Labour Code Implementation Plan

The series has covered four Codes, twenty-nine older Acts repealed across the four Codes (four under the Code on Wages Section 69, three under the IR Code Section 104, thirteen under the OSH Code Section 143, and nine under the SS Code Section 164(1)), several dozen sections, and a handful of dates. The earlier articles in this series walked the substance into operation: the three layers of the rollout from 21 November 2025; the four Codes and what each one owns; the employee-versus-worker distinction that decides every threshold; the 50% rule that recomputes the wage base across every monetary obligation; the Wage Code, the Industrial Relations Code, the Occupational Safety, Health and Working Conditions Code, and the Code on Social Security in operation; and the compliance calendar that strings the year against time. This article is the closing review.

Most of what an HR or finance team does on the four Codes is picked up correctly through the earlier articles in this series. Eight failure patterns recur stubbornly, and they recur even at organisations that have read the substance and built the calendar. They turn up at audits, at inspections, at internal reconciliations, and at the moment a notification clock fires. Each pattern is the same shape underneath: a duty that looks settled until it cascades into the next ledger or the next threshold check, and the cascade goes missing.

Two material liabilities under the four Codes are live in policy and pending in operation. The Workers' Re-Skilling Fund under Section 83 of the Industrial Relations Code attaches at every retrenchment from 21 November 2025 onward, and the Fund's collection account, reconciliation procedure, and disbursement rules sit in the held-back layer pending separate notification. Aggregator contributions under Section 114(4) of the Code on Social Security are payable at a rate within the 1% to 2% band yet to be fixed under Section 114(5), with a commencement date also yet to issue. Both items accrue today against the relevant trigger event; the catch-up hits the P&L the quarter the collection mechanics notify, which is what provisioning now prevents.

A 90-day plan closes the loop. Days 1 to 30 audit the establishment against each Code, each section, and each threshold. The middle thirty days remediate the cadre-wise structures, the registers, the appointment letters, and the third-layer provisions. Days 61 to 90 institutionalise the runbooks, the training, and the calendar. Ninety days closes the loop on the four Codes.

In force from 21 November 2025 across all four Codes, the substantive duties below have applied since the commencement date. Final Central Rules under each Code remained pending as of 25 April 2026; State Rules continued to notify state by state; the Ministry of Labour and Employment's Additional FAQs of 16 March 2026 carried the current authoritative interpretive position, directing employers to apply saved older-Act notifications and the still-draft Central Rules until final Rules notify under each Code. Almost every duty across the four Codes sits in the live-and-self-executing first layer of the rollout, with two material items in the held-back layer (the Re-Skilling Fund's collection mechanics 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), and a third item suspended on item 3 of Section 164(1) of the SS Code (the EPF Act, 1952 repeal entry, with the EPF Scheme 1952, the EDLI Scheme 1976, the EPS 1995, and the EPF Tribunal (Procedure) Rules 1997 saved through 21 November 2026 unless extended). The eight mistakes below are the patterns that catch employers under all three layers.

This reference holds the article's body sections, walked through in turn below.

The recomputed wages number from the 50% rule flows into every monetary obligation under the four Codes. PF contribution under Section 16 of the Code on Social Security; gratuity under Sections 53 and 56 of the SS Code with the 26-day divisor under Explanation 3 to Section 53(2); statutory bonus under Sections 26 and 41 of the Code on Wages; retrenchment compensation under Section 70(b) of the IR Code (read with the average-pay definition in Section 2(d)); the Re-Skilling Fund contribution under Section 83 of the IR Code on 15 days' last-drawn wages; leave encashment under Section 32 of the OSH Code; maternity benefit under Section 60(3) of the SS Code on the average daily wage for the period of actual absence: each of the seven runs on the recomputed wage base. Most payroll systems update the PF base automatically. The bonus engine, the gratuity provisioning ledger, and the retrenchment cost calculator often sit on the older base because they live with finance rather than HR. Not cascading the 50% rule beyond PF is the first.

The fix runs at the cadre level. Run the 50% recomputation once per cadre at the start of each financial year; compute the delta in every downstream liability; update the ledger provisions in one pass. The Pune electrical equipment manufacturer used through the preceding articles in this series carried a ₹14,400-per-employee annual employer PF lift on its senior production engineer cadre, with a ₹28,846 five-year gratuity provisioning lift in parallel; the cumulative number across 60 cadres of that profile ran ₹8.64 lakh annually on PF and ₹17.30 lakh on five-year gratuity provisioning, before any retrenchment cost ran.

