
Introduction
In our previous Article we discussed the key compliance and implementation considerations arising under the Code on Wages (Central) Rules, 2026 and the Code on Social Security (Central) Rules, 2026, with a particular focus on the evolving regulatory obligations for employers and establishments. It further considered the practical impact of the newly introduced rules relating to the calculation and payment of minimum wages, and employer compliance mechanisms on establishments operating in India.
In Part II of this series, we shall examine the Occupational Safety, Health and Working Conditions (Central) Rules, 2026 and the Industrial Relations (Central) Rules, 2026.
The Occupational Safety, Health and Working Conditions (Central) Rules, 2026 (“OSH Rules”)
The labour laws landscape in India, incidental to occupational safety, health and working conditions, previously translated to 14 (fourteen) central legislations, each governing a distinct sector, a distinct category of worker, a distinct set of hazards, produced a compliance architecture that was, in practice, confusing. The Occupational Safety, Health and Working Conditions Code, 2020 (“OSH Code“) consolidates these fourteen parallel and often fragmented compliance regimes into a single, unified framework. With the notification of the OSH Rules by the Ministry of Labour and Employment, 14 (fourteen) further subordinate legislation have now been repealed, including the Contract Labour (Regulation and Abolition) Act 1970.
Single Contractor Licensing
Section 47 of the OSH Code replaced the contractor licensing regime under the Contract Labour (Regulation and Abolition) Act, 1970, under which a contractor was required to obtain a separate licence for each establishment where contract labour was deployed, often across multiple states, generating a web of state-specific, establishment-specific licences of varying validity periods. Now under the OSH Code, every contractor who has employed 50 (fifty) or more contract workers in the preceding 12 (twelve) months is required to obtain a single licence, valid for 5 (five) years.
The OSH Rules operationalize this through 4 (four) provisions in Chapter XI, Part I. Rule 85 sets the eligibility threshold for applicants, wherein a contractor is disqualified only if they: (i) are an undischarged insolvent; or (ii) have been convicted within the preceding 2 (two) years of an offence carrying more than 3 (three) months’ imprisonment. Rule 86 prescribes the conditions for a license, including compliance with prescribed working hours and wage payment per the Code on Wages, 2019. Rule 88 creates the national licence mechanism for which an application is filed electronically in Form XXI by the contractor with operations across multiple states. Notably, the timeline for approval is 45 (forty-five days) during which the licensing authority must electronically consult the concerned State Government and raise their objections, failing which the licence is auto-generated. Rule 90 further mandates a security deposit of Rs. 1000/- (Rupees One Thousand Only) per contract labour against which, under Rule 86 (iv)(2), the Chief Labour Commissioner (Central) may draw directly if minimum wages go unpaid.
Annual Health Checkup
An additional compliance for employers that the OSH Code imposes on every employer is the duty to provide free annual health examinations to such class of employees above an age prescribed by the appropriate Government. Rule 5 of the OSH Rules, introduces that every employer of dock work, building or other construction work shall arrange free of cost medical check-up for every employee over the age of 40 (forty). Such employers should note that, depending on workforce size, this obligation may increase both compliance costs and documentation requirements.
Welfare Facilities
Earlier, canteen thresholds and requirements of various welfare facilities, including crèche obligations, washing facilities, rest rooms, and first aid requirements, varied by sector and by statute. The OSH Code consolidate these into a common set of welfare obligations applicable across all covered establishments, with uniform thresholds and prescribed standards for each facility in Chapter VI of the OSH Rules. The practical effect is that employers to whom these provisions apply who previously operated under sector-specific regimes must now audit their welfare infrastructure against a single, horizontally applicable benchmark.
The Industrial Relations (Central) Rules, 2026 (“IR Rules”)
The Industrial Relation Code, 2020 (“IR Code“) consolidated 3 (three) expansive labour statutes — the Trade Unions Act, 1926; the Industrial Employment (Standing Orders) Act, 1946; and the Industrial Disputes Act, 1947 — into a single legislative instrument, thereby streamlining India’s historically fragmented labour law landscape into a more cohesive and unified industrial relations framework. The IR Rules, notified in supersession of the Industrial Disputes (Central) Rules, 1957 and the Industrial Employment (Standing Orders) Central Rules, 1946, assume particular significance as they operationalize this legislative consolidation by translating the broader objectives of the Industrial Relations Code, 2020, into an actionable compliance and governance framework for employers, establishments, and industrial stakeholders.
Sector-Specific Model Standing Orders
Section 29 of the IR Code moved away from the “one-size-fits-all” approach to model standing orders that characterized the predecessor Industrial Employment (Standing Orders) Act, 1946, by expressly empowering the Central Government to formulate sector-specific model standing orders rather than a single uniform template, thereby acknowledging that India’s industrial diversity across sectors could not be governed by one overarching framework. The Model Standing Orders, 2026, prescribed under Rule 10 of the IR Rules provides 3 (three) sector-specific distinctions by prescribing separate instruments for: (i) manufacturing sector; (ii) mining sector (with Rail Travel Facility extended to all mining workers); and most notably (iii) the services sector, which for the first time brings the services sector under formal standing orders coverage and codified contemporary work arrangements including work-from-home provisions, IT-specific working hours determined by employer-worker agreement, IT security misconduct (unauthorized access to IT systems), and worker classification. Chapter IV of the IR Rules further supplements the procedural machinery to achieve this statutory vision by regulating the submission of draft standing orders, certification and deemed certification timelines (with a 30 (thirty) day objection timeline), authentication of certified standing orders and modification procedures.
Grievance Redressal Committees
The IR Code introduced the mandatory requirement for industrial establishments employing 20 (twenty) or more workers to constitute Grievance Redressal Committees (“GRCs“), establishing a statutory framework for workplace dispute resolution. The IR Rules formalize and operationalize the manner of choosing GRC members (Rule 6(2)), procedures for filing grievances under Rule 7 (including electronic filing through designated portals) and the escalation process to conciliation officers when GRC decisions are not reached or disputed (Rule 8).
Negotiating Councils Framework
One of the most significant institutional reforms introduced under the IR Rules relates to the formal recognition framework for negotiating unions and negotiating councils. Rule 9 operationalizes Section 14 of the IR Code by prescribing the detailed framework governing: (i) matters for negotiation (Rule 9 (1)); (ii) verification of membership (Rule 9 (4) and (5)); and (iii) recognition validity of recognition (Rule 9 (6)). In addition to the substantive reforms discussed above, the IR Rules also seek to consolidate labour administration into a significantly more centralized and digitized compliance architecture by recognizing electronic filings, portal-based submissions, online service of notices, and digitally maintained records across a wide range of industrial relations processes, including settlements, conciliation proceedings, standing orders, retrenchment notices, recognition disputes, and employee complaints. This increased digitization is likely to materially enhance procedural traceability, evidentiary accountability, and documentation expectations for employers.
Conclusion
India’s labour law reform exercise has now moved decisively from legislative consolidation to implementation architecture. Collectively, the four labour Codes and corresponding Central Rules signal a transition toward a unified, documentation-intensive, technology-driven compliance regime, compelling employers to reassess workforce structures, governance systems, employment practices, and enterprise-wide compliance preparedness. As noted in our previous article, state governments are yet to notify their corresponding rules, and employers would be well advised to monitor state-level developments closely as those frameworks are rolled out.













