India's Four Labour Codes: What Delhi NCR Employers Must Do Now

India's four Labour Codes — the Code on Wages 2019, the Industrial Relations Code 2020, the Code on Social Security 2020, and the Occupational Safety, Health and Working Conditions Code 2020 — came into force on 21 November 2025, replacing 29 central labour laws. Central and State rules under the Codes are still being finalised, including in Delhi and Haryana; in the meantime, transitional provisions keep rules and schemes under the earlier laws operative where consistent with the Codes. The Codes apply now. Employers who have not yet aligned payroll, contracts and HR documentation with them should treat the points below as current obligations, not preparation. **The Code on Wages 2019** The most immediately impactful Code for most employers. Key changes: - Unified definition of "wages" — includes basic pay, dearness allowance, and retaining allowance; excludes HRA, overtime, and bonuses, but excluded components above 50% of total remuneration are added back. This definition affects gratuity, provident fund, and ESIC calculations. - Minimum wage is universally applicable — the Code removes the distinction between "scheduled" and other employment - Payment timeline obligations apply to all employers, not just "industries" **The Industrial Relations Code 2020** - The threshold for mandatory standing orders has been raised to 300 workers (from 100) - The threshold for prior government permission for retrenchment or closure has been raised to 300 workers (from 100) - A new concept of "fixed-term employment" is introduced — fixed-term workers are entitled to the same benefits as regular workers and can be hired without the consent of existing workers **The Code on Social Security 2020** - Unifies ESI, EPF, Gratuity, and related schemes - Extends coverage to gig and platform workers - ESIC coverage applies to establishments with 10 or more employees **The OSH Code 2020** - Unifies 13 existing laws including the Factories Act, Contract Labour Act, and Building & Construction Workers Act - Common health and safety standards across all establishments with 10+ workers - Mandatory annual medical examinations for employees in hazardous work **What Delhi NCR Employers Should Do Now** 1. Audit your current employment documentation against the new Code definitions — particularly the definition of "wages" for PF and gratuity calculations 2. Review your standing orders if you have 100-300 workers — your obligations change under the new threshold 3. Assess your fixed-term employment usage — fixed-term contracts now have statutory recognition under the IR Code, with pro-rata benefits and gratuity after one year of service 4. Update your employment contracts to align with the new Code requirements 5. Review your contractor arrangements under the OSH Code — the principal employer obligations are significantly expanded