Workers are the count under the IR Code and the OSH Code; employees are the count under the Code on Wages and the Code on Social Security. A senior production engineer at ₹70,000 fixed monthly remuneration is an employee for the Wage Code and the SS Code, contributing toward the 20-employee PF threshold under Chapter III of the SS Code, and is not a worker for the IR Code under Section 2(zr) and not a worker for the OSH Code under Section 2(1)(zzl). A floor supervisor at ₹16,000 sits in both counts. The same supervisor at ₹22,000 sits in the employee count and outside the worker count by virtue of the ₹18,000 cap of Section 2(zr)(iv) of the IR Code and Section 2(1)(zzl)(iv) of the OSH Code. Counting employees when the threshold is in workers, or workers when the threshold is in employees, is the second.

Maintain two counts side by side in the HR file. Apply the worker count to the 20-worker GRC trigger under Section 4 of the IR Code, the 100-worker Works Committee trigger under Section 3, the 300-worker Standing Orders trigger under Section 28(1), and the chapter X regime under Section 77 onward. Apply the employee count to the 20-employee PF threshold, the 10-employee bonus chapter applicability under Section 41(2) of the Code on Wages, and most other Wage Code and SS Code thresholds. Re-run both counts on every quarterly close, and re-document within five names of any threshold under either count.

The principal employer under the OSH Code carries chain-of-liability for the contractor's failures. Welfare provision sits in Section 53, where the principal employer steps in if the contractor falls short on Sections 23 and 24. Wage default sits in Section 55(3), where the principal employer pays the contract worker's wages and recovers from the contractor separately. Engaging an unlicensed contractor is itself an offence on the principal employer under Section 54, irrespective of any reliance on contractor representations. Treating contract labour as arms-length is the third.

A vendor-management approach that ends with an executed services agreement does not protect the principal employer. Active audit at engagement and on a recurring quarterly cadence is the operational fix: contractor licence verification under Section 48, wage register read, PF and ESI deposit verification, welfare provision check, and contract-worker accident notification protocol. Contract labour above the 50-worker threshold of Section 45 of the OSH Code is also caught by an additional layer of central licensing under Section 47 read with Section 48; manpower-supply contractors with 50 or more contract workers on any such day in the preceding 12 months sit in the same chain.

Thresholds under the four Codes apply at the establishment level, not at the enterprise level. A company with three offices of eight employees each, one each in Pune, Bengaluru, and Chennai, has no single establishment that crosses the 10-employee OSH-registration threshold under Section 3 or the 10-person ESI threshold under Section 1(4) of the SS Code. The same twenty-four employees in one office cross both. Section 2(3) of the SS Code carries a multi-state branch exception where branches in different states are treated as one establishment for limited PF and ESI purposes. Counting at enterprise level instead of establishment level is the fourth.

The fix is to treat every location as a standalone unit. Run the threshold map separately for each office, each plant, and each warehouse. Apply Section 2(3) of the SS Code where it operates; do not assume it operates as a default. The Coimbatore printing-and-packaging press, with 30 employees in a single location, was a 30-employee establishment for the Wage Code and the SS Code; the same thirty people split across three offices of ten each would have been three 10-employee establishments under the OSH Code, three 10-person establishments for ESI, and three offices below the 20-employee PF threshold of Chapter III of the SS Code.

Section 17(2) of the Code on Wages requires that wages, as defined under Section 2(y), be paid within two working days of removal, dismissal, retrenchment, resignation, or unemployment due to closure of the establishment. Two working days is short and inflexible. Most payroll systems run on a monthly cycle and clear exit wages through the next payroll run; the practice was tolerable under decades of relaxed enforcement on the older Section 5(2) of the Payment of Wages Act, 1936, and the Code's Inspector-cum-Facilitator regime under Section 51 is materially tighter on the point. Other terminal dues run on their own clocks: gratuity within 30 days under Section 56(3) of the SS Code with simple interest accruing under Section 56(4) on delay; PF withdrawal on the EPF Scheme's claim-and-settlement process; leave encashment under Section 32 of the OSH Code or the contract. Processing exit dues through the next payroll cycle is the fifth.

