Labour Code Compliance Calendar

On Tuesday, 4 August 2026, the HR head of the 220-person electrical equipment manufacturer in Pune sat in the conference room with the FY 2026-27 compliance calendar spread on the table in front of her. A single A2 year planner, printed at the start of April after the FY 2026-27 salary restructure had cleared, ran from 1 April 2026 to 31 March 2027 along the long axis. Down the short axis ran every statutory obligation under the four Codes the establishment carried: foundational items already done and maintained, monthly items repeating with payroll, annual items booked against named months, and event-triggered runbooks indexed in a separate folder beside the planner. Cells in the planner were either coloured (action booked, owner assigned, supporting document filed) or marked dormant (the obligation did not apply at the establishment's threshold band). The planner was the operating layer of everything the preceding articles in this series had walked into substance.

Across the planner, the year so far read in artefacts: the Grievance Redressal Committee reconstituted on 1 January under Section 4 of the Industrial Relations Code, 2020; the 21-day Section 40 notice for the FY 2026-27 salary restructure dated 6 April; the first wage payment under the recomputed wage base released on 5 May for April wages under Section 17(1)(iv) of the Code on Wages, 2019; the 21-day Section 40 notice for the second-line evening shift dated 18 May; the dangerous-occurrence report under Section 11 of the Occupational Safety, Health and Working Conditions Code, 2020 filed on 9 June for the 5 June hose burst; the inter-state migrant intake of fifteen workers from West Bengal beginning the day-one journey-allowance accrual under Section 61; the senior production technician's gratuity payment under Section 53 of the Code on Social Security, 2020 due by 16 August on the thirty-completed-year retirement; the press operator's nursing-break schedule under Section 66 running until October 2027; the senior production supervisor's employees' compensation reimbursement under Chapter VII reconciled in mid-July. Each artefact sat against its calendar position, owner, and supporting file reference.

Three classes of items still ran across the year. Monthly recurrers had cleared April through July; August through March remained, each carrying the same eight obligations (the 5th-of-the-month wage payment under Section 17(1)(iv); the 12th-of-the-month employer and employee EPF deposit against the 15th deadline under paragraph 38(1) of the saved EPF Scheme, 1952; the 12th-of-the-month ESI deposit against the 15th deadline under regulation 31 of the saved ESIC Regulations, 1950; the cadre-wise minimum wage check on every Maharashtra Office of the Commissioner of Labour notification; the wage register update; the overtime register update; the register of fines and damage-or-loss deductions update; and the end-of-month review of any accidents, dangerous occurrences, or notifiable diseases under Sections 10, 11, and 12 of the OSH Code). Annual one-shots booked against named months filled the second register: the FY 2026-27 statutory bonus payable by 30 November 2027 under Section 39 of the Code on Wages; the calendar-year leave register close under Section 32 of the OSH Code on 31 December 2026; the OSH Code annual return as notified; the September safety audit; the Section 61 inter-state migrant journey allowance lump sum due on the engagement's anniversary; the cadre-wise 50% rule review and recompute booked for March 2027 ahead of the FY 2027-28 rollover. Event-triggered runbooks waiting on the day they fire filled the third: the 2-working-day exit under Section 17(2); the 30-day gratuity payment under Section 56(3); the Section 10 accident notification; the Section 11 dangerous-occurrence notification; the Section 12 notifiable-disease notification; the Section 40 21-day notice for any further Third Schedule change; the Section 3(4) 30-day intimation for any change in establishment particulars; the chapter IX retrenchment workflow with the Section 83 contribution to the Workers' Re-Skilling Fund.

The substance was set when the preceding articles in this series walked through each Code in operation. This article strings it against time. Cadence is what an HR team owns.

In force from 21 November 2025 across all four Codes, the obligations that fill the planner sit almost entirely in the live-and-self-executing first layer of the three-layer rollout, with two material items in the held-back layer: the Re-Skilling Fund's collection account, reconciliation procedure, and disbursement rules under Section 83 of the IR Code; and the rate within the 1% to 2% band and the commencement date for aggregator contributions under Section 114(5) of the SS Code. Provisional items running on saved older-Act notifications under the parallel saving clauses read with Section 6 of the General Clauses Act, 1897 (the EPF deposit deadline of paragraph 38(1) of the Scheme, 1952; the ESI deposit deadline of regulation 31 of the ESIC Regulations, 1950; the BOCW cess rate of 1% under the legacy 1996 notification) flow into the planner without disruption while the final Central Rules notify in stages through FY 2026-27.

