Overview

In 2020, India consolidated 29 central labour laws into four comprehensive labour codes — the Code on Wages, the Industrial Relations Code, the Code on Social Security, and the Occupational Safety Code. While the legislative intent was to simplify compliance and extend coverage to informal workers, implementation has proceeded unevenly across states and sectors.

The Labour Code Monitor is an ongoing documentation and policy tracking effort that examines the gap between legislative promise and administrative reality. Over eighteen months, we tracked notification schedules, state-level rulemaking, enforcement data, and worker testimonies across six states.

What We Found

Notification delays are structural, not incidental. As of mid-2024, only eleven states had notified rules under all four codes. The remaining states cited administrative capacity constraints, pending stakeholder consultations, and fiscal concerns about extending provident fund and ESIC coverage to informal establishments.

Inspections have declined, not increased. Despite a stated shift toward “facilitative” enforcement, the number of inspections under key provisions — particularly those related to minimum wages and contract labour — fell by an estimated 34% in the states we monitored, compared to the pre-consolidation period.

The unorganised sector remains outside the net. The Code on Social Security created the category of “gig and platform workers” and promised a National Social Security Board. As of the monitoring period, the board had not held a substantive meeting, and no state had constituted its own unorganised workers’ board under the new framework.

Methodology

We built a monitoring framework across three layers:

  1. Legislative tracking: Mapping each state’s gazette notifications, subordinate rules, and amendments against the central framework. We maintained a live spreadsheet updated monthly.

  2. Administrative data: Right-to-information requests to state labour departments for inspection registers, complaint records, and prosecution data. Response rates varied significantly — Karnataka and Kerala were most responsive; UP and Bihar required appeals.

  3. Worker interviews: Structured interviews with 340 informal sector workers across construction, domestic work, home-based piece-rate work, and platform delivery. Interviews were conducted in Hindi, Tamil, and Kannada with research associates in each state.

Key Findings by Code

Code on Wages

The Universal Minimum Wage concept — a national floor below which no state could go — was welcomed but the floor rate set was below existing minimum wages in fourteen states, effectively weakening protections in those states if they harmonised downward.

Industrial Relations Code

The threshold for requiring government permission before retrenchment was raised from 100 to 300 workers, a change that labour groups argued would affect an estimated 7 lakh workers in medium-sized establishments who previously had some procedural protection.

Code on Social Security

Provisions for building and construction workers — who have their own dedicated cess-funded welfare boards — remained ambiguous. Several state boards paused operations pending clarification on whether their mandate survived the consolidation.

Occupational Safety Code

The code introduced self-certification for smaller establishments, reducing mandatory inspections. Among workers in hazardous industries, awareness of new provisions was extremely low — fewer than 12% of workers we interviewed could name any right under the new code.

Policy Recommendations

Based on our monitoring, we submitted recommendations to the Ministry of Labour and Employment and to three state labour commissioners:

  • Establish a time-bound implementation calendar with public tracking
  • Restore and strengthen the inspection regime, particularly for construction and domestic work
  • Constitute state unorganised workers’ boards with mandatory quarterly meetings
  • Create accessible grievance mechanisms in regional languages

A full policy brief was submitted to the Standing Committee on Labour in August 2024. We continue to update the monitoring database quarterly.

This project was conducted in partnership with labour law researchers, union federations, and worker collectives. All interview data was anonymised and consented.