Reference only — not legal advice. This page is EarthReheal WasteLedger's plain-language interpretation of the rule, written to help organisations understand what may apply to them. It can be incomplete or inaccurate. Always read the official gazette notification or statute, and confirm with your regulator or a qualified adviser, before relying on it for compliance decisions.
Quick Summary
India's four Labour Codes came into force on 21 November 2025, replacing 29 older central labour laws. For anyone running a building, campus or site, the most visible day-to-day duties come from the Occupational Safety, Health and Working Conditions Code, 2020 (OSH Code): keep first-aid facilities at the workplace, report serious accidents and dangerous occurrences quickly, make sure contractors who supply 50 or more contract workers hold a valid licence, and engage security guards only through a licensed private security agency. This page deliberately covers these premises-facing duties. Payroll and HR obligations (provident fund, ESI, gratuity, bonus and similar) are listed only as guidance at the end — they are normally handled by your payroll provider.
What This Rule Is
The Labour Codes. Parliament consolidated central labour law into four Codes: 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. The Government brought all four into force with effect from 21 November 2025, and the Ministry of Labour and Employment has described them as subsuming 29 existing labour laws, including the Factories Act, 1948 and the Contract Labour (Regulation and Abolition) Act, 1970.
Rules under the Codes. The Codes set the framework; detailed forms, timelines and procedures sit in rules. The Occupational Safety, Health and Working Conditions (Central) Rules, 2026 were notified on 8 May 2026. Central rules apply where the Central Government is the "appropriate government" (for example, certain central establishments and sectors). For most private premises the state government is the appropriate government, so state rules govern. At the time of writing, Gujarat had final rules and most other states had published draft rules; check the current position for your state.
Private Security Agencies (Regulation) Act, 2005 (PSARA). A separate central Act. Private security agencies must hold a licence from the state Controlling Authority; under Section 7 a licence is valid for five years unless cancelled, and may be renewed for further five-year periods.
Who This Applies To
- Any workplace — offices, hotels, hospitals, schools and colleges, malls, residential societies with staff, warehouses and processing sites: first-aid and accident-reporting duties apply wherever people are employed.
- Principal employers using contract labour — for example housekeeping, facility management, security, waste-handling or construction contractors. The OSH Code's contract-labour provisions apply where 50 or more contract workers are employed (the old 1970 Act threshold was 20).
- Contractors supplying or engaging 50 or more contract workers — they need a licence before deploying workers.
- Premises that engage security guards — the guards must come from a PSARA-licensed agency.
Factories, mines, plantations and building or construction work have additional, sector-specific duties under the same Code; see the Related Rules.
State-Level Variations
The OSH Code is uniform nationwide, but most of the working detail depends on state rules: accident-notice forms and recipients, first-aid box contents, contractor-licence fees and procedure, and the online portal used. At the time of writing, most states' rules under the Codes were still in draft. Where a state has not finalised its rules, confirm with your state labour department which procedure its inspectors currently accept.
PSARA licences are issued by the state Controlling Authority. An agency licensed in one state needs a licence for each state in which it operates, so check the licence covers the state where your premises are.
Compliance Requirements — What You Actually Have to Do
1. Keep first-aid facilities at every workplace. The OSH Code's welfare provisions require first-aid facilities. Keep a stocked first-aid box, a named person responsible for it, and a record of periodic checks. Box contents and the number of boxes per worker are set by rules — confirm the scale with your state rules.
2. Report accidents and dangerous occurrences promptly. Under the OSH (Central) Rules, 2026:
- Death: inform the Inspector-cum-Facilitator and the other authorities named in the rules immediately.
- Injury preventing the worker from working for 48 hours or more: send the report within 12 hours after that 48-hour period.
- Dangerous occurrence (for example a fire, explosion, gas leak or structural collapse), even with no injury: report within 12 hours.
State rules may set different forms or recipients; confirm with your state labour department. Keep an internal incident log either way.
3. Check contractor licences where 50 or more contract workers are engaged. Before a contractor deploys workers, ask for the contractor's licence under the OSH Code. It is commonly reported that the licence is issued online and valid for five years; confirm the validity stated on the licence itself. The separate principal-employer registration under the 1970 Act has been replaced by the Code's single establishment registration — confirm your establishment's registration position with your state labour department.
4. Engage guards only through a licensed security agency. Ask for the agency's PSARA licence, check it is issued for your state, and note the expiry date (five-year validity under Section 7).
5. Track expiries. Contractor and security-agency licences lapse. Keep copies and renew or re-verify before expiry.
How EarthReheal WasteLedger helps. WasteLedger tracks a monthly first-aid box check, a workplace accident notice task for each reportable event, contractor licences (where 50 or more contract workers are engaged) and the security agency licence, with expiry reminders.