This reference holds the article's body sections, walked through bucket by bucket below.

Foundational items are done once and maintained. A new foundational item triggers when the establishment first crosses a new threshold; the registration filed against the older threshold sits as the maintained baseline, and the new threshold's incremental obligation attaches as its own foundational event. The Pune manufacturer's foundational items had cleared by January 2026 across the four Codes, with the GRC reconstitution on 1 January 2026 the most recent recurrence. Twelve foundational items sit on the day-1 list for any mid-sized employer.

Two items on the list bear flagging. Trilingual format on the notice board runs on Section 50(2) of the Code on Wages read with the still-draft Central Rules; the English-Hindi-and-local-language requirement sits in the Rules rather than on the face of the Code itself, and the local language is the one understood by the majority of employees rather than the State's official language by default. The crèche obligation runs on two separate Code sections that read slightly differently: Section 24(3) of the OSH Code triggers at "more than fifty workers ordinarily employed", with the crèche provided for children below six years of the establishment's employees; Section 67 of the SS Code triggers at "fifty or more employees" on a gender-neutral parent text. At exactly 50, only the SS Code triggers; below 50, neither triggers; above 50, both trigger. Run the count under both Codes in parallel on every threshold review, and crèche the lower of the two thresholds.

For the Pune manufacturer, the foundational set was complete: Section 3 registration as a deemed-registered factory under the saved Factories Act intimation in November 2025; the Section 119 common licence application filed in February 2026 against the still-draft format with issuance pending the final OSH Central Rules; notice board in English, Hindi, and Marathi at the main entrance with all five Section 50(2) items current; monthly wage period stated in every appointment letter and on the notice board; appointment letters issued to all 220 employees within the 21 February 2026 window; Standing Orders not yet applicable (192 workers, below the 300-worker threshold); GRC reconstituted on 1 January 2026; Works Committee not constituted in the absence of a Maharashtra Government direction; EPF and ESI registrations opened years earlier and current; gratuity coverage attaching by virtue of the establishment being a factory; baseline welfare and welfare-ladder items current including the contracted-out crèche under Section 24(3) of the OSH Code and Section 67 of the SS Code; gazette subscriptions running on the Maharashtra Office of the Commissioner of Labour, the Central Ministry of Labour and Employment, and the Centre's PIB; provision recognised on the books for the Section 83 Re-Skilling Fund liability against any future retrenchment, with no aggregator obligation arising (the manufacturer not falling within any of the nine Seventh Schedule categories).

Eight items recur every month. Most are date-anchored to the wage period; a few run against statutory deadlines that do not bend to a company calendar (the EPF and ESI 15th-of-the-succeeding-month rule); the cadre-wise minimum wage check runs whenever the State Government notifies a fresh rate, irrespective of the company's monthly review cycle.

Both EPF and ESI deposits run on a 15th-of-the-succeeding-month rule under instruments older than the Codes: paragraph 38(1) of the Employees' Provident Funds Scheme, 1952 with the EPFO Circular of 8 January 2016 removing the earlier 5-day grace period; regulation 31 of the Employees' State Insurance (General) Regulations, 1950. The saving clauses under the SS Code (Section 164(2)(b) for the EPF Schemes; Section 29 read with Section 157 for the ESIC Regulations) carry these older instruments forward into operation. Deadlines on the face of the SS Code itself are silent; the live deadlines live in instruments saved into operation by the Code.

The Pune manufacturer's monthly payroll cycle ran on the 5th of each succeeding month for monthly-paid employees, two days inside the seven-day Section 17(1)(iv) deadline. EPF and ESI deposits cleared on the 12th of each succeeding month, three days inside the 15th cut-off. Register updates ran on the last working day of each month, with electronic captures backed up to the Pune-and-Mumbai dual-data-centre HR system. Cadre-wise minimum wage checks ran on every Maharashtra Commissioner of Labour notification, with the rate change captured on the wage register and the notice board on the same day. Exit reviews and the OSH-event review ran in the same end-of-month meeting between the HR head and the works manager.

