When the Employees' Compensation Act, 1923 came into force, India was a British colony, twenty-four years before Independence and twenty-seven years before the Constitution. The Central Legislative Assembly that passed it sat under Viceroy Lord Reading. Penicillin had not yet been discovered; Tata's aviation department, which would later become Air India, was nine years from being founded.
That Act has governed how Indian employers compensate workplace injuries through the entire lifespan of independent India. Four generations of workers have spent their lives under it. A great-grandfather who joined a textile mill in 1925, a grandfather who joined a steel plant in 1958, a father who joined an IT services firm in 1985, and a daughter who joined a fintech in 2015 were all governed by the same Act when they were injured at work, until November 2025.
On 21 November 2025 it was finally repealed, along with twenty-eight other older central labour statutes spanning a century of Indian labour history. The list includes the Trade Unions Act, 1926, the Industrial Disputes Act, 1947, the Factories Act, 1948, the Mines Act, 1952, the Maternity Benefit Act, 1961, the Contract Labour Act, 1970, and the Unorganised Workers' Social Security Act, 2008. In their place, the Ministry of Labour and Employment notified four new Labour Codes into force: the Code on Wages, the Industrial Relations Code, the Occupational Safety, Health and Working Conditions Code (the OSH Code), and the Code on Social Security.
If your company runs payroll in India, the rules under which you run it changed on 21 November 2025. Equal pay across genders, overtime paid at twice the normal rate, exit dues cleared within two working days of any employee leaving, and an appointment letter issued to every new hire: these have been live legal duties since that morning. Most HR teams have not noticed.
The headlines that put the date at 1 April 2026 were reporting an administrative target the government later missed. The law itself was already in operation by the time those stories ran.
For the working employer, the legal position from 21 November 2025 forward has three layers running at once. Some Code provisions are live and self-executing. Others are live but operating on the older Acts' rules until the Centre and the states notify fresh ones. A small set of provisions has been deliberately held back from operative effect, awaiting separate notifications that have not yet issued. Each layer asks a different action of an HR or finance team. The article walks through all three.
The four notifications
| Code | Notification | Date | Coverage |
|---|---|---|---|
| Code on Wages, 2019 | S.O. 5322(E) | 21 November 2025 | Brought into force in part, building on earlier partial commencements |
| Industrial Relations Code, 2020 | S.O. 5320(E) | 21 November 2025 | Brought into force in entirety |
| Occupational Safety, Health and Working Conditions Code, 2020 | S.O. 5321(E) | 21 November 2025 | Brought into force in entirety |
| Code on Social Security, 2020 | S.O. 5319(E) | 21 November 2025 | Brought into force in part; operationalised items 1, 2, and 4 to 9 of Section 164(1), expressly excluding item 3 (the EPF Act repeal entry) |
A technical corrigendum (S.O. 5936(E)) followed on 19 December 2025, with retrospective effect to the commencement date. Its job was to clarify the enforcement timeline of certain EPF-related provisions of the Code on Social Security. The continuity of the EPF Act, 1952, the EPF Scheme 1952, the EDLI Scheme 1976, the EPS 1995 and the EPF Tribunal (Procedure) Rules 1997 does not depend on this corrigendum. It rests on the savings clause in Section 164(2)(b) of the Code, which preserves these schemes operationally for one year from the date of commencement, to the extent not inconsistent with the Code. The transitional period therefore runs to 20 November 2026 unless extended.
Why 1 April was not the law
The 1 April 2026 date that featured in nearly every newspaper article on the subject has its own provenance. The Union Labour and Employment Minister addressed CII IndiaEdge on 3 December 2025. At and around that event, government briefings (with a senior official speaking to reporters) indicated the Centre's intention to operationalise the rules under all four Codes from 1 April 2026, the start of FY 2026-27. That date was an administrative target. It does not appear in any of the 21 November 2025 notifications, in the December 2025 corrigendum, or in the PIB master release that accompanied them.
