Health and Safety in India: 7 Changes Under the New OSH Code
If your organisation runs a delivery centre in Bangalore, Hyderabad, Pune, Chennai or Gurugram, the legal basis for its health and safety arrangements changed on 21 November 2025. On that date the Government of India brought all four Labour Codes into force, and the Occupational Safety, Health and Working Conditions Code 2020 replaced thirteen central Acts in a single step. Twenty-nine central labour laws were repealed across the four Codes together.
Most foreign parents have not registered this. Their India policies still cite the Factories Act and the Contract Labour Act by name, their compliance calendars still track filings under repealed legislation, and nobody in London or New York has asked what changed. Meanwhile the reform is being described by Indian counsel as the most significant employment law transition in decades.
Seven things matter for an office-based operation. The seventh is the one that determines how urgently you should act.
1. Thirteen Acts became one Code
The OSH Code consolidates a long list of separate statutes into a single instrument, among them the Factories Act, the Contract Labour (Regulation and Abolition) Act and the Inter-State Migrant Workmen Act. The government published its own briefing on the Code setting out the consolidation and its intent. For a multi-site employer this is genuinely simplifying: one framework rather than a patchwork accumulated over decades.
The immediate practical consequence is documentary. Any policy, contract, induction pack or compliance register that names a repealed Act is now citing legislation that no longer exists. That is not a technicality when a document is produced to an inspector or to a client conducting supplier due diligence.
2. The threshold is ten workers
The Code applies to establishments with ten or more workers. A small representative office may fall outside it, but a delivery centre of any meaningful size will not, and the threshold counts workers at the establishment rather than the entity's global headcount.
Growth across the threshold is not announced. As with most headcount-triggered regimes, the obligation attaches when the condition is met, and confirming which of your Indian locations now sit above it is a short exercise that is worth doing deliberately.
3. Registration, licensing and filing moved online
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A significant part of the reform is administrative rather than substantive: single registration, all-India licences in place of state-by-state duplication, electronic filing of returns, and time-bound or deemed approvals.
This is a real improvement, and it changes what your compliance function does day to day. It also means the record of your compliance is now a digital trail rather than a folder in a local office, which is easier to produce when asked and equally easier for an inspector to examine.
4. Working hours and overtime consent
The Code sets the standard working day at eight hours and the working week at forty-eight, with overtime permitted beyond that and daily hours extending further where the worker consents, subject to the limits and intervals prescribed by the appropriate government.
For delivery centres this deserves attention rather than a nod. Operations supporting London or New York business hours run shift patterns that would be unremarkable in India and would attract scrutiny in either home jurisdiction. Consent is a specific requirement, not an assumption embedded in an employment contract, and the arrangements should be documented as such.
5. Women working at night
Related and more specific. The Code addresses employment of women beyond conventional hours, permitting it subject to consent and to the provision of appropriate safety measures.
Any operation running a night shift to cover Western time zones is squarely within this. Transport arrangements, facility security, staffing levels and the consent record are the practical elements. This is one of the areas where a group policy written for a London office transfers least well, because the underlying risk profile and the statutory expectation are both different.
6. Grievance mechanisms and committee structures
The reform requires attention to internal committee structures, including grievance redressal arrangements, which for many establishments means constituting or reconstituting bodies that already existed under the old framework in a different form.
The failure mode is predictable: the committee exists on paper from the previous regime, its constitution no longer matches what the current Code requires, and nobody has revisited it because the committee has not needed to meet.
7. In force does not yet mean fully enforceable
The point that should shape your response, and the one most summaries state badly.
The Codes themselves are law and the Acts they replaced are repealed. But labour sits on the Concurrent List of the Indian Constitution, which means both the central government and the states legislate in this area, and the detailed rules that make the Codes operational have not all landed. Central rules have been in draft, and state rules are at varying stages of notification. Full operationalisation in any given location depends on that state completing its own process.
Two consequences follow. There is a transitional period in which the practical detail of what you must do is still settling, so anyone offering categorical operational answers today should be treated carefully. And because the rules are state-level, a Karnataka establishment, a Telangana establishment and a Maharashtra establishment will not necessarily face identical requirements at the same moment. Groups with offices in several Indian cities need to track this per state, not per country.
The official position is published by the Ministry of Labour and Employment, with the Codes themselves available through India Code. Given how quickly this is moving, verify the current status for your specific states rather than relying on any summary, including this one.
What this means for a foreign parent
| Area | Action | Urgency |
|---|---|---|
| Policy documents | Remove references to repealed Acts, cite the Code | Now, cheap to fix |
| Establishment threshold | Confirm which locations exceed ten workers | Now |
| Registration and filings | Move to the electronic regime, confirm licences | As rules land |
| Working hours | Document consent for extended hours | Now |
| Night working | Review consent, transport, security, staffing | Now |
| Committees | Check constitution against current requirements | As rules land |
| State variation | Track per state, not per country | Ongoing |
The pattern to notice is that roughly half of these can be done immediately and cheaply, and the other half depend on rules that are still arriving. That argues for doing the first half now rather than waiting for complete clarity, because the documentary items are the ones a client questionnaire or an internal audit will surface first.
Running India alongside everywhere else
India is rarely a group's only overseas operation, and it is frequently the largest by headcount. That combination makes it the entity most likely to be materially non-compliant and least likely to be visible from headquarters.
The arrangement that works is the same one that works elsewhere: local obligations discharged under local law by people qualified there, feeding a single group view of what is current and what is outstanding. Periodic health and safety audits verify each entity against its own national requirements rather than a translated group standard, and holding status for every country in one register is where health and safety consultants and software are worth more in combination than either alone. Your health and safety policy can remain a single group document provided the legal layer beneath it is genuinely local.
Where Arinite fits
Arinite coordinates locally qualified practitioners so that Indian obligations are met under Indian law, and under the applicable state rules, while your group keeps one point of contact across every country. We support 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years. Our health and safety consultants work extensively with IT and software and finance and banking organisations, which between them account for most foreign-owned headcount in Indian delivery centres, and our global health and safety consultants handle the wider APAC picture that usually accompanies it.
If you have an Indian operation and no clear answer on what changed in November 2025, our international health and safety consultants can establish where you stand. A free gap analysis will separate what you can fix this month from what genuinely has to wait for the rules.
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Written by
Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