Ten items recur on an annual cycle. Some run on the financial year (1 April to 31 March), some on the calendar year (1 January to 31 December), and one runs on the engagement-anniversary clock for inter-state migrant workers.

Two items on the annual list carry the largest financial weight at most mid-sized employers. The annual cadre-wise 50% rule review runs the recomputation walked in The 50% Wage Rule against the cadre-level salary structures, with the recomputed wage base flowing into PF under Section 16 of the SS Code, gratuity under Section 53 of the SS Code, statutory bonus under Sections 26 and 41 of the Code on Wages for cadres at or below the bonus eligibility ceiling, retrenchment compensation under Section 70(b) of the IR Code, and the Section 83 Re-Skilling Fund contribution. Companies that do not run the annual review compound the gap year on year; the catch-up surfaces on the next inspection or the next salary structural change. Statutory bonus payment under Section 39 of the Code on Wages runs to a fixed deadline on the accounting year close: bonus for the accounting year 1 April 2026 to 31 March 2027 is payable by 30 November 2027, regardless of the company's book-closure date for financial-statement purposes.

The Pune manufacturer's annual cadence ran across the FY 2026-27 planner as follows: the FY 2026-27 cadre-wise 50% rule review on 6 to 24 March 2026 ahead of the rollover (see The 50% Wage Rule); the Section 119 common licence renewal scheduled at five years from issuance, with the issuance date pending the final OSH Central Rules; the journey allowance to the fifteen West Bengal inter-state migrant workers due at the end of the second engagement-year for any worker who renewed beyond the initial three-month term; the annual health check-up programme for the 78 employees aged 45 and above running on a rolling basis through June, July, and August 2026 against the empanelled occupational-health centres in Pune; the sector-specific safety audit booked for September 2026; the calendar-year leave register close on 31 December 2026 with the carry-forward and encashment computation running over the first week of January 2027; the FY 2026-27 statutory bonus payment booked on the planner for 30 November 2027; and the next FY 2027-28 cadre-wise 50% rule review booked for early March 2027.

Event-triggered runbooks sit dormant until the event fires. The day of the event becomes the day-zero of the clock, and the clock runs to the deadline the Code section prescribes. Build the runbook before the event so the work does not depend on memory under pressure.

Three actions fire on day one of any new hire. The appointment letter goes out under Section 6(1)(f) of the OSH Code in the form prescribed by the appropriate Government, with wage period, nature of work, fixed-term duration where applicable, place of posting, hours of work, and wage rate captured. PF and ESI registrations open, and the Universal Account Number for PF and the Insurance Number for ESI are allocated. The attendance record opens on the muster roll and the wage register from the first day worked.

An exit by removal, dismissal, retrenchment, resignation, or closure-induced unemployment fires the two-working-day clock under Section 17(2) of the Code on Wages. Wages, as defined under Section 2(y), clear within two working days of the date of exit. Other terminal dues run on their own clocks: gratuity under Section 56(3) of the SS Code carries 30 days from the date of becoming payable, with simple interest accruing on delay beyond that date under Section 56(4); PF withdrawal runs on the EPF Scheme's claim-and-settlement process; leave encashment under Section 32 of the OSH Code or the contract runs on its own framework. Track each clock separately against the same exit event.

Maternity onset under Chapter VI of the SS Code fires the 26-week leave benefit under Section 60(3) for natural birth (or 12 weeks under the proviso for a woman with two or more surviving children), the medical bonus under Section 64 (₹3,500 carried forward from the saved 2011 notification), the protection against dismissal under Section 68, and the protection against wage deduction under Section 69. The 12-week benefit for adoptive and commissioning mothers under Section 60(4) fires from the date the child is handed over, regardless of the child's age, after the Supreme Court's read-down in Hamsaanandini Nanduri v. Union of India, 2026 INSC 246, dated 17 March 2026. Nursing breaks under Section 66 run twice per working day from the maternity return-to-work date until the child turns fifteen months. Crèche obligation under Section 67 of the SS Code attaches at the establishment level once 50 or more employees are on payroll.

