Health and Safety in Your India GCC: 11 Questions for the Parent Company
Your global capability centre in Bengaluru, Hyderabad, Pune or Gurugram employs more people than your head office. It runs engineering, claims handling, legal research, data annotation or model evaluation. It sits in a managed building leased from a developer, and the local leadership team handles compliance.
That last sentence is where the exposure lives. Not because the local team is weak, but because India's occupational safety framework has just been rebuilt, the rebuild is being completed state by state at different speeds, and a parent reading UK or US signals will not notice when one of its states moves.
This is a list of questions rather than answers, deliberately. On several points the correct answer depends on which state your entity sits in, and published commentary currently disagrees on some thresholds. Asking is cheap. Assuming is not.
Why the ground has moved
India has consolidated a large body of separate labour legislation into four codes, one of which is the Occupational Safety, Health and Working Conditions Code. It absorbs more than a dozen earlier statutes, including the provisions that governed factories, contract labour and inter-state migrant workers. The Ministry of Labour and Employment maintains the position on the labour codes, with statutory texts available through India Code.
Three features matter more to a GCC parent than the detail.
The scope is wider than the old regime, reaching commercial establishments at a low worker threshold rather than only factories and mines, so an IT or business services office is squarely inside it in a way it was not always before.
Labour is a concurrent subject, so the central rules are half the picture. Each state and union territory frames its own, and they are not moving in step. Two entities of the same size in different states can face different obligations in the same month.
And the enforcement model has changed shape, moving away from imprisonment towards higher financial penalties with provision for compounding offences. That makes non-compliance a cost and a disclosure item rather than a remote criminal risk, which is exactly what surfaces in diligence.
1. Which rules actually bind this site today?
The first question, and the one most parents cannot answer. Is the entity operating under the new central rules, under its state's notified rules, or still under the pre-existing state legislation because the state has not finished? Ask for the answer in writing with a date on it.
2. Is the establishment registered, and what is its identification number?
Need Expert H&S Guidance?
Our qualified consultants can help you implement the right health & safety measures for your business.
Registration has moved to a central electronic process, with a single identification number issued per inspectable unit and a certificate to be displayed at the premises. There are also transitional obligations for entities already registered under the old regime to bring their details into the new system.
Ask for the certificate and the number. If nobody can produce them, that is the first task, and it is administrative rather than difficult.
3. Which thresholds apply, and have they been verified against the notified rules?
Several obligations switch on at headcount thresholds: safety committees, welfare facilities, on-site health provision. Published summaries currently give different figures for some of these, which is a good reason to insist on verification against your own state's notified rules rather than against an article.
For a GCC growing from 300 to 700 people inside eighteen months, this is not academic. You will cross thresholds, and the trigger is the site rather than the company.
4. Is there a safety committee, and is its composition compliant?
Where a committee is required, the requirements are structural rather than nominal: balanced employer and worker representation, female representation proportionate to the female share of the workforce, meetings on a fixed cycle, and a short deadline for acting on recommendations.
That last element is the one a parent should probe. A committee that meets and minutes is easy. A committee whose recommendations are implemented within a defined period, with evidence, is the actual requirement.
5. Are health examinations being provided, and who holds the records?
The framework provides for periodic health examinations at the employer's cost, with wider coverage where hazardous exposure is involved and age-based entitlements for the general workforce.
Two questions follow. Are they happening, and where do the results sit. Clinical results should remain with the medical provider, with the entity holding only what it needs. A GCC that has accumulated employee medical reports in an HR folder has created a data problem alongside a compliance one.
6. What proportion of staff are first aid trained, and is the refresher cycle live?
India's approach here is prescriptive in a way the UK's is not. Where the UK requires an assessment and sets no ratio, the Indian framework sets a proportion of the workforce to be trained, with refresher intervals.
For a 2,000-seat centre that is a significant training programme, and it is the kind of obligation that is met once at commissioning and then allowed to decay as people leave. Ask for the current trained percentage, not the number trained since opening.
7. Does the headcount trigger on-site health provision?
Above certain sizes an establishment is expected to provide a staffed health facility. For a large GCC in a multi-tenant campus the practical question is whether that provision is yours, the developer's, or shared, and whether the arrangement is documented.
"There is a clinic in the park" is not an answer. Whose obligation it discharges, and on what terms, is.
