New Labour Codes: Employer Compliance Checklist for 2026

**Alt text:** New Labour Codes: Employer Compliance Checklist for 2026 – SNGSPL guide covering wages, social security, working conditions, registrations, and record keeping
India’s labour law framework has undergone a major change with the implementation of the four Labour Codes. For employers, 2026 is an important year to review payroll structures, employment documentation, statutory registers, contractor compliance, workplace policies and other labour-law obligations. The four Labour Codes consolidate 29 existing central labour laws into four broad areas:
  • Code on Wages, 2019
  • Industrial Relations Code, 2020
  • Code on Social Security, 2020
  • Occupational Safety, Health and Working Conditions Code, 2020
The Government announced that the four Labour Codes became effective from 21 November 2025. Final Central Rules were subsequently notified in May 2026. However, employers must still check whether the relevant Central or State rules apply to their particular establishment because labour-law administration can depend on the nature and location of the business. For businesses, the key question is no longer simply whether the Labour Codes apply. The more important question is: Is your organisation’s HR, payroll and statutory compliance framework ready for the new requirements? This 2026 checklist can help employers identify the major areas that should be reviewed.

1. Review Your Salary and Wage Structure

One of the most important areas under the Labour Codes is the definition of “wages.” The Code on Wages generally includes basic pay, dearness allowance, retaining allowance, special allowance and employer PF within wages, while excluding certain components subject to the statutory framework. The Code also contains a provision requiring certain amounts to be added back to wages when excluded components exceed the prescribed proportion of remuneration. The Ministry of Labour and Employment’s 2026 FAQ also clarifies certain components relevant to the 50% calculation, including treatment of overtime and specified statutory contributions.

Employer checklist:

  • Review the salary structure of employees.
  • Identify the components included in wages.
  • Check whether allowances are structured appropriately.
  • Review the impact on PF and other statutory contributions where applicable.
  • Recalculate statutory benefits where the wage definition affects their computation.
  • Check CTC and payroll structures after applying the applicable rules.
  • Maintain proper documentation for salary revisions.
Employers should avoid changing salary structures based only on generic online formulas. The applicable Central/State rules, employee category and establishment-specific requirements should be considered.

2. Review Appointment Letters and Employment Documentation

Employers should ensure that employees receive appropriate employment documentation containing relevant terms and conditions of employment. The Labour Codes place greater emphasis on standardised employment-related documentation and records.

Employers should review:

  • Appointment letters
  • Employment agreements
  • Job descriptions
  • Salary structures
  • Working hours
  • Leave provisions
  • Probation clauses
  • Notice-period provisions
  • Transfer provisions
  • Confidentiality clauses
  • Disciplinary procedures
  • Statutory benefits
An outdated appointment-letter format may not adequately reflect the organisation’s current employment terms.

3. Check Working Hours, Overtime and Leave Records

Working hours, weekly holidays, overtime and annual leave are important areas covered under the Occupational Safety, Health and Working Conditions framework. The OSH Code includes provisions dealing with daily and weekly working hours, annual leave, overtime, night shifts and maintenance of employment records.

Compliance checklist:

  • Maintain accurate attendance records.
  • Track working hours.
  • Maintain overtime records.
  • Review overtime calculations.
  • Maintain weekly-off records.
  • Track leave balances.
  • Review compensatory-off records where applicable.
  • Ensure overtime payments are calculated correctly.
  • Review shift and night-work arrangements.
Businesses operating factories, manufacturing units, warehouses or establishments using shift workers should pay particular attention to these requirements.

4. Review PF, ESI and Other Social Security Compliance

The Social Security Code brings several social-security provisions under a consolidated framework. Employers should review their existing processes for:
  • Provident Fund
  • Employees’ State Insurance
  • Gratuity
  • Maternity-related benefits
  • Employee records
  • Social-security contributions
  • Other applicable statutory benefits
Payroll teams should also verify whether changes in the definition of wages affect statutory calculations.

Employer action:

Conduct a payroll compliance audit and compare: Current salary structure → Applicable wage definition → Statutory contribution → Employee benefit calculation This exercise can help identify discrepancies before they become compliance issues.