An accident causing death or bodily injury preventing work for 48 hours or more, or any prescribed nature of accident, fires the Section 10 notification under the OSH Code. A dangerous occurrence at the workplace, with or without bodily injury, fires the Section 11 notification. Notifiable diseases (29 entries in the Third Schedule of the OSH Code) fire the Section 12 notification when contracted by a worker. Forms, timelines, and authorities run separately across the three; one event may trigger one, two, or all three notifications, and the day-of-event runbook walks all three before any single filing closes the protocol. Where the accident causes death and occurs in a plantation, in building or other construction work, or in any other establishment that is not a factory or a mine, Section 10(2) carries the additional two-month inquiry-by-prescribed-authority rule.

Any change in the eleven Third Schedule service conditions fires the 21-day notice under Section 40 of the IR Code. Wages, including the wage period; employer contribution to provident or pension funds; compensatory and other allowances; hours of work and rest intervals; leave with wages and holidays; starting, altering, or discontinuing shift working otherwise than in accordance with standing orders; classification by grades; withdrawal of customary concession or change in usage; introduction or alteration of discipline rules other than standing orders; rationalisation, standardisation, or improvement likely to cause retrenchment; and any non-casual increase or reduction in persons employed in any occupation, process, department, or shift all sit in the Schedule. The 21-day clock runs from the date the notice issues to the affected workers in the prescribed manner; the change can take effect on day 22 at the earliest.

When establishment particulars change (the address, the occupier or owner, the nature of work, or the headcount band), the 30-day intimation clock fires under Section 3(4) of the OSH Code. The intimation runs electronically to the Registering Officer, and the change records on the deemed-registered or registered file.

Retrenchment fires the chapter IX or chapter X workflow depending on the worker count. Establishments below 300 workers, irrespective of whether they sit above or below 50 workers, run chapter IX (Sections 65 to 76) for retrenchment under Section 70: one month's notice or wages in lieu under Section 70(a), 15 days' average pay per completed year of continuous service under Section 70(b), 15 days' last-drawn wages to the Workers' Re-Skilling Fund under Section 83 (credited within 45 days under Section 83(3)), and notice to the appropriate Government before the action takes effect. The 50-worker floor in the Section 65(1)(a) Explanation is the trigger for chapter IX lay-off compensation under Sections 67 to 69, not for chapter IX retrenchment, which attaches without a numerical worker-count minimum on a worker who has completed one year of continuous service. Establishments at 300 workers and above run chapter X (Sections 77 to 82), with prior permission from the appropriate Government, three months' notice under Section 79(1)(a), and the same Section 70(b) and Section 83 entitlements. The Re-Skilling Fund collection mechanics sit in the held-back layer; the substantive liability is live, with the collection account, reconciliation, and disbursement rules pending separate notification.

Lay-off in a 50-to-299 worker industrial establishment (factory, mine, or plantation under the Section 65 Explanation) fires the chapter IX lay-off-compensation workflow under Sections 67 to 69 of the IR Code, with 50% of basic plus DA per laid-off day, one year of continuous service required, and a 45-day cap during any rolling 12-month period subject to agreement between the worker and the employer. A lay-off in a 300-worker-and-above establishment fires the chapter X workflow with prior government permission under Section 78.

Closure fires the 60-day notice under Section 74 (chapter IX) or the 90-day notice with prior permission under Section 80 (chapter X), with closure compensation to affected workers and the Section 75 unavoidable-circumstance cap of three months' average pay where the trigger qualifies (the Explanation excludes financial difficulties, accumulation of stocks, expiry of a lease, and exhaustion of minerals from "unavoidable circumstances").

Strike notice received from workers, or a lockout notice issued by the employer, fires the Section 62(6) reporting clock under the IR Code: report to the appropriate Government and the Conciliation Officer within 5 days of the notice received or issued. A strike or lockout already in existence on the date it is declared fires the Section 62(3) same-day reporting clock.

Contractor default on wage payment, PF deposit, or welfare provision under the OSH Code fires the principal-employer step-in under Section 53 (welfare) and Section 55(3) (wages), with recovery from the contractor pursued separately. Engagement of an unlicensed contractor is itself an offence on the principal employer under Section 54 of the OSH Code, irrespective of any reliance on contractor representations.

