Implemented on 21st November 2025, the Labour Codes of 2020 represent a landmark reform in India’s employment law framework, consolidating 29 separate legislