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Labour Law Insights: November 2025

Labour Law Insights: October 2025 - Grant thornton Bharat
The four Labour Codes were announced in November replacing the earlier 29 Labour laws. This is a historical announcement and set to change the Labour Law reforms. We have shared the details and analysis of these path-breaking Labour codes in our November 2025 edition of Labour Law Insights. The edition also covers our regular labour law releases in various states, EPFO updates, and important judgements.
Contents

Labour law updates

  • The Government’s notification on 21 November 2025 to implement four Labour codes marks a major shift in India’s labour law framework. Employers must update HR policies, align pay structures with the uniform “wages” definition, and revise processes for working hours and record-keeping. Key measures include annual health check-ups, gratuity for fixed-term employees completing 1 year, and social security for gig workers. It also involves compliance simplification through PAN-India licensing and single return filings. With state rules in place and overlaps persisting, proactive adaptation is vital to manage risk and leverage ease-of-doing-business reforms.
  • The Government of Karnataka has introduced a Menstrual Leave Policy applicable to all registered establishments under major labour laws. This progressive step aligns Karnataka with global best practices for gender-sensitive workplace policies. Employers should update leave management systems, HR policies, and employee communication channels to ensure smooth implementation. The absence of documentation requirements simplifies compliance, but organisations should maintain internal records for transparency.
  • The Government of Karnataka has notified the Karnataka Platform-Based Gig Workers (Social Security and Welfare) Rules, 2025. The notification formalises gig work and extends social security to platform workers, offering grievance mechanisms, safety standards, and access to welfare schemes for better protection and transparency. Aggregators must assess the financial impact of welfare fee contributions and new compliance obligations, review contracts and policies to align with the Act, use clear language on pay, rights, and grievance processes, and provide advance notice of any changes to workers.
  • The Haryana S&E (Amendment) Ordinance, 2025 raises the registration threshold to 20 employees and extends daily work hours to 10, signalling a nationwide trend towards easing compliance and enhancing flexibility. States like Maharashtra, Punjab, Telangana, and Bihar have introduced similar reforms, while Delhi and Karnataka are considering changes. Amendments reduce compliance for small businesses but raise concerns over reduced rest intervals, longer workdays, and worker welfare. Provisions include expanded overtime limits, night shifts for women under safety norms, and gender inclusivity. Employers must update HR policies, SOPs, and safety measures to balance ease of business with employee well-being.
  • The Government of Haryana has exempted IT/ITES, startups, and other knowledge-based industries from the Industrial Employment (Standing Orders) Act, 1946 for five years. However, with the Industrial Relations Code, 2020 now in force, organisations must align with its provisions, including model standing orders, grievance handling, and dispute resolution. This requires updating employment policies, training HR teams, and ensuring digital record-keeping for transparency. Businesses that adapt quickly will reduce compliance risks and maintain smooth employee relations under the new regime.
  • The amendment to the Andhra Pradesh Shops and Establishments Act, 1988 seeks to boost operational flexibility, simplify compliance, and promote gender inclusivity by exempting establishments with fewer than 20 workers and permitting women to work night shifts under strict safety norms. While easing business and enabling workforce flexibility, the changes raise concerns over reduced rest periods, extended working hours, and lack of protections for lean, AI-driven organisations. Employers must update HR policies, strengthen safety infrastructure, and adopt measures to safeguard employee welfare amid these new conditions.
  • The Government of Maharashtra has proposed amendments to the Shops and Establishments Rules, 2018 to enhance workplace safety and ease compliance. Key changes include raising the registration threshold to 20 employees, reducing regulatory burden for micro establishments, and introducing stringent safety measures for women working night shifts, such as transport, lighting, CCTV, and consent documentation. However, excluding establishments with fewer than 20 workers leaves lean, AI-driven businesses outside formal protections, creating welfare risks and highlighting the need for alternative compliance frameworks.
  • The Government of Maharashtra has issued a notification under Section 7 of the Rights of Persons with Disabilities Act, 2016, outlining measures to protect persons with disabilities from abuse, violence, and exploitation. This notification strengthens the legal and administrative framework for safeguarding persons with disabilities. Organisations and authorities must ensure timely reporting, preventive interventions, and rehabilitation support. Employers, care institutions, and NGOs should train staff on SOP compliance and maintain vigilance against abuse or exploitation. Digital reporting and coordination with district-level committees will be critical for effective implementation.
  • The Government of Maharashtra has issued draft rules under the Maharashtra Private Placement Agencies (Regulation) Act, 2025 to regulate private placement agencies operating within the state, across India, and overseas. These draft rules mark a significant step toward formalising the operations of private placement agencies and promoting ethical practices in recruitment. Agencies must prepare for digital compliance via Mahaswayam portal, maintain accurate records, and ensure timely renewals to avoid penalties. Businesses should start aligning their processes with these requirements, as final rules are expected soon after the consultation period.
  • Employers in Soreng, Gyalshing, and Mangan districts of Sikkim must register under the ESI, since the Central Government has notified the extension of Employees’ State Insurance (ESI) Act, 1948 provisions in these districts. This was done to ensure contribution compliance and zafacilitate access to ESI medical facilities for their workforce.
  • The President of India has promulgated the Contract Labour (Regulation and Abolition) Lakshadweep (Amendment) Regulation, 2025, under Article 240 of the Constitution, amending the applicability of the Contract Labour (Regulation and Abolition) Act, 1970 in the Union Territory of Lakshadweep. Establishments in Lakshadweep engaging 50 or more contract workers will now fall under the Act, reducing regulatory burden for smaller businesses.
  • The President of India has promulgated the Industrial Disputes (Ladakh) Amendment Regulation, 2025, amending the Industrial Disputes Act, 1947, for the Union Territory of Ladakh. The expanded notice requirements and extended timelines aim to strengthen dispute resolution mechanisms and provide greater predictability for industrial establishments. Organisations should update their compliance frameworks to reflect the 60-day notice period and ensure implementation.
  • Employers in various states must declare annual holiday lists as per the National & Festival Holidays Act applicable in the state and submit the list of holidays with concerned labour dept. before end of December 2025 in the prescribed format.
  • Entities in various states must regularly monitor minimum wage notifications relevant to their state and employment category to ensure adherence to legal requirements. Kindly refer to the notifications for more details on rates and applicability period and employments.

