclusion of transgender persons.

b) Industrial Relations Code, 2020

  • Consolidates several laws: Trade Unions Act, 1926; Industrial Disputes Act, 1947; Industrial Employment (Standing Orders) Act, 1946 etc.
  • Key changes:
    • The threshold for prior government approval for layoffs/closures has been increased from 100 workers to 300 workers in an establishment.
  • Recognition of fixed‐term workers and their rights (including benefits).
  • Streamlined dispute resolution: provisions for Industrial Tribunals, direct access in some cases.
  • Definition of “strike” is replaced/augmented by “mass casual leave” (where >50% of workers take casual leave, it may be treated as strike).

c) Code on Social Security, 2020

  • Aims to cover organised, unorganised, gig & platform workers, migrant workers, fixed‐term workers, etc.
  • Key features:
    • Social security benefits for gig & platform workers introduced (definitions of “gig work”, “platform work”, “aggregators”).
  • Universality in coverage, portability across states.
  • Expanded coverage of schemes (employee state insurance, gratuity after shorter service, pension, maternity, etc.).
  • Single registration/licensing model being pushed.
  • Formal recognition of new employment forms.

d) Occupational Safety, Health and Working Conditions (OSHWC) Code, 2020

  • Consolidates ~13 older Acts relating to factories, mines, plantations, construction, etc.
  • Major provisions:
    • Uniform working hours: weekly cap of 48 hours, daily up to 8‐12 hours with overtime.
  • Free annual health check‐ups for workers above age 40.
  • Women workers permitted to work night shifts in all types of establishments (with consent and safety).
  • Mandatory safety committees, harmonised standards, single license/registration in many cases.
  • Improved protections for hazardous industry workers, plantations, migrant labour etc.

3. Implications for Companies, Boards & Practitioners

As someone working in the Company Law / CS / regulatory domain, here are the immediate compliance and strategic implications:

For Companies / Boards

  • Review HR practices immediately: appointment letters, wage structures, minimum wages, overtime policies, fixed‐term contracts.
  • Contracts & fixedterm employment: Fixed-term employees will now get many of the benefits of permanent staff (leave, medical, social security) in many cases. Make sure contracts are re-aligned.
  • Single registration / licence regime: Companies operating across states or contracting may need to streamline licensing/registration under the codes.
  • Gig/platform operations: If your business uses gig/contract/platform workers, you must assess implications (social security contributions by aggregator, UAN portability etc.).
  • Safety/hours compliance: Ensure that working hours, overtime, health checkups, safety committees etc are in place. For example, providing annual health checkup for workers over 40 or in hazardous work.
  • Wage payments: Timely payments enforced. Written agreement terms crucial. Minimum wage coverage now across industries. Non-compliance risk increases.
  • Women workforce: Night shifts, equal pay, safety measures now mandated – companies must update shift policies, safety protocols, grievance redressal mechanisms.
  • Industrial relations / dispute risk: The raise of thresholds for permission for layoffs may reduce some regulatory burden, but trade unions are sceptical—companies may still face enhanced inspections or vigilance.

For Practitioners/CS/Firm (like your audience)

  • This is a rich subject for your YouTube content: you can make a video series on each Code, its clauses, compliance checklist, comparison of ‘old law vs new Code’.
  • Prepare client advisory notes: many companies will seek help to align their employment contracts, HR policies, payroll systems.
  • Link with your Company Law teaching/training: highlight how the changes affect MOAs/AOAs (object clauses relating to business operations using gig workers, contract labour), board resolutions (on safety committees), and disclosures.
  • Use your GST/Income-tax stance: though these codes are labour exclusively, there may be indirect tax / cost implications (higher social security contributions, payroll cost) and your clients may want the holistic view.
  • Use visuals & tables for social media: e.g., “Before vs After labour ecosystem” table (as in the PIB release).

4. Viewpoints – Opportunities & Challenges

Opportunities

  • From a worker welfare perspective, many gaps are filled: gig workers, platform workers, fixed-term workers, women working night shifts, universal minimum wages, portability of benefits. This is a significant step for social justice and broadening the formal economy.
  • For businesses, simplification of multiple overlapping laws into codes helps clarity. Single registration/licence and uniformity across states may reduce compliance cost over medium term.
  • Formalisation of workforce may improve productivity, retention, morale and lead to stronger employer-brand outcomes. A study estimated formal workforce could rise by ~15% with implementation.
  • Aligning with global labour standards may encourage more investment, support India’s push for manufacturing and employment in the “Aatmanirbhar Bharat” vision.

Challenges & Criticisms

  • Trade unions and workers’ groups have flagged concerns: the higher threshold for regulatory oversight (300 workers) may reduce protections in many establishments.
  • Implementation & rule-making details are still to be fully notified in many states; until then, there can be ambiguity about transitional provisions.
  • For small businesses and unorganised sector, cost of compliance (wages, social security, health checks) may increase, at least in the short term. Some economists warn of short‐term strain. Reuters
  • Real-world enforcement, especially in migrant, informal, contract worker segments, remains a challenge; bridging intention vs on-ground delivery will take time.
  • States have labour as concurrent subject; state rules/notifications will matter. Some states may lag or have local issues in implementation.
  • Change management for companies: HR systems, payroll, contracts, record-keeping will all require adjustment. That may mean cost and time.