Out-of-cycle release with named weekend cover is the operational fix; a Friday exit clears by Tuesday morning at the latest under the two-working-day clock. Maintain a separate event tracker for gratuity, PF withdrawal, and leave encashment against their respective deadlines. Retain the bank-transfer proof and the dues-ledger sheet in the employee file against an Inspector-cum-Facilitator's request to verify the timeline.

Section 40 of the IR Code requires every employer to give 21 days' notice in the prescribed manner before any change in the conditions of service applicable to workers, where the change falls into any of the eleven categories listed in the Third Schedule. Wages, including the wage period and the mode of payment, sit in item 1; compensatory and other allowances sit in item 3; hours of work and rest intervals sit in item 4; leave with wages and holidays sit in item 5; introduction or alteration of shift working otherwise than in accordance with standing orders sits in item 6. Most salary restructuring sits inside item 1 or item 3, most shift changes sit inside item 6, and most leave-policy changes sit inside item 5. Missing the 21-day notice for Third Schedule service-condition changes is the sixth.

The notice carries statutory force as a precondition for the change to take effect. A change implemented without the notice is not validly in force. Write the Third Schedule into the HR change-management protocol, so no salary or shift change leaves the desk without the 21-day clock visibly running. Document the notice and the mode of delivery in the worker file against an Inspector-cum-Facilitator's request to verify compliance. The Pune manufacturer's FY 2026-27 salary restructuring was itself a Section 40 change, with the notice issued on 6 April 2026 and the recomputed wage base applied on the 27 April pay run; the audit trail in the HR file carried the notice text, the date, the mode of delivery, and the worker acknowledgements.

Two material liabilities under the four Codes are live in policy and pending in operation. The Workers' Re-Skilling Fund under Section 83 of the IR Code attaches at every retrenchment from 21 November 2025 onward: 15 days of the worker's last-drawn wages per retrenched worker, separate from and additional to the 15 days' average pay per completed year of continuous service under Section 70(b), credited to the worker's account within 45 days under Section 83(3). The Fund's collection account, reconciliation procedure, and disbursement rules sit in the held-back layer pending separate notification of the operating machinery. Aggregator contributions under Section 114(4) of the SS Code attach at 1% to 2% of annual turnover excluding tax, levy, and cess paid or payable to the Central Government, capped at 5% of the amount payable to gig and platform workers, across nine aggregator categories listed in the Seventh Schedule; the rate within the band and the commencement date sit in Section 114(5), pending Central Government notification. Treating third-layer (held-back) items as a future problem is the seventh.

Two actions close the gap. Book the liability on the company's books at the moment the trigger event runs (the retrenchment for Section 83; the gig or platform payment for Section 114(4) where the establishment falls within the Seventh Schedule). Ring-fence the cash so the contribution can be paid against accumulated events when the collection mechanics land. The Pune manufacturer's three-press-operator retrenchment from Industrial Relations Code 2020 Guide carried ₹15,000 per worker on Section 83, that is ₹45,000 in total, booked as accrued payable to the Fund alongside the ₹3,15,000 retrenchment compensation under Section 70(b) and the ₹90,000 notice pay under Section 70(a). The accumulated catch-up hits the P&L in the quarter the collection notification issues for any company that has not provisioned, with no operational cushion against the surprise.

Minimum wage rates under the Code on Wages run on Section 5 of the Code, with rates revised periodically by notification from the appropriate Government. Centrally regulated employments see Variable Dearness Allowance revisions half-yearly on 1 April and 1 October each year. State revisions run annually or at longer intervals, with separate half-yearly DA revisions in most states; the cadence varies state by state. A wage compliant on the date of hire can fall below a freshly notified state floor without any contractual change. Missing state-level minimum-wage notifications is the eighth.

The fix is a notification watch. Subscribe to the gazette of every state of operation; route alerts to a weekly HR-and-finance brief; re-run the cadre-wise minimum wage check on every notification; capture the rate change on the wage register and on the notice board on the same day. The Pune manufacturer's monthly cadre-wise minimum wage check ran on every Maharashtra Office of the Commissioner of Labour notification, with the rate change captured before the next payroll cycle. A multi-state employer carries a parallel watch on every state of operation, fed into the same weekly brief.

The held-back layer of the four-Code rollout carries two material liabilities and one suspended repeal. Each calls for a different action.