The administrative target rested on the rule-making cadence. The Centre pre-published draft Central Rules under all four Codes on 30 December 2025, with consultation windows of 30 to 45 days. As of 25 April 2026, no authoritative primary source confirms that final Central Rules under any of the four Codes have been notified. The Ministry's own FAQs dated 30 December 2025 expressly invoke Section 6 of the General Clauses Act, 1897 to keep older rules and notifications in force until fresh rules are notified under each Code, to the extent these are not inconsistent with the Code. The Additional FAQs dated 16 March 2026 carry forward this transitional position with item-specific clarifications. The 1 April 2026 target has slipped, with final Central Rules pending Law Ministry vetting.
The slip does not pause anything that is already in operation. Every Code provision that was operative on its own terms from 21 November 2025 has been operative since then. The provisions that depended on rules ran on saved older-Act rules through the transitional months and still run on them today. The only items left in suspension are those expressly excluded from commencement, which the next section names.
The three layers
Not every provision of the four Codes came into force at the same time or at the same depth. The provisions divide into three layers based on what each one needs to operate, and each layer asks a different action of the working employer.
| Layer | What it means | Representative examples | What you do about it |
|---|---|---|---|
| Live and self-executing from 21 November 2025 | Took full legal effect on the commencement date and runs on the bare Code's text. The duty applies and the rate, form, or threshold is fixed in the Code itself. The employer has been under these obligations since November 2025. | Equal remuneration across genders for the same work or work of similar nature (Section 3 of the Code on Wages). Overtime at not less than twice the normal rate (Section 14 of the Code on Wages, applied through the normal working day fixed under Section 13 of the Code on Wages). Pay exit dues within two working days of resignation, dismissal, retrenchment, or closure (Section 17(2) of the Code on Wages, subject to Section 17(3) which permits the appropriate Government to provide a different time limit, and Section 17(4) which preserves any timeline already provided in any other law for the time being in force). Issue an appointment letter to every new hire (Section 6(1)(f) of the OSH Code), with form and content to be prescribed by rules; existing employees not previously issued letters are to be issued one within three months of commencement. | Operationalise these into HR policy and payroll this quarter if not already done. Continued non-operationalisation now sits on a live obligation, not on a draft one. |
| Live, but operating on the older Acts' rules | The duty is in force from 21 November 2025, with the rate, form, or procedure drawn from saved older-Act notifications until fresh rules are notified under the new Codes. Section 69(2) of the Code on Wages and parallel saving clauses in the other three Codes preserve the older notifications for this purpose. | Pay at or above the notified minimum wage. The obligation under Section 5 of the Code on Wages is in force from 21 November 2025; existing state minimum-wage notifications under the Minimum Wages Act, 1948 are saved and continue to apply until fresh rates are notified under Section 6, in accordance with the procedure in Section 8 and subject to the floor wage discipline of Section 9 of the Code on Wages. Registers and wage slips, bonus forms, gratuity procedures, inspection formats, annual return templates, and the single establishment registration under Section 3 of the OSH Code all run on prescribed forms drawn from saved or transitional sources. | Update templates and the filing cadence to the new prescribed forms as they notify. Subscribe to gazette notifications so subsequent state-level rule changes do not slip past you. Do not assume any single national go-live date for the rules; each state moves at its own cadence. |
| Held back from operative effect | Excluded from the commencement notifications, awaiting separate notification of operative machinery. The Employees' Provident Funds and Miscellaneous Provisions Act, 1952 sits in a special transitional position: although it features in Section 164(1) of the Code on Social Security as one of the nine Acts to be repealed, the EPF Scheme 1952, EDLI Scheme 1976, EPS 1995 and EPF Tribunal Rules 1997 continue in operational force under the savings clause in Section 164(2)(b), which preserves them for one year from commencement. The existing EPFO contribution architecture therefore continues unchanged through this transitional window, which closes on 20 November 2026 unless the Centre extends it. | The Workers' Re-Skilling Fund mechanics under Section 83 of the Industrial Relations Code (15 days' last-drawn wages on every retrenchment, separate from and in addition to retrenchment compensation under Section 70(b) of the Industrial Relations Code; credited within 45 days under Section 83(3); collection mechanics still pending). The aggregator contribution under Section 114(4) of the Code on Social Security (between 1% and 2% of annual turnover excluding any 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; eight specified aggregator categories in the Seventh Schedule of the Code on Social Security plus a residual catch-all for any other goods and services provider platform; commencement and the rate within band pending notification under Section 114(5)). The Social Security Fund disbursement rules for unorganised, gig, and platform workers. | Budget for the contingent liability in your cost model. Recognise it on the books so that when the rules land you are not caught short. For aggregators, run the 1% and the 2% scenarios against current turnover and current payouts to gig and platform workers; the 5% cap on those payouts is the binding ceiling for most aggregators. |
A weekly notification watch is the single cheapest compliance investment available through this transitional year. Until State Rules stabilise across every state in which you operate, an unmonitored mailbox is the largest hidden compliance risk on your desk.
