The OSH Code: What Changed for Factories and Sites

The Occupational Safety, Health and Working Conditions Code, 2020 (OSH Code) is now legally in force nationally, but what actually applies to your factory or site right now still depends heavily on whether your state has notified its own rules under the Code.

Key facts at a glance

• The OSH Code consolidates roughly 13 earlier laws - including the Factories Act 1948, Contract Labour Act, BOCW Act, Inter-State Migrant Workmen Act and Mines Act - into one code.
• All four Labour Codes, including the OSH Code, came into force nationally on 21 November 2025.
• Central rules were pre-published in draft on 30-31 December 2025, with final Central rules expected around April 2026.
• Because labour is a concurrent subject, each state must notify its own rules; as of mid-2026 most states have not yet fully notified.
• The Code moves toward a single registration and licence concept for establishments that previously needed multiple registrations under separate laws.
• Direction of travel includes mandatory appointment letters and periodic free health check-ups for defined categories of workers.
• Practical effect: employers should track their specific state's notification status rather than assume the Code is uniformly operational everywhere.

Why the OSH Code exists

Before the OSH Code, factory, construction, mining and contract-labour safety obligations were spread across more than a dozen separate laws, each with its own registration process, inspecting authority and paperwork. The stated goal of consolidating them is to reduce duplicate registrations, standardise definitions (like what counts as a "worker" or a "factory"), and make compliance more predictable across sectors.

Consolidated laws, one framework

Rather than separately complying with the Factories Act, the Contract Labour Act, the BOCW Act and similar laws, establishments covered by the OSH Code are meant to eventually operate under one consistent set of definitions and one licensing framework, administered by the relevant state authority.

What changes in practice

Single registration direction

The Code moves toward a single registration for an establishment instead of multiple registrations under different laws, reducing duplicate paperwork - though the practical single-window process depends on each state's implementation.

Appointment letters

The OSH Code framework pushes toward mandatory written appointment letters for employees, which formalises employment terms that were previously undocumented in many smaller establishments.

Health check-ups

Periodic free health check-ups for certain categories of workers, particularly in hazardous processes, are part of the Code's direction, aimed at earlier detection of occupational health issues.

Working conditions and welfare

The Code retains and in places standardises requirements around working hours, overtime, welfare facilities (canteens, crèches, restrooms) and safety committees, carrying forward much of the substance of the earlier Factories Act while aiming for more uniform thresholds.

Old law vs OSH Code direction

What employers should actually do now

Given that most states have not yet fully notified their OSH Code rules as of mid-2026, the pragmatic approach is twofold. First, continue meeting the obligations you already have under whichever laws are actively enforced in your state today - do not stop factory registrations, safety committee obligations, or welfare facility provisions on the assumption the OSH Code has already replaced them everywhere. Second, actively track your state's OSH Code notification timeline so you can adopt the new framework as soon as it becomes operational for you, rather than being caught unprepared or over-applying rules that are not yet locally in force.

If you are not sure where your business stands on the Labour Codes transition, ComplianceCheck's labour code assessment gives you a clear picture in a few minutes.

Sources

• Ministry of Labour and Employment - labour.gov.in
• Occupational Safety, Health and Working Conditions Code, 2020 (central notification and rules)
• Respective state Labour Department notifications

This guide is general information, not legal advice. Requirements vary by state, sector and headcount - confirm specifics with a compliance professional or the relevant authority.