5. Practical Compliance Checklist for Companies (What to Do)

Here’s a high-level action-plan for companies/boards/CS firms you can share with your clients or students:

No.AreaImmediate Action
1HR Contract & Appointment LettersEnsure all workers (including contract/fixed-term/gig) have written appointment letters specifying designation, wage, terms.
2Minimum Wage & Floor Wage ComplianceCheck that current wage structure meets/exceeds new minimums (state + national floor); update payroll accordingly.
3Payroll/Payment TimelinessEnsure wages are paid timely, overtime calculation, no unauthorised deductions; update software/process.
4Fixed-Term / Contract WorkersReview status of fixed-term employees: ensure statutory benefits entitlement (leave, medical, social security).
5Social Security CoverageMap workforce (organised/unorganised/gig/platform); verify contributions for PF/ESI/social security; portability of benefits across states.
6Working Hours & OvertimeAlign working hours to maximum 48 hours/week as per code; daily up to 8-12 hours; overtime properly compensated.
7Safety / Health RegulationsFor establishments (especially hazardous/large), ensure annual health check-ups (age>40), safety committees, protective equipment, welfare facilities.
8Women Workers / Night Shift PoliciesReview policies permitting women night shifts (with voluntary consent and safety); equal pay for equal work; grievance redressal committees.
9Single Registration & LicensingInvestigate whether your state requires migration of licences/returns into single licence/return regime; plan transition.
10Industrial Relations / Lay-offsIf workforce >300 or restructuring is contemplated, check new thresholds and procedures under Industrial Relations Code.
11State Rules & NotificationsMonitor your state labour department’s notifications and implementation rules (since Codes require state rules too).
12Communication & TrainingUpdate internal policies/manuals; conduct training for HR/management; communicate changes to employees; keep records.

You may want to develop a sample checklist or matrix for your clients and upload it as a PDF, or make a short video segment on “Top 5 Compliance Pitfalls under the new Codes”.

6 My View

As a CS/Company-Law professional and educator for CS Executive students, here are some additional thoughts you can share in your video/post:

  • Integration with Company Law: While these are labour laws, they will impact company’s board disclosures, director’s oversight (especially in large companies) – e.g., working conditions, social security contributions, corporate social responsibility overlaps, HR governance. This is a good moment to emphasise the role of the company secretary in ensuring compliance, internal audits, reporting, governance.
  • Change in Contract Labour Landscape: Many businesses use contract/fixed-term/gig workforce. The new Codes make it clear that benefits can’t be sidestepped; thus business model implications are real. This links with your teachings on “Setting up business entities and closure” – labour cost, workforce mix, contract structures will need to be revisited.
  • Digital Economy & Gig Workers: For firms in platform economy / digital media / IT/ITES (which your audience may include) – this is huge. Recognition of “gig work”, definition of “aggregator”, social security coverage – these were not there in older laws. You can do a separate module on digital workforce compliance under the Codes.
  • Transitional Phase & State-Wise Variation: While the Codes took effect on 21 Nov 2025, many of the rules/regulations from States remain to be notified. So the next 12-18 months will be a transition period. This is a teaching point: “Be alert but flexible; monitor state notifications”.
  • Opportunity for your Firm and Channel: This reform provides you a content-goldmine
  • Create a video series: “Labour Code 1 – Code on Wages”, “Labour Code 2 – IR Code”, etc.
  • LinkedIn posts: share “Before vs After” tables, infographics, quick compliance tips.
  • Advisory write-ups: for companies wanting to streamline workforce policy, you can offer your firm’s services.
  • Caveat / Balanced View: It’s important to present a balanced view. While many benefits are promised, actual on-ground enforcement, clarity of rules, state implementation will determine how effective the Codes are. Some critics say the Codes may tilt slightly towards employer flexibility. Encourage your audience to adopt a proactive, not reactive, mindset.

7. Conclusion

The implementation of the four Labour Codes on 21 November 2025 marks a paradigm shift in India’s labour-law architecture. For workers, it opens doors to better protection, formalisation, social security, equal opportunities. For businesses and compliance professionals, it offers both challenge and opportunity – requiring timely alignment, but also offering clearer, unified regulation.

For your audience (company secretaries, business owners, HR departments, compliance professionals), the message is clear: This is not a “wait-and-see” reform. The wave has begun. Early movers who align policies, contracts, payroll, safety systems will be ahead in governance, risk mitigation, and will also send the right message to stakeholders (employees, regulators, investors).

As you prepare your video/presentation/post: you may consider using visually engaging formats – e.g., “Top 10 changes that every employer must know”; “Checklist for HR in 2026 under the new Labour Codes”; “Impact on gig/platform workforce: what IT/ITES companies must do”.

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