On BOCW project completion, the cess payment fires under Chapter VIII of the SS Code, currently at the 1% rate notified under the older Building and Other Construction Workers' Welfare Cess Act, 1996 (S.O. 2899 of 26 September 1996) within the 1% to 2% statutory band that Section 100(1) of the SS Code has carried forward. The 1996 Cess Act was itself repealed by item 8 of Section 164(1) of the SS Code from 21 November 2025; the rate notification and the BOCW Welfare Cess Rules, 1998 framework continue in operation through the savings clause in Section 164(2). The cess is payable within 60 days of completion under Section 103(1) of the SS Code, or within such other period as the Central Government has notified. For projects exceeding one year, an annual cess payment runs at the end of each year against the year's incremental construction cost, on the saved 1998 Rules framework.

Transfer of ownership or management fires the Section 73 IR Code workflow, with notice and retrenchment compensation to workers carrying one year or more of continuous service, unless the provisos to Section 73 apply (uninterrupted service preserved, terms not less favourable, and the new employer assuming liability).

Build a written runbook for each event class before the event fires. The first time a runbook is needed is the wrong time to draft it. Assign an owner, a backup owner, and a 24-hour cover for any event class that runs on a clock shorter than 5 days (the 2-working-day exit; the same-day strike or lockout report; the day-of-event accident notification; the day-of-event dangerous-occurrence notification).

Take the founder of the 30-person printing-and-packaging press in Coimbatore, on Monday 16 March 2026, at her 30-employee, 22-worker count.

Foundational items walk one at a time: Section 3 OSH Code registration carrying forward as deemed-registered against the saved older-Act intimation under Section 3(8), with the change-in-particulars 30-day intimation clock under Section 3(4) running on the next change; appointment letters to all 30 existing employees not issued within the 21 February 2026 window (now closed), with back-dated retrospective letters issuing on a Section 6(1)(f)-format compliance note; trilingual notice board in English, Tamil, and Hindi at the main entrance carrying all five Section 50(2) items current; the wage period stated in every appointment letter and on the notice board; the Grievance Redressal Committee at the 22-worker count constituting within the next two weeks (the establishment four months past the constitution date on 16 March 2026); Standing Orders and Works Committee both inapplicable at 22 workers (far below the 300-worker Section 28(1) and 100-worker Section 3 thresholds); EPF, ESI, and gratuity registrations open and current (gratuity attaching at the 10-employee shop threshold under Chapter V of the SS Code); the Section 23 welfare baseline in place (cleanliness, ventilation, lighting, drinking water, latrines, waste disposal); rest rooms, canteen, and crèche not yet triggered (the 50-worker, 100-worker, and 50-worker/50-employee thresholds uncrossed across the OSH Code and the SS Code); gazette subscription running to the Tamil Nadu Office of the Commissioner of Labour and the Centre's MoLE notifications.

Monthly cadence: monthly wage payment by the 7th-of-the-succeeding-month under Section 17(1)(iv); wage slips on or before payment; EPF and ESI deposits by the 15th-of-the-succeeding-month under the saved Schemes; register updates at wage-period close; cadre-wise minimum wage check against Tamil Nadu notifications; exit review; OSH-event review.

Annual cadence: OSH annual return; statutory bonus for FY 2026-27 by 30 November 2027 (the 30-employee count crosses the Section 41(2) bonus chapter applicability threshold of 20 persons, so the bonus duty attaches); annual health check-ups for any employees aged 45 and above (against the prescribed-classes scope under the Tamil Nadu OSH Rules); minimum wage notice-board refresh at the start of each financial year; the cadre-wise 50% rule review.

Event-triggered: same runbooks as for any establishment, attaching when each event fires. None of the chapter X retrenchment, closure, or lay-off triggers attach at the 22-worker count; chapter IX retrenchment under Section 70 attaches without a numerical worker threshold and runs on the same notice, compensation, and Section 83 Re-Skilling Fund contribution as for any larger establishment.

The 30-person establishment carries every item on the always-applies list and a few items on the threshold list (registration at 10 employees; appointment letter; GRC at 20 workers; PF at 20 employees; ESI at 10 persons; bonus at 20 persons; gratuity in factories, mines, oilfields, plantations, ports, and railway companies, or in any other shop or establishment with 10 or more employees on any day in the preceding 12 months). Most items on the threshold list sit dormant. The compliance footprint is tractable for a one-person HR generalist who also runs vendor invoices, provided the foundational items are caught up against the missed windows and the annual cadence is booked.

