The Biggest Change
Appointment Letters — Universal Obligation New
- Every employer must issue an appointment letter to every employee
- — across every establishment, every sector, every employment type.In Simple TermsEvery single employee in India — whether you work at a startup, a factory, a shop, or a multinational — must now receive a written appointment letter from your employer. This was never mandatory across all sectors before. If you don't have one, your employer is violating the law.
- This was previously required only in specific regulated sectors. The OSH Code makes it universal.
- The format will be prescribed under the final rules. Employers should begin issuing letters now — non-issuance is a compliance breach from 21 November 2025.
Before
Required only in specific scheduled or regulated employment sectors. Many employers — particularly in manufacturing, construction, and hospitality — routinely onboarded without formal documentation.
Now
Mandatory for every employee in every establishment. No exceptions. Including existing employees with no letter on record. Format to be prescribed under final rules.
Inspection RiskAppointment letters are the most likely document to be checked in early inspections. If any employee in any of your locations does not have one — existing or new — that is an immediate exposure. Audit and issue.
Registration
Single Registration — 10+ Employees
- Every establishment with 10 or more employees must register electronically within 60 days of existence.
- Establishments already registered under any Central Act need not re-register but must intimate existing registration details within 30 days of any change.
- A single registration and single licence now replaces the previous multiple registration and licence requirements across 13 laws.
Health and Safety
Annual Health Check-ups and Workplace Safety
- Free annual health check-ups for all employees aged 40 and above.
- For workers in hazardous processes or dangerous operations: free pre-employment and periodic health examinations regardless of age.
- Workplace must be free from hazards likely to cause injury or disease — covering cleanliness, ventilation, lighting, safe drinking water, and waste disposal.
- Separate toilet facilities for male, female, and transgender workers are mandatory.
Welfare Facilities
What Must Be Provided and When
- All establishments: Washing and bathing facilities, sitting arrangements, lockers, first aid, rest rooms — for male, female, and transgender employees separately.
- 100+ workers: Canteen facility mandatory.
- 50+ employees: Crèche for children below 6 years. Can be shared or through common facilities.
- 500+ workers (mines and construction): Ambulance room required.
- 250+ workers (construction), 100+ workers (mines): Safety officer must be appointed.
Women at Work
Night Shifts and Hazardous Work
- Women are permitted to work in all establishments and all types of work — including previously restricted sectors.
- For work before 6 AM or after 7 PM: employer must obtain prior written consent and comply with prescribed safety measures, transport arrangements, and working conditions.
- Employer must provide adequate safety safeguards before employing women in hazardous or dangerous operations.
- Employment of pregnant women in processes involving serious risk of injury or poisoning may be restricted by the appropriate government.
Contract Labour
Principal Employer Responsibilities
- Provisions apply where 50 or more contract labourers are employed on any day in the preceding 12 months.
- Contractors employing 50+ workers must obtain a licence — valid for 5 years. A single common licence covers factories, beedi and cigar work, and contract labour engagement.
- Principal employer is responsible for providing all welfare facilities to contract workers. The contractor cannot be used as a shield.
- If the contractor fails to pay wages, the principal employer is liable to make payment directly to contract labour.
- Contractor must issue an experience certificate on demand to contract workers.
Principal Employer LiabilityReview all contractor agreements to ensure welfare responsibilities are clearly allocated. Where contracts are silent on welfare, the liability defaults to you as the principal employer.
Inspector Reform
Inspector-cum-Facilitator Model
- The traditional Inspector role is replaced with an Inspector-cum-Facilitator — focused on education and facilitation alongside enforcement.
- Inspections are now conducted through a randomised web-based system, reducing discretion and potential for selective enforcement.
- Complaint-based inspections are still available, subject to approval from competent authorities.
- Penalties have been rationalised and in some cases increased. Minor offences are compoundable. Serious safety violations attract severe penalties including imprisonment.
Inter-State Migrant Workers
Journey Allowance and Portability
- Applies to establishments with 10 or more inter-state migrant workers on any day in the preceding 12 months.
- Employer must pay a lump-sum journey allowance once a year covering to-and-fro travel between the place of employment and the worker's native state.
- Inter-state migrant worker defined as a person drawing wages up to ₹18,000 per month (or higher as notified).