On November 21, 2025, India’s long-awaited Occupational Safety, Health and Working Conditions (OSH) Code, 2020 came into force. It replaces 13 National Labour laws with a single consolidated Code intended to improve transparency, enhance worker welfare, and promote ease of doing business in India. Significant labour reforms were also brought into force on this date in three additional Codes: the Code on Wages 2019, the Industrial Relations Code 2020, and the Code on Social Security, thereby replacing 29 laws with these four Codes and establishing a framework to enable robust improvements in OHS for workers and employers. It is important to note that many of the detailed provisions will be fully enacted upon the issuance of state rules.
Simplified Administrative Requirements for Employers
Notable OSH Code 2020 changes to improve administrative procedures focus on reducing paperwork, consolidating resources and eliminating delays. These include the replacement of multiple registrations and licences for employers with a single licence valid across India for establishments requiring registration, including factories, businesses, motor transport undertakings, and mines, among others. The new mandatory use of electronic filings and records digitization in the Code speeds processes, with registration certificates now issued electronically.
Additional time-saving provisions specify a 30-day time-bound approval for the site appraisal committee to give its recommendations for an expansion or initial factory location application involving hazardous processes.
A single National OHS Advisory Board to set mandatory national standards for OHS and working conditions replaces six boards. In addition to the specified Government representatives, the Board is to include expert invitees, as well as five employer representatives and five employee representatives.
Other administrative reductions under the Industrial Relations Code 2020 include changes to requirements for industrial establishments that must obtain government permission for layoffs; the permission threshold has increased from 100 to 300 employees, and States have been given greater flexibility to further revise this limit.
Modernized Compliance Procedures and Decriminalization
In an effort to reduce the burden of inspections on employers and improve inspection efficiency, the prior inspection system has been replaced with a randomized, digital approach that assigns inspections based on risk algorithms. It shifts from mandatory, regular, in-person visits to a risk-based approach that involves web-based electronic information requests, followed by targeted on-site inspections, if necessary. A new "Inspector-cum-Facilitator" role is established. These new Facilitators reportedly act to guide and support employers in achieving compliance rather than act as "Inspector Raj" enforcers.
The new OSH Code 2020 also establishes a provision whereby the Government may, by notification, formulate a scheme to empanel experts to conduct the “third-party audit and certification” of start-up establishments or specified classes of establishments. These experts are directed to report their audit findings to the concerned employer and to the Inspector-cum-Facilitator. Implementation of this provision will be dependent on Government action.
Other compliance-related revisions across the four revised codes largely decriminalize certain minor first-time offences, replacing criminal penalties (e.g., imprisonment) with civil penalties (e.g., monetary fines).
Worker Well Being Benefits
OHS Code worker welfare provisions, applicable to establishments employing 10 or more employees, are expanded and clarified, offering greater transparency on employment terms, wages, designations, and social security. Key changes include:
- Mandatory Employee “Appointment Letters” specifying designation, category, wage and social security details, etc.
- A reduction in the number of required days worked to qualify for annual paid leave (180 days from 240 days).
- Specified overtime hours, with no employee required to work for more than 8 hours in a day and 48 hours in a week without the consent of the worker.
- Expansion of employee eligibility for a free annual health checkup from seven sectors to all sectors.
Related benefits enacted in the Wage Code 2019 extend minimum wage protections to all employees in both organized and unorganized sectors, require revisions to minimum wages every five years, with inflation adjustments every six months, and require equal pay for all genders.
Changes to the Code on Social Security revise benefits to establish 26 weeks of paid maternity leave for every woman employee who has worked for at least 80 days in the 12 months before an expected birth. Women adopting a child below 3 months of age, or commissioning mothers (using surrogacy), are entitled to 12 weeks of maternity benefit. Flexibility for working from home is also addressed.
Significantly, the revised Industrial Relations Code 2020 now specifies that Grievance Redressal Committees (required for establishments with 20 or more workers) must include women in proportion to their presence in the workforce. An equal number of members must also represent the employer and the workers.
Workplace Safeguards
OHS Code revisions also establish additional safety provisions for employees. These include:
- Safety Committees, with representatives from employers and workers, are mandated for factories with 500 or more workers, employers of 250 or more Building & Other Construction Workers (BOCWs), and employers of 100 or more mine workers.
- Women working at night (before 6 AM and after 7 PM) are provided with safety measures, including facilities (listed below) and transportation with their consent.
- Provision of adequate, suitable and separate shelters or rest-rooms for male, female and transgender employees and a lunchroom in every factory and mine wherein more than 50 workers are ordinarily employed and in a motor transport undertaking wherein an employee is required to halt at night.
- Provides for bathing places and locker rooms for male, female and transgender employees separately.
- Provides for the potential expansion of the Code’s applicability to include any establishment, even if it has one employee, carrying out hazardous or life-threatening occupations.
Next Steps
These Codes are now in force. In-scope establishments should review their employee records to ensure all employees have an employee appointment letter (required by February 21, 2026) and that work and break schedules meet more stringent requirements. Establishments with 20 or more workers should ensure their Grievance Redress Committee memberships meet the new requirements. Establishments with 50 or more employees that do not have a crèche facility within the prescribed distance must arrange for one.
Employers will also wish to take advantage of simplified administrative procedures as soon as practicable, and review electronic recordkeeping and EHS compliance systems to align with new electronic submission requirements.
Finally, employers should continue to monitor national and state rules for additional updates on the implementation of these requirements.
About the Author
Jen Chiapella is an EHS Regulatory Specialist at STP ComplianceEHS, where she monitors EHS and environmental, social, and governance (ESG) regulatory changes across North America and supports other global and client-specific monitoring tools and products.
Prior to joining STP, Jen spent over 25 years in EHS consulting, which included extensive experience in the development of the International Audit Protocol Consortium (IAPC) EHS Audit Protocols, as well as other client-specific EHS compliance tools in North America and abroad. Her experience also includes certification as an environmental auditor and over a decade of auditing for industrial and light industrial facilities in the U.S., where she is based.