Take the head of HR of an 800-person automotive component plant near Chennai, on the morning of Tuesday 4 August 2026, planning the FY 2026-27 calendar.

Foundational items: registered factory under Section 3 of the OSH Code; common licence under Section 119 covering factory operations and a 75-contract-worker engagement; trilingual notice board in English, Tamil, and Hindi at the main entrance and at the contract-worker assembly area; monthly wage period stated in every appointment letter; appointment letters issued to all 800 employees within the 21 February 2026 window; Standing Orders applicability under Section 28(1) of the IR Code (the establishment sits at 720 workers, above the 300-worker threshold) with the Model Standing Orders adopted under Section 30(3) and the adoption intimated to the Tamil Nadu Certifying Officer in February 2026; GRC constituted on 28 November 2025 with 5+5 employer-worker representation; Works Committee constituted on a Tamil Nadu Government order issued in March 2026; EPF and ESI registrations current; gratuity coverage on the factory trigger; baseline welfare and welfare-ladder items in place: rest rooms, shelters, and lunchroom under Section 24(2)(iii); canteen above 100 workers under Section 24(1)(v); crèche above 50 workers under Section 24(3) of the OSH Code and 50 employees under Section 67 of the SS Code; welfare officer above 250 workers under Section 24(2)(iv); ambulance room above 500 workers in a factory under Section 24(2)(i), triggered at the establishment's 720-worker count; safety officer on the rolls under the 500-worker factory trigger of Section 22(2). Gazette subscriptions running across the Tamil Nadu Office of the Commissioner of Labour, the Centre's MoLE, and the PIB. Provision recognised on the books for the Section 83 Re-Skilling Fund liability against any retrenchment in the 720-worker chapter X regime, where the cash impact runs materially higher than the chapter IX equivalent (see Industrial Relations Code 2020 Guide).

Monthly cadence: same eight items as the Pune manufacturer, with EPF and ESI deposit volumes scaled to the 800-employee population and the wage register update running across a longer cadre map.

Annual cadence: same ten items, with three additional weights at this scale: the cadre-wise 50% rule review across the 800-employee population runs higher cumulative cost (the annual employer PF lift compounds across every cadre carrying excluded-basket-heavy structures, before the gratuity provisioning ladder runs); the annual health check-up programme covers a larger cohort aged 45 and above; the contractor compliance review runs across two or three contractors engaging 75 contract workers in total, with separate licence verifications, wage register reads, and PF/ESI deposit verifications per contractor.

Event-triggered runbooks cover every event class. The chapter X regime attaches across retrenchment, closure, and lay-off at the 720-worker establishment, with prior-permission processes adding time and uncertainty to any cash outlay (see Industrial Relations Code 2020 Guide).

The 800-person establishment carries almost every item on the threshold list. Compliance footprint at this scale demands a four-person HR team, a separate payroll function, an in-house company secretary, and an external labour-law lawyer on retainer. Volume is what differs from the 30-person Coimbatore press; the structure of the calendar is the same.

Two operating principles separate a working calendar from a checklist on paper.

Every recurring item gets owned by a person with a recurring calendar reminder. The ownership is single-point: one HR officer is responsible for the EPF deposit cycle, with a backup named for cover; one HR officer owns the wage-register update at the close of the wage period, with a backup; one HR officer owns the cadre-wise minimum wage check on every State notification. A recurring item without a named owner is the recurring item that gets missed.

Written runbooks own every event-triggered item. Each runbook names the trigger, the day-zero reference event, the immediate-action steps, the Code section, the deadline, the form, the recipient authority, the document retention, and the owner with a backup. The first time a runbook is needed is the wrong time to draft it. Quarterly walk-throughs with the affected owners keep the runbooks current; the two-working-day exit, the same-day strike-or-lockout report, the day-of-event accident notification, and the 21-day Section 40 notice each carry their own runbook in the Pune manufacturer's HR file.

This article builds the calendar. Labour Code Implementation Plan closes the series with the eight failure patterns that recur across compliance audits under all four Codes, the third-layer (held-back) liabilities to provision for now, and a 90-day starter plan that takes a typical company from where it is now to a working compliance baseline.