5. Review Gratuity Calculations

Gratuity is another area that should be reviewed as part of a Labour Code compliance exercise. Employers should check:
  • Employee eligibility
  • Continuous service records
  • Last drawn wages used for calculation
  • Fixed-term employment arrangements
  • Contractor and employee classification
  • Gratuity provisions in employment documentation
  • Payroll and accounting treatment
The correct treatment may depend on the employee’s circumstances and the applicable provisions. Businesses should therefore avoid relying on a single standard calculation for every employee category.

6. Audit Contract Labour Compliance

Contract labour can create significant compliance responsibilities for both principal employers and contractors. Employers using security guards, housekeeping staff, facility-management workers, production workers, logistics personnel or other outsourced manpower should review their contractor-management process.

Contract labour checklist:

  • Maintain a list of all contractors.
  • Verify contractor registrations/licences as applicable.
  • Check contractor employee records.
  • Verify wage payments.
  • Review PF and ESI compliance where applicable.
  • Collect statutory challans and returns.
  • Verify attendance records.
  • Maintain contractor agreements.
  • Monitor deployment of contract workers.
  • Conduct periodic contractor compliance audits.
The OSH Code contains specific provisions dealing with contract labour and related matters. Principal employers should not assume that signing an agreement with a contractor completely eliminates their compliance responsibilities.

7. Review Workplace Health and Safety Requirements

Workplace safety is a major component of the OSH framework. Depending on the nature of the establishment, employers should review:
  • Health and safety policies
  • Workplace risk assessments
  • Safety training
  • Personal protective equipment
  • Emergency procedures
  • First-aid facilities
  • Fire-safety arrangements
  • Accident reporting
  • Safety committees where applicable
  • Health examinations where required
  • Welfare facilities
Manufacturing and industrial establishments should give particular attention to safety procedures and statutory records.

8. Check Registers, Records and Returns

A compliance framework is incomplete without proper documentation. The OSH Code specifically provides for maintenance of registers, records and filing of returns. Employers should review whether their records are:
  • Accurate
  • Updated
  • Properly maintained
  • Available for inspection
  • Consistent with payroll data
  • Consistent with attendance records
  • Consistent with employee master data
Important records may include employee information, attendance, wages, overtime, leave, contractor details and statutory payments, depending on the applicable requirements.

9. Review Industrial Relations Policies

The Industrial Relations Code is another major component of the new labour-law framework. Employers should review their processes relating to:
  • Standing orders where applicable
  • Disciplinary procedures
  • Grievance handling
  • Termination procedures
  • Retrenchment
  • Lay-off requirements
  • Worker representation
  • Industrial disputes
  • Internal employment policies
The final Model Standing Orders for relevant sectors were also notified in May 2026. Companies with larger workforces should ensure that HR policies and employee-relations procedures are aligned with the applicable requirements.

10. Review POSH and Other Workplace Policies

The Labour Codes do not replace every workplace-related law. Employers should therefore avoid treating Labour Code compliance as a complete replacement for all other statutory obligations. For example, organisations should continue reviewing applicable requirements relating to:
  • Prevention of Sexual Harassment (POSH)
  • Maternity benefits
  • State-specific labour requirements
  • Shops and Establishments requirements
  • Professional Tax
  • Labour Welfare Fund
  • Minimum wage notifications
  • Contractor compliance
  • Factory-specific requirements
The exact obligations can vary based on the state, industry, employee strength and establishment type.

11. Check State-Specific Requirements

This is one of the most important points for employers in 2026. The Labour Codes provide a national framework, but employers should not assume that one compliance checklist automatically applies to every business across India. The applicable rules can depend on whether the Central Government or the relevant State Government is the appropriate authority. Therefore, before implementing changes, employers should check: State → Industry → Establishment type → Employee strength → Worker category → Applicable rules For businesses operating in multiple states, this becomes even more important because compliance requirements may differ between locations.