Section 83 of the Workers' Re-Skilling Fund is the first item. Substantive liability has applied since 21 November 2025 on every retrenchment under chapter IX or chapter X of the IR Code; the contribution is 15 days of the worker's last-drawn wages, or such other number of days as the Central Government may notify, separate from and additional to the retrenchment compensation under Section 70(b). Section 83(3) requires credit to the worker's account within 45 days of retrenchment. The Fund's collection account, the reconciliation procedure, and the disbursement rules sit in the held-back layer pending separate notification of the operating machinery; until that machinery notifies, the practical compliance approach is to book the liability on the company's books at the moment the retrenchment is effected, ring-fence the cash, and pay against accumulated retrenchment events when the collection mechanics land.

Aggregator contributions under Section 114(4) of the SS Code are the second item. The contribution attaches at 1% to 2% of the aggregator's annual turnover excluding tax, levy, and cess paid or payable to the Central Government, capped at 5% of the amount paid or payable to gig and platform workers in a financial year. Nine aggregator categories sit in the Seventh Schedule: ride-sharing services, food and grocery delivery services, logistics services, e-marketplace selling goods or services, professional services provider, healthcare, travel and hospitality, content and media services, and a residual catch-all for any other goods and services provider platform. The rate within the 1% to 2% band, the commencement date for the contribution, the return format, and the payment infrastructure sit in Section 114(5), with the Central Government's notification not yet issued as of 25 April 2026. As of that date, no aggregator is currently liable to remit a Central contribution; the framework liability is in force, the operational machinery is pending. Karnataka's Platform-Based Gig Workers (Social Security and Welfare) Act, 2025 (Karnataka Act No. 72 of 2025) sits alongside, with a statutory welfare-fee band of 1% to 5% per transaction and an operational rate notified at 1% to 1.5% with per-transaction caps (50 paise, 75 paise, and ₹1 by business model) at the time the Karnataka Platform-Based Gig Workers Welfare Board was constituted on 27 January 2026. Section 18(5) of the Karnataka Act provides that the State welfare fee counts toward the contribution payable under Section 114(4) of the Code on Social Security, with annual reconciliation, addressing the double-counting concern at the State-Centre interface. A national aggregator across multiple states will therefore eventually run a single consolidated contribution computation, with State-level welfare fees flowing into the Central contribution where the State-level fee is notified and the Section 18(5)-style interlock applies, rather than two parallel registers.

Item 3 of Section 164(1) of the SS Code is the third item, suspended rather than held-back. The entry lists the Employees' Provident Funds and Miscellaneous Provisions Act, 1952 for repeal, but was expressly excluded from the 21 November 2025 commencement notification. Section 164(2)(b) saves the EPF Scheme, 1952, the EDLI Scheme, 1976, the EPS, 1995, and the EPF Tribunal (Procedure) Rules, 1997 for one year from commencement, that is until 21 November 2026 unless extended. The EPFO contribution architecture continues unchanged through the transitional window. No fresh action is required on the suspension itself; it is an administrative state, not a compliance duty. What it generates is the watch: when the suspension lifts (by repeal taking effect or by extension of the savings clause), the contribution architecture under Chapter III of the SS Code takes over from the EPF Act framework, and the operational continuity needs to be planned ahead.

The provisioning recommendation runs at the upper bound of the band. For an aggregator within the Seventh Schedule with annual turnover of ₹100 crore and gig and platform worker payments of ₹40 crore, the upper bound under Section 114(4) is 2% of ₹100 crore (₹2 crore) or 5% of ₹40 crore (₹2 crore), the two limbs of the cap meeting at the same number; for the same aggregator with payments of ₹30 crore, the cap-binding figure runs at 5% of ₹30 crore (₹1.5 crore), below the 2% turnover figure. The lower of the two is what the provision is built against. Re-Skilling Fund provisioning runs as a per-retrenchment booking, with the cash ring-fenced in a separate account or sub-ledger.

The plan splits into three phases. Days 1 to 30 audit; days 31 to 60 remediate; days 61 to 90 institutionalise. Each phase carries its own deliverables, owners, and documentation set.

Days 1 to 30, the audit

The audit covers every Code, every Code section the establishment carries an obligation under, every threshold, and every timeline. Five workstreams run in parallel through the first 30 days.

Pull the cadre-wise fixed monthly salary structure from the master sheet. Run the 50% test on every cadre. Compute the recomputed wage base where the excluded basket exceeds the half-threshold. Map the cadre-level delta into PF, gratuity, bonus, retrenchment compensation, the Re-Skilling Fund contribution, leave encashment, and maternity benefit. The output is a cadre-by-cadre wage-base reconciliation sheet against the FY 2026-27 P&L provisioning.