EPFO updates

  • The EPFO vide its circular No. 1189836/EDLI/Directions/FO/X/2025-Part (1) dated 03 November 2025 has issued detailed instructions regarding the Examination and Format of EDLI (Employees’ Deposit Linked Insurance) Exemption/Extension Applications under the EDLI Scheme, 1976. This circular is an important compliance directive for establishments seeking EDLI exemption. It does not directly impact PF contributors but ensures that employers opting for alternative insurance arrangements meet statutory conditions. The move reflects EPFO’s focus on clarity, accountability, and timely disposal of cases, which ultimately safeguards employee benefits.
  • The EPFO, vide its circular No. LitigationManagement/E58312 dated 20 November 2025, has issued strict instructions to strengthen litigation management and ensure timely handling of court cases. This directive is an internal compliance measure and does not affect PF contributors directly. It underscores the EPFO’s commitment to legal diligence and risk mitigation, ensuring statutory and financial interests are protected. By enforcing accountability and digital monitoring via LIMBS, the EPFO enhances operational efficiency and transparency in litigation management.
  • The Ministry of Labour & Employment, vide Notifications S.O. 4920(E) and S.O. 4921(E) dated 29 October 2025, has authorised RPFCs and designated EPFO officers to exercise powers under Sections 14AC and 14B of the EPF & MP Act, 1952. By decentralising prosecution and penalty recovery, the EPFO strengthens compliance enforcement, enables faster legal action, deters delays in contributions, and safeguards statutory provisions and employees’ rights while reinforcing its focus on efficiency, accountability, and timely enforcement.
Labour Law Insights: November 2025
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Labour Law Insights: November 2025