On 21 November 2025, the Government of India took a historic step by implementing the long-awaited four Labour Codes — Code on Wages (2019), Industrial Relations Code (2020), Code on Social Security (2020), and Occupational Safety, Health and Working Conditions Code (2020).

This landmark reform comes nearly five years after their initial introduction and represents a major overhaul of India’s labour governance framework. By consolidating 29 existing labour laws into a simplified and unified structure, these Codes aim to enhance regulatory clarity, improve compliance efficiency, and address evolving workforce dynamics. The move underscores the government’s commitment to modernising labour regulations, ensuring better protection for workers while enabling ease of doing business for employers across sectors.

With the notification on 21 November 2025, the uncertainty surrounding the enforcement of the Labour Codes has now been resolved. Consequently, the substantive phase begins — encompassing transition, interpretation, formulation of rules, development of schemes and standards, and their effective implementation at the ground level. 

What are the four labour codes

The Code on Wages, 2019

Amends and consolidates the laws relating to wages and bonus and matters connected therewith or incidental thereto

The Social Security Code, 2020

Seeks to amend and consolidate the laws relating to social security with the goal to extend social security to all employees and workers either in the organised or unorganised or any other sectors and for other incidental or related matters

Industrial Relations Code, 2020

Consolidates and amends the laws relating to trade unions, conditions of employment in industrial establishments, investigation and settlement of industrial disputes and for all other incidental or related matters

Occupational Safety, Health & Working Conditions Code, 2020

Focussed on consolidating and amending the laws regulating the occupational safety, health and working conditions of the persons employed in an establishment and for all other incidental or related matters

Which labour codes are implemented—and to what extent? 

  • Industrial Relations Code, 2020 and Occupational Safety, Health and Working Conditions Code, 2020  have been implemented in its entirety
  • The Code on Social Security, 2020 has been brought into effect, with certain exclusions, including the non-repeal of the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952
  • The Code on Wages, 2019 has also been implemented, with certain exclusions related to the constitution of the Central Advisory Board 

How the codes impact businesses

  • Mandate of enforcement: The Central Government has mandated the enforcement of the Code on Wages in its entirety across all states and UTs.
  • Objective of enforcement: This step aims to ensure uniformity and eliminate any scope for ambiguity in the implementation of wage-related provisions nationwide.
  • Exclusions: The enforcement excludes specific provisions under Sections 42 and 67, which pertain to the constitution and functioning of the Central Advisory Board by the Central Government.
  • Purpose of exclusion: These exclusions are intended to allow flexibility in formalising the Advisory Board without affecting the overall applicability of the Code.
  • Overall intent: The notification seeks to provide absolute clarity and certainty regarding the applicability and execution of the Code, thereby fostering consistency in wage regulations across the country. 
  • Comprehensive enforcement: The notification ensures the enforcement of the Code on Social Security, 2020 in its entirety, reaffirming the Government’s commitment to provide universal social security coverage to all eligible individuals.
  • Objective of enforcement: The measure aims to establish uniformity and clarity across jurisdictions, eliminating any scope for interpretational discrepancies in the application of social security provisions.
  • Exclusions: Certain provisions under Sections 15, 16, 143, and 164 are excluded from immediate enforcement. These provisions relate to the formalisation and operationalisation of schemes under: Employees’ Provident Fund (EPF), Employees’ Pension Scheme (EPS) & Employees’ Deposit Linked Insurance (EDLI)
  • Purpose of exclusion:  The exclusions are intended to allow adequate time for the structuring and implementation of these schemes, ensuring a smooth transition.
  • Overall intent: The notification seeks to maintain consistency in the application of social security benefits nationwide, while enabling a seamless rollout of complex schemes. 
  • Concept of fixed-term employment: Introduced with benefits not be less than of a permanent worker
  • Conditions for strikes and lockouts prescribed: No strikes and lock outs without giving proper notice in compliance with the norms laid down in the code
  • Standing orders: Required in establishments where 300 or more workers are employed
  • Retrenchment, lay-off and closure provisions: Not to be applicable if workers are
  • Concept of core and non-core workers: Employment of contract labour in core activities of any establishment is prohibited (with certain exceptions)
  • Canteen and crèche facility: Mandated for specified establishments
  • Special provisions for women: Consent of female employees required for working before 6 am and after 7pm along with other safety measures
  • Concept of leave rules and leave encashment introduced 
  • Free annual health check-ups: Mandated for specified employees of specified establishments

Key areas of consideration 

  • Payroll: Review Payroll policies regarding monthly disbursements, complete and final settlements, recoveries, loans and advances and statutory advances etc.  
  • HR function: A detailed review of various categories such as employment, compensation, leave and meternity benefits etc.
  • Financial impact: Understanding the financial impact on P&L both from employers and employees point of view
  • Policies:
    • Develop a policy framework for newer concepts, such as gig and platform workers and obligations as an aggregator 
    • Adhere to occupational safety and health standards as per provisions under the Labour Codes 
  • Manpower composition review:
    • Carry out a thorough review of the staffing composition and related compliance obligations as Principal employer and contractor
    • Worker vs employee analysis
    • Analysis of gigs and platform workers etc., as a compared to contract workers 

How Grant Thornton Bharat can help

We help organisations divide their strategy into three phases to gauge preparedness and ensure a smooth transition. 

1.
Detailed assessment, i.e., comparing existing with new provisions
  • Review compensation structure and benefits
  • Review existing HR processes and policies
  • Review employment and other contracts
  • Map/compare the prescribed guidelines under the codes as applicable
  • Presentation before the management and stakeholders
2.
Transition
  • Assist in revising compensation structure, policies, contracts, etc.
  • Worker v/s employee analysis
  • Assist in putting plan in place for transition to new codes
  • Assist in creating the process ownership structure and align internal department, management and other stakeholders
3.
Implementation and compliance
  • Assist in compliances under new codes
  • Provide handholding support over a fixed period
  • Assist with implementing any change in provisions, clarifications, notified after the effective date
  • ERP system changes and change management 

Why Grant Thornton Bharat

Transitioning to a new legislative framework is not a one-time activity but a journey. At Grant Thornton Bharat, we are well-equipped to assist our clients as we navigate this legislation change, which will impact employers across industries. 

Single point of contact 

A dedicated project manager who will act as your single point of contact 

Empaneled regulators 

Ex-regulators from EPFO empanelled with us to cater to clients’ requirements

Tailored-made solutions

Well-defined communication protocols to provide agile and responsive services 

Robust reporting and commitment to timelines

Ensure timely and robust reporting for swift management decision making 

We have a team of committed professionals, comprising experienced CAs, Lawyers, and Company Secretaries, with expertise across Payroll, Tax, Labour laws, Company Law and Regulatory domains to help us cover all aspects of the engagement. 

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Webinar recording

Decoding Labour Codes: The dawn of a new era

We hosted a webinar titled ‘Decoding Labour Codes: The dawn of a new era’ on the new Labour Codes, which came into effect on 21 November 2025. Our experts shared practical guidance on proactive worker classification, compliance with new wage definitions, documentation for social security benefits, digital readiness for streamlined reporting, and the importance of strategic workforce planning across HR, finance, and legal teams.