What this means today
A company that has not yet operationalised the first layer of obligations (the duties that took full effect on 21 November 2025) is in breach of obligations that are already live. Equal remuneration, overtime at the statutory rate, exit dues within two working days, and appointment letters for every new hire have been live since November 2025. The transitional state of the rules does not change any of those duties. They sit in the bare Acts.
Saved older-Act forms for registers, wage slips, returns, and the establishment registration remain valid until they are replaced by fresh rules. A company still using them is compliant. There is no penalty for the interim use of forms saved by the Codes' own saving clauses.
Budgeting now for the third layer of obligations is what the rest of the regulated sector is doing. The Workers' Re-Skilling Fund contribution at 15 days' last-drawn wages on every retrenchment, the aggregator contribution where applicable, and the Social Security Fund disbursements will all land at some point in the next several quarters. A company that has provisioned for them on its books absorbs the rule with no operational shock when it lands.
The biggest practical risk through this transitional period is silent. A company assumes, because the press said the rules were pending, that nothing has changed and that the older Acts continue to apply. Eight of the older Acts have been operatively repealed. The ninth (the Employees' Provident Funds and Miscellaneous Provisions Act, 1952) has not, and remains in force only because of the express carve-out described above. Every other older Act in the field has been replaced by the corresponding Code, and the Code's substantive duties are live. The compliance line on this point is sharp.
Centre and state
The Codes are central legislation, and their operation is split. The Centre rules on a defined set of industries and entities: railways, mines, oilfields, banking, insurance, telecommunications, major ports, air transport, central public sector undertakings and their subsidiaries, and autonomous bodies established under a Central Act. State governments rule on almost everything else, including most factories, shops, offices, and services. An employer operating in more than one state tracks more than one notification cadence for minimum wage revisions, licence fees, and inspection rules.
Karnataka, Maharashtra, and Kerala have notified rules under one or more of the Codes. Delhi has notified rules under the Code on Wages and the Code on Social Security. A handful of additional states, including Uttar Pradesh, Madhya Pradesh, Gujarat, Haryana, Uttarakhand, Jharkhand, Odisha, Bihar and Arunachal Pradesh, have notified rules under at least one Code. Comprehensive notification under all four Codes remains rare, and most states' rules are at varying stages of draft progress. This explains the mixed picture in employer briefings through the first half of 2026: the underlying Codes apply uniformly, while the operating rules vary jurisdiction by jurisdiction. Build periodic review into your compliance calendar; a single filing cycle will not satisfy every jurisdiction.
Three actions this quarter
Three actions are worth naming up front because they unblock everything else.
Map current obligations against the three layers described above. Pull your existing register of labour-law obligations: wages, PF, ESI, gratuity, ESIC returns, contract-labour licences, Standing Orders if any. Against each line, mark whether the relevant Code has changed anything material and which layer the duty now sits in. This map becomes the master working sheet for your Code transition.
Set up a notification watch. Subscribe to the gazette notifications of the Ministry of Labour and Employment and of the Labour Department of every state in which you operate. Feed these into a weekly email brief to HR and finance. New state rules and the final Central Rules will continue to notify through the rest of FY 2026-27.
Commission a legal review of your salary structure. Before any employment contract is touched, apply the 50% wage rule from Section 2(y) of the Code on Wages and the parallel definitions in the other three Codes against your cadre-wise salary templates. The recomputed PF, gratuity, and bonus liabilities are the largest single financial decision of the transition. Article 4 in this series takes that arithmetic apart on a worked example.
What article 2 covers
The four Codes replace twenty-nine older laws. Article 2 walks through which Code owns which question, so you can answer any compliance question in two steps: identify the Code, then identify the section.