India’s labour law landscape has undergone a historic transformation with the consolidation of 29 central labour laws into four comprehensive Labour Codes:
Code on Wages (2019),
Industrial Relations Code (2020),
Code on Social Security (2020), and
Occupational Safety, Health and Working Conditions (OSH) Code (2020).
Effective April 1, 2026, Organizations must navigate a multi-phase implementation plan, overhaul payroll and HR systems, and address significant compliance, operational, and change management challenges. So how to do this.
Here is a comprehensive plan:
| Day 0–30 | Preparation Phase – Immediate |
| Audit CTC Structures | Identify employees where basic + DA is below 50% of CTC; model financial impact of restructuring |
| Review Contracts | Update fixed-term contracts to reflect new statutory benefit language and gratuity eligibility |
| Map Workforce Categories | Classify all employees as permanent, fixed-term, contract, gig, or platform workers |
| Track State Notifications | Monitor state-level rule notifications for all operating locations |
| Impact | Early preparation is critical. Organizations that delay CTC audits or contract reviews risk rushed, error-prone restructuring under enforcement pressure. Multi-state employers must pay special attention to state-specific variations, as compliance obligations may differ across jurisdictions. |
| Day 31–60 | Communication & Compliance Alignment Phase with stakeholders – commencement / Initiate |
| Conduct Training Sessions | Organize orientation for HR, payroll, and line managers on key changes, compliance requirements, and new procedures. |
| Employee Communication | Clearly explain the impact of salary restructuring, changes in take-home pay, and enhanced social security benefits |
| Change Management | Address employee concerns, manage resistance, and provide support during the transition |
| Update Internal Committees | Constitute or renew POSH Internal Committee; set up Grievance Redressal Committees as required |
| Impact | Change management is often underestimated. Employees may perceive salary restructuring as a pay cut due to reduced take-home pay, even though long-term benefits improve. Transparent communication and training are essential to minimize resistance and maintain morale. |
| Day 60–90 | Monitoring, Audit, and Ongoing Compliance (Post-Implementation) |
| Internal Compliance Audit | Verify that all statutory contributions, digital records, and policy updates are in place; close any gaps before enforcement deadlines. |
| Monitor State and Central Updates | Track ongoing notifications, FAQs, and amendments from the Ministry of Labour and state governments. |
| Periodic Training | Refresh training for HR and compliance teams as rules evolve |
| Prepare for Inspections | Ensure readiness for risk-based, algorithm-driven inspections via the Shram Suvidha Portal |
| Impact | Compliance is not a one-time exercise. The codes introduce risk-based inspections and digital audits, making it essential for organizations to maintain up-to-date records and stay alert to regulatory changes. Multi-state employers must apply the most worker-friendly provisions where central and state rules differ. |
For more comprehensive plan on new labour code implementation in 2026, kindly visit and follow – www.atanumandal.in
Have you implemented new labour code implementation for your organisation? Let me know what road map did you made for the implementation?
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