Map every obligation under the four Codes against the establishment's footprint. Use the threshold matrix and the four-bucket calendar from Labour Code Compliance Calendar: foundational items, monthly items, annual items, event-triggered runbooks. For each line, capture the Code section, the threshold (or "always applies"), the timeline, the form, and the owner. The output is a working compliance map alongside the calendar.

Identify the establishment's exposure to the held-back layer. Estimate retrenchment frequency from historical data and book the Re-Skilling Fund provisioning at 15 days' last-drawn wages per retrenchment. Where the establishment falls within the Seventh Schedule of the SS Code, model the aggregator contribution at the upper bound of the 1% to 2% band against current annual turnover and at the 5% cap against gig and platform worker payments, taking the lower of the two. The output is a contingent-liability schedule with the third-layer items separately captured.

Subscribe to gazette notifications of the Centre and every state of operation. Route the alerts to a weekly HR-and-finance brief. Set up filters for the Code-specific notifications (S.O. and G.S.R. series under the four Codes; minimum wage notifications from each state's Office of the Commissioner of Labour or equivalent). The output is a running notification log in the HR file.

Pull the contractor list and the licence file. List every contractor engagement at the establishment with worker count, licence number, licence expiry date, and last-deposit verification date. Apply the 50-worker threshold under Section 45 of the OSH Code and the multi-state / all-India contractor licence rule under the first proviso to Section 47(3) to identify contractors caught by the central licensing regime. The second proviso to Section 47(3) requires the central authority to consult the concerned State authorities before issuing such an all-India licence. The output is a contractor compliance register with quarterly verification cadence.

Days 31 to 60, the remediation

The remediation closes the gaps the audit surfaced. Eight workstreams run in this phase.

Recompute PF, gratuity, and statutory bonus on the recomputed wage base, cadre by cadre. Run the catch-up adjustment in the current FY's payroll. Update the gratuity provisioning ledger with the cadre-level delta from year one. Configure the bonus engine on the statutory fraction 1/12 (eight and one-third per cent.) under Section 26(1) of the Code on Wages; the rounded 8.33% understates the minimum by ₹10 per ₹3,00,000 of annual wages, recurring across the workforce. Reconcile the FY 2026-27 employer PF, gratuity, and bonus figures against the cadre map.

Update the appointment letter template to the Section 6(1)(f) OSH Code format prescribed in the still-draft Central Rules. Issue retrospective letters to every existing employee who had not been issued one within the 21 February 2026 window, with a documented memo recording the back-dated issuance. Update the wage period statement, the nature of work, the place of posting, the hours of work, and the wage rate fields on every letter.

Refresh the notice board to the Section 50(2) format with all five items current: the abstract of the Code on Wages, the category-wise wage rates, the wage period and day or date and time of payment, and the Inspector-cum-Facilitator's name and address. Display in English, Hindi, and the language understood by the majority of employees, per the still-draft Rule 51 of the Central Rules.

Constitute or refresh the Grievance Redressal Committee under Section 4 of the IR Code at every establishment with 20 or more workers. Equal employer-worker representation up to 10 members. Women representation proportionate to the share of women in the workforce. Chairperson alternating yearly between the employer and worker sides. Document the constitution memo and the rotation schedule.

Decide on Standing Orders if the establishment is at 300 or more workers under Section 28(1) of the IR Code. Adopt the Model Standing Orders under Section 30(3) (the simpler route for most mid-sized employers, with the adoption intimated to the Certifying Officer and deemed certification on intimation), or draft a custom set under Section 30(1) and (2) (for industries carrying practices the Model does not contemplate, with the draft forwarded to the Certifying Officer for certification within sixty days, deemed certified on inaction beyond that period under the proviso to Section 30(5)).

Audit every contractor on the establishment's roster against the OSH Code chain of liability. Verify licence currency under Section 48, wage register entries against the rolling pay periods, PF and ESI deposit slips against the saved Schemes' 15th-of-the-succeeding-month deadlines, welfare provision against Sections 23 and 24, and accident notification protocol under Section 10 read with Sections 53 and 55(3) for principal-employer step-in.