8. Is the POSH Internal Committee constituted and reporting?
Not part of the OSH framework, and included here because it is the single most commonly unmet statutory obligation we see in Indian offices.
India's legislation on sexual harassment at the workplace requires an employer above a small headcount to constitute an internal committee with a prescribed composition, including an external member, and to file an annual report. For a GCC this is not optional, it is not discharged by a global policy, and it is checked. Ask whether the committee exists, who the external member is, and when the last annual report was filed.
9. Do you hold current fire and occupancy approvals for your floors?
Fire safety approvals in India are administered at state level and attach to the building and its occupancy. In a leased GCC the developer typically holds them, which is reasonable, but the tenant still needs to know they exist, cover the current use and have not lapsed after a fit-out.
Ask for copies. A fit-out that subdivided an open floor into meeting rooms and a data room has changed the occupancy the approval described.
10. Who carries the duty for contract staff?
Security, housekeeping, catering, transport and facilities engineering are almost always contracted, and the new framework brings contract labour into its scope rather than leaving it in a separate statute.
The questions are the familiar ones from any shared-duty arrangement. Who inducts them. Who assesses the work they do on your floor. Who records an incident when one of them is injured. And is the contractor licensed where licensing applies. A GCC with 1,400 employees and 200 contracted staff has two populations and frequently one set of records.
11. What does your state require for night shifts?
GCCs exist to cover other time zones, so night working is the norm rather than the exception. State rules govern it, and conditions attached to women working night shifts in particular have changed repeatedly and vary by state, typically covering consent, transport, security and facilities.
This is the item where a group policy written in London is most likely to be both well-intentioned and non-compliant, because the local requirement is specific and procedural.
The parent company's checklist
| Question | Ask for | What a weak answer looks like |
|---|---|---|
| Which rules bind us | Written position, dated, naming the state | "We are compliant with Indian law" |
| Registration | Certificate and identification number | Nobody knows where it is |
| Thresholds | The notified state rules, not commentary | A figure quoted from an article |
| Safety committee | Constitution, minutes, action closure evidence | Minutes with no actions |
| Health examinations | Programme, cycle, and where records sit | Reports held in an HR folder |
| First aid training | Current trained percentage and refresher dates | Total trained since opening |
| On-site health provision | Documented arrangement with the developer | "There is a clinic in the park" |
| POSH committee | Members, external member, last annual report | Covered by the global policy |
| Fire and occupancy | Copies, matched to current floor layout | Landlord holds it, unseen |
| Contract staff | Licences, inductions, incident records | One record set for two populations |
| Night shift conditions | State requirement and how it is met | Group policy applied unchanged |
If the entity can answer four or fewer of those, the issue is not Indian compliance. It is that the parent has no line of sight into it, which is a governance finding rather than a local one.
How this fits a group framework
The pattern that works in India is the one that works in Germany or Japan, and the temptation to treat the GCC as self-managing is the thing to resist.
Keep one methodology and one register across the group, with the local requirement attached to each line and the state recorded alongside the country. That is where health and safety consultants and software are worth more in combination than either alone, because a framework being completed state by state will move under you, and the only way to notice is to hold the obligation and its source in a system rather than in a local team's memory. Periodic health and safety audits then verify the entity against the rules actually in force where it sits, and the group's competent person arrangement needs someone who can read the Indian position rather than infer it.
A note on currency. This framework is still being implemented, central and state rules have been arriving through 2025 and 2026, and figures quoted in secondary commentary are not consistent. Treat any specific threshold as something to verify against the notified rules for your state before relying on it. The Ministry of Labour and Employment is the primary source, and the ILO is useful for the comparative picture.
Where Arinite fits
Arinite has spent 15+ years giving parent companies a single view of compliance across entities they do not sit in. We support 1,500+ businesses in 50+ countries and protect 100,000+ employees, with 95%+ client retention. Our health and safety consultants work extensively with IT and software, insurance, legal and AI and data businesses, which between them account for most of the GCC footprint in India.
Our global health and safety consultants coordinate locally qualified practitioners who track their own state's position, so the answer you get is current rather than inferred, and our international health and safety consultants can tell you how your India entity sits against the rest of the group.
Send the eleven questions to your India leadership team and see how many come back with a document attached. Then book a free gap analysis and we will tell you in one call which answers would survive an inspection.
Related Articles
Written by
Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