Crèche, Canteen and Drinking Water
- Crèche — 50 or more employees. Code on Social Security, 2020, section 67 and the Social Security (Central) Rules, 2026 (G.S.R. 344(E)), rule 37: a crèche for children under six within one kilometre — your own, or a common or tie-up crèche — with at least 10 sq ft per child, an attendant and an ayah per 10 children, and four visits a day for mothers. Chapter VI of the Code reaches shops and establishments with 10 or more employees, so offices and shops are covered too. The central rules bind only where the Central Government is the appropriate government; most private establishments follow their state's rules under the Code, which may add conditions.
- Canteen — 100 or more workers, including contract labour. OSH Code, 2020, section 24(1)(v) and OSH (Central) Rules, 2026 (G.S.R. 345(E)), rule 53 — only for factories, mines, building and construction work, motor transport undertakings, docks, plantations and beedi works. Offices, shops, hotels and schools are not covered by the central canteen rule.
- Drinking water. Where drinking water comes from a borewell or tanker, test it against IS 10500 twice a year. Food businesses must do so under FSSAI Schedule 4. Cleaning overhead and underground tanks every six months is good practice; no law sets a schedule.
Penalties & Enforcement
The OSH Code is enforced by Inspector-cum-Facilitators appointed by the appropriate government, who may inspect premises and records. The Code provides fines, and for some contraventions imprisonment, with higher penalties for contraventions causing death or serious injury; many first-time, lesser contraventions can be compounded. The exact amount depends on the provision breached, so confirm the applicable penalty with your adviser rather than relying on a single figure.
Under PSARA, carrying on a private security agency business without a licence is an offence. Whether and how a client that engages an unlicensed agency is exposed should be confirmed against the Act and your state's PSARA rules.
Beyond penalties, the practical risk is that a serious accident on site with no first-aid provision, no timely report, or an unlicensed contractor or security agency is difficult to defend.
Frequently Asked Questions
Q: Our housekeeping contractor has 30 people on site. Do they need an OSH Code licence? A: The contract-labour licence provisions apply at 50 or more contract workers. Below that, the licence requirement does not apply, but first-aid and accident-reporting duties still do.
Q: Is the old Contract Labour Act licence still valid? A: The 1970 Act is among the laws subsumed by the Codes. Transitional arrangements for existing licences depend on the rules; confirm with your state labour department.
Q: Which rules apply to us — central or state? A: For most private premises, the state government is the appropriate government, so state rules apply. The Central Rules of 8 May 2026 apply where the Centre is the appropriate government.
Q: Does WasteLedger handle PF, ESI or gratuity? A: No. These are payroll and HR obligations. The list below is guidance only; check them with your payroll provider.
Q: Which payroll and HR obligations should we check with our payroll provider? A: Guidance only — these are not tracked by WasteLedger, and thresholds should be confirmed with your payroll provider or adviser:
- Employees' Provident Fund — commonly at 20 or more employees.
- Employees' State Insurance — commonly at 10 or more employees.
- Gratuity and bonus — bonus commonly at 20 or more employees.
- Crèche — commonly at 50 or more employees (Code on Social Security, 2020).
- Canteen — at 100 or more workers (OSH Code, Section 24).
- Professional tax and labour welfare fund — state laws; vary by state.
Government / Official Sources
- Ministry of Labour and Employment — press release on implementation of the four Labour Codes (PIB)
- Occupational Safety, Health and Working Conditions Code, 2020 — bare text (VVGNLI)
- Ministry of Labour and Employment — Codes, Central Rules and notifications
- Private Security Agencies (Regulation) Act, 2005 — Section 7 (Indian Kanoon)
- Your state labour department — state rules, forms and portal
Related Rules
- RULE_FACTORIES_ACT — factory-specific safety, health and welfare duties, now carried into the OSH Code.
- RULE_BOCW — building and other construction work, with its own safety and welfare requirements.
- RULE_SHOPS_ESTABLISHMENTS — state registration and working conditions for commercial premises.
- RULE_FIRE_SAFETY — fire prevention and fire NOC; fires are also reportable dangerous occurrences.
- RULE_POSH_ACT — the headcount used for POSH includes contract workers on site.
Additional Reference Content
Secondary sources (law firm explainers, news, consultancy blogs, or official-body sites on a non-.gov.in/.nic.in domain) — useful context, not primary legal authority.
- OSH (Central) Rules, 2026 — key highlights (SCC Online) — accident and dangerous-occurrence reporting timelines.
- OSH (Central) Rules, 2026 — Lakshmikumaran & Sridharan
- Contract labour under the new regime — Lakshmikumaran & Sridharan — 50-worker threshold, five-year licence, single registration.
- Labour Codes implemented effective 21 November 2025 — EY alert