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The April 2025 edition of our Labour Law Insights newsletter covers latest labour law developments in various states, EPFO updates, important judgements as well as ESIC updates. It highlights revisions in minimum wages, changes in compliance requirements under factory and labour welfare legislations, and progressive bills concerning gig and platform workers. The newsletter also addresses critical updates from regulatory authorities such as ESIC and EPFO that streamline processes, enhance transparency, and support long-term compliance objectives. These updates hold significant operational implications and merit immediate attention from employers and professionals managing workforce matters.
Employers in Kerala, Telangana, Delhi, Andhra Pradesh, Punjab, Uttar Pradesh and Haryana are required to follow the revised rates of minimum wages/Dearness Allowance as applicable to them pursuant to the notifications issued by the respective Labour Departments. Most of these rates have been revised due to increase in the Consumer Price Index, which would support workers in the states to meet the rising cost of living. Further, employers shall also take into account the arrears of wages payable to the eligible employees due to changes in rates of minimum wages especially those effective from back date. This compliance becomes critical for employers because any employee dues not paid to them becomes “unpaid accumulations” under the state specific Labour Welfare Fund (LWF) Act and if not paid need to be deposited with the respective LWF authority as per law.
The Trade Unions in West Bengal shall regularly check that no person who is not in employment cease to be office bearer in the Trust and accordingly file the annual return with correct particulars.
The establishments and contractors in Kerala shall take note of the amended fees for obtaining certificate of registration and license, respectively under Inter-state Migrant Workmen (Regulation of Employment and conditions of Service) Act, 1979.
The Government of Andhra Pradesh has proposed more stringent qualifications for the appointment of welfare officers in factories operating in the state. This initiative aims to ensure that workers receive support from well-qualified and experienced welfare officers.
The employees and employers in Karnataka needs to take note of the revised rate of professional tax to be deposited with the authorities for February. The February increase could be intended to synchronise with annual accounting practices or to balance state revenue collections as the financial year draws to a close.
The factories in Jharkhand need to take note of the amendments issued pursuant to registration fees, amendment fees, annual returns and closure of factories. The annual return-related provisions are made more stringent as non-filing or delayed filing may lead to late fees and even cancellation of factory licence. Therefore, employers of factories shall ensure compliance with annual return submissions as per prescribed timelines.
The establishments in Gurgram shall register themselves and file quarterly return ER-I on the online portal www.hrex.gov.in. The digitalisation of quarterly returns is a welcome move in bringing transparency and seamless data collection by the Department. However, there are practical challenges being faced by establishments in Haryana as their registration application on hrex portal are not being approved by the Department and they’ve been asked to physically visit the Department seeking additional information and documents. This difficulty not only becomes a hurdle in the Government’s initiatives towards ease of compliance but also shows reluctances of on-ground officers/authority having jurisdiction towards these compliances.
The establishments in Maharashtra employing security guards shall take note of the amendments with respect to definition of establishment, and prohibition of employment of children. The increase of age of employment of children as security guard to 18 years is a welcome step towards prohibition of employment of even adolescents until they attain adulthood.
The Government of Telangana has issued draft bill for governing employment of platform and gig workers and the same will be notified soon. During 2024 the Karnataka Government also issued similar legislation such as The Karnataka Platform-based Gig Workers (Social Security and Welfare) Bill, 2024, on 29 June 2024. Telangana is the third state after Rajasthan and Karnataka who has released bill for gig and platform-based workers. Overall, the bill appears to be a progressive step towards providing social security and welfare to gig workers, reflecting an understanding of the gig economy’s dynamics and the challenges faced by those who work in it. It aligns with global trends of increasing legal protections for gig workers. The legislation seeks to safeguard the rights of gig worker and regulating the aggregators considering that lakhs of workers have been engaged in the unregulated industries. Important to note that the concept of gig worker and related governing provisions are also covered in the Code on Social Security, 2020 (“SS Code”). However, since the SS Code is yet to be implemented, the state governments have taken the initiative to protect rights of platform-based gig workers to meet the need of the hour and regulate the aggregators working in the industries such as food and grocery delivery, travel, hospitality, ride sharing etc. It would be interesting to see how this Bill will be implemented vis-à-vis the proposed implementation of SS code.
The EPFO has removed the requirement for uploading a cheque leaf or attested bank passbook while filing claims. This change simplifies and accelerates the EPF claim process, reduces dependency on employers, and shifts validation responsibility entirely to the bank/NPCI system. It will help in quick KYC approvals and low administrative effort for both members and employers.
The circular provides a practical workaround to ensure that employees do not lose out on past contributions due to employer-side technical or procedural gaps. It reinforces EPFO’s intent to recover dues even when standard mechanisms are not feasible, while also cautioning that such cases should remain exceptions. Employers availing this route should be prepared for scrutiny and must comply with all follow-up formalities to ensure regulatory alignment.
Allotment and activation of UAN through UMANG app is a landmark step towards digitisation and self-service in the EPFO ecosystem. By using Aadhaar-based facial authentication, the process becomes more secure, seamless, and user-friendly, especially for informal sector workers or remote users with limited employer interaction. It cuts down administrative delays and enables real-time access to EPF services, such as passbook viewing and claim filing. This move aligns with the Government’s broader vision of faceless, paperless, and transparent services.
The EPFO has issued a circular to ease procedural barriers for EPF members seeking housing-related advances after a sufficient time has lapsed. By allowing self-declaration without linkage to past withdrawals, EPFO promotes flexibility while maintaining a clear eligibility window of 60 months post-house completion. Employers should inform eligible employees of this relaxation and ensure housing completion dates are well-documented.
The EPFO has issued a circular allowing bulk generation of UANs without Aadhaar in certain special cases. This update offers a practical workaround for handling legacy PF data, ensuring that members from exempted trusts or unresolved cases are not disadvantaged due to procedural gaps like lack of Aadhaar at the time of data transfer. By separating the accounting and Aadhaar seeding processes, the EPFO enables quicker crediting of past dues while still maintaining compliance. However, the restriction on transactions until Aadhaar linking is done preserves the integrity of the KYC process. Employers and field offices should actively coordinate to complete Aadhaar seeding post-generation to operationalise these frozen UANs swiftly.
The EPFO has issued a circular to address a recurring issue faced during the surrender or cancellation of exemption by PF Trusts, where TDS on annual interest was incorrectly deducted on the entire past accumulation amount, including both taxable and non-taxable portions. This update is a significant stride toward data accuracy and fair taxation in EPF operations. By enabling clear segregation of interest components, it protects members from undue tax burdens and aids employers in complying correctly. It also pushes field offices to resolve legacy entries promptly, ensuring a smooth transition to the improved system. Overall, the move enhances accountability and strengthens the EPFO’s efforts toward digitally governed and member-friendly processes.
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