Build the third-layer provisioning entries. Recognise the Re-Skilling Fund liability as accrued payable on every retrenchment from 21 November 2025 onward, including any retrenchment between commencement and the audit date. Recognise the aggregator contribution provisioning entry at the upper bound (2% of annual turnover, with the Explanation to Section 114(4) carving out tax, levy, and cess paid or payable to the Central Government from the turnover figure but not State-level levies; or 5% of the amount paid or payable to gig and platform workers in the financial year, whichever is lower) for any establishment within the Seventh Schedule of the SS Code. Run the catch-up against any historical retrenchment events that occurred without the Section 83 contribution booked.

Cross-check every existing register against the Wage Code, the OSH Code, and the SS Code preservation rules. Wage register, overtime register, register of fines under Section 19(8) of the Code on Wages, register of damage-or-loss deductions under Section 21(3), employee register, and dangerous-occurrence register under the OSH Code Section 33 framework. Five-year preservation from the date of the last entry, in physical or electronic form.

Days 61 to 90, the institutionalisation

The institutionalisation moves the audit findings and the remediation work into recurring cadence. Six workstreams run in this phase.

Move all four registers into the new prescribed form where the final Central Rules have notified. Where rules are pending, maintain the older-form registers with the Code-section reference noted on every entry. Cross-reference the wage register Form I, the overtime register, the registers of fines and deductions, and the employee register against Section 50 of the Code on Wages and the still-draft Rule 51 of the Code on Wages (Central) Rules.

Build runbooks for the seven event-triggered actions most likely to occur. New hire under Section 6(1)(f) of the OSH Code with PF and ESI registration under Chapters III and IV of the SS Code; exit wages under Section 17(2) of the Code on Wages with the two-working-day clock and weekend cover; accident under Section 10 of the OSH Code; dangerous occurrence under Section 11; retrenchment under Sections 70(a), 70(b), and 83 of the IR Code, with the chapter IX retrenchment workflow under Section 70 attaching at any worker count subject to the one-year continuous-service eligibility, and the chapter X prior-permission workflow attaching above 300 workers under Section 79(1)(a); strike or lockout notice under Section 62(6) of the IR Code; contractor default under Section 55(3) of the OSH Code. 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, the owner, and the backup.

Train the HR and payroll team on the new wage definition under Section 2(y) of the Code on Wages and the parallel definitions in the IR, OSH, and SS Codes; on the 50% rule cascade into the seven downstream calculations; on the two-working-day exit; on the 21-day Section 40 notice for Third Schedule changes; on the held-back-layer items and the provisioning approach. A two-day workshop cycle covers most of the substance, with a single-page decision-tree handout per Code on the desk.

Recognise the third-layer (held-back) provisions on the books. Pass the FY 2026-27 closing entries with the Re-Skilling Fund accrued payable balance and the aggregator contribution provision balance (where applicable). Document the policy basis, the rate, the cap, and the upper-bound assumption in the financial statement notes for FY 2026-27.

Set up the quarterly compliance review cadence. Calendar a quarterly walk-through of the compliance map, the cadre-wise count under both the worker and the employee definitions, the threshold map against any new hires or exits in the quarter, the contractor compliance file, and the third-layer provisioning balances. Schedule the annual cadre-wise 50% rule review for early March 2027 ahead of the FY 2027-28 rollover.

Calendar an external compliance audit for the close of FY 2026-27 by an independent labour-law adviser. Provide the audit team with the compliance map, the cadre-by-cadre wage-base reconciliation sheet, the threshold map, the third-layer provisioning balances, and the runbook set. Capture the audit findings on the FY 2027-28 plan as the next-year remediation list.

Final Central Rules under each of the four Codes were pending as of 25 April 2026; the consultation windows on the 30 December 2025 drafts had closed, but the final notifications had not issued. State Rules continued to notify state by state through FY 2026-27. The Re-Skilling Fund collection mechanics under Section 83 of the IR Code, and the aggregator contribution rate within the 1% to 2% band and the commencement date under Section 114(5) of the SS Code, remained the two material gaps in the rollout. A weekly notification watch is the cheapest compliance investment available through this transitional period.

The series will be revised when material rules notify. Readers should treat each article as a working baseline and reconcile against the latest gazette before relying on a number for an audit defence. The substance of the four Codes is in force; the operational rollout runs in stages through the next several quarters; the 90-day plan is what closes the loop on every duty live today and provisions for every duty pending tomorrow.