12. Conduct a Labour Compliance Gap Analysis

Instead of checking individual requirements randomly, employers can conduct a structured labour compliance audit. A simple 2026 gap-analysis framework can be:
Compliance Area Current Status Gap Identified Action Required
Salary Structure Reviewed/Not Reviewed Wage structure issue Recalculate
Appointment Letters Reviewed/Not Reviewed Missing clauses Update format
PF/ESI Reviewed/Not Reviewed Contribution mismatch Correct payroll
Gratuity Reviewed/Not Reviewed Calculation gap Review
Contract Labour Reviewed/Not Reviewed Documentation gap Audit contractors
Working Hours Reviewed/Not Reviewed Record gap Improve tracking
Overtime Reviewed/Not Reviewed Calculation issue Review payroll
Leave Records Reviewed/Not Reviewed Record gap Update system
Safety Reviewed/Not Reviewed Policy gap Implement controls
Registers & Returns Reviewed/Not Reviewed Missing records Update compliance
HR Policies Reviewed/Not Reviewed Outdated policy Revise
State Compliance Reviewed/Not Reviewed State-specific gap Verify requirements
This approach allows management to identify compliance gaps and assign responsibility for corrective action.

13. Create a Monthly Compliance Calendar

Labour compliance should not be treated as a once-a-year activity. HR and compliance teams should maintain a monthly calendar covering:
  • Payroll compliance
  • PF/ESI requirements
  • Professional Tax where applicable
  • Labour Welfare Fund requirements where applicable
  • Attendance and wage records
  • Contractor compliance
  • Statutory returns
  • Licence renewals
  • Employee documentation
  • Inspection-related records
Assigning an owner and deadline to each activity can significantly improve compliance tracking.

14. Keep Evidence of Compliance

One of the most overlooked areas is maintaining evidence. An organisation may have completed a statutory activity but still struggle during an audit if supporting documents cannot be produced. Maintain organised records of:
  • Payroll registers
  • Attendance
  • Wage sheets
  • Statutory challans
  • Returns
  • Employee records
  • Contractor documents
  • Licences
  • Inspection reports
  • Safety records
  • Policies
  • Training records
  • Grievance documentation
A good compliance system should make it easy to answer: What was done? When was it done? Who completed it? What document proves it?

2026 Labour Code Employer Checklist

Before closing your compliance review, ask: ☐ Have we reviewed our salary structure? ☐ Have we checked the applicable definition of wages? ☐ Have we reviewed appointment letters? ☐ Are PF and ESI processes being correctly followed? ☐ Have we reviewed gratuity calculations? ☐ Are working hours and overtime properly recorded? ☐ Are leave records updated? ☐ Have we audited contract labour compliance? ☐ Are workplace safety requirements being followed? ☐ Are statutory registers and records properly maintained? ☐ Have we reviewed applicable Industrial Relations requirements? ☐ Are our HR policies updated? ☐ Have we checked state-specific labour requirements? ☐ Do we have a monthly compliance calendar? ☐ Can we produce documentary evidence of compliance?

Why Labour Compliance Audits Matter in 2026

The Labour Codes are intended to simplify and consolidate India’s labour-law framework, but implementation still requires businesses to translate statutory requirements into practical HR, payroll and operational processes. A compliance audit can help employers identify gaps in:
  • Payroll
  • Employee documentation
  • Statutory contributions
  • Contractor management
  • Working hours
  • Safety
  • Registers and records
  • HR policies
  • State-specific requirements
Rather than waiting for a notice, inspection or employee dispute, organisations can use 2026 as an opportunity to conduct a structured compliance review.

Need Help With Labour Law Compliance?

Managing labour-law compliance across payroll, HR, contractors and statutory records can be complex, particularly for businesses operating across multiple locations. SNGSPL provides professional Labour Law Compliance support to help businesses review their applicable requirements, identify compliance gaps and improve their labour-law compliance processes. Learn more about our urlLabour Law Compliance Serviceshttps://sngspl.com/services/labour-law-compliance/.

Conclusion

The new Labour Codes represent a significant change in India’s labour-law framework. For employers, compliance in 2026 should go beyond simply understanding the Codes. Businesses should review their salary structures, employment documentation, social-security compliance, working hours, overtime, contractor management, workplace safety, statutory records and state-specific requirements. A structured compliance gap analysis can help organisations identify areas requiring attention and establish a more systematic approach to labour-law compliance. Disclaimer: This article is for general informational purposes and should not be treated as legal advice. Labour-law requirements can vary based on the establishment, industry, employee strength, location and applicable Central or State rules. Employers should verify the requirements applicable to their specific circumstances before implementing changes.
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