The Occupational Safety, Health and Working Conditions Code, 2020 consolidates thirteen enactments, but almost every operative obligation — registration thresholds, licence conditions, working hour limits, welfare facilities, forms and registers — is left to rules. Until a state notifies its rules, establishments continue under the legacy Factories Act, Contract Labour Act and Shops and Establishments regime.
That produces the split reality practitioners live in today: a group with plants in three states may be preparing for Code-based single registration in one, filing legacy Form registers in the second, and reading draft rules in the third. Any compliance calendar that assumes a single national switch date will be wrong for most multi-state employers.
The obligations that typically change first when a state notifies are registration and licensing (a common registration replacing multiple ones), the register and return set (consolidated formats replacing act-specific ones), and the appointment letter requirement, which applies to every employee and is the item clients most often overlook.
Our advice is to sequence readiness by state rather than by Code. For each state, identify the establishment type, the current registration or licence, and the equivalent under the notified or draft rules. Where rules are only in draft, note the comment deadline and the likely transition period — several states have provided a window for migrating existing registrations rather than requiring fresh applications.
The live position by state and by Code is maintained on our State Labour Code Tracker, which is updated as notifications are published in state gazettes.
Key takeaways
- Until state rules are notified, legacy Acts continue to apply.
- Registration, registers and appointment letters change first.
- Sequence readiness state by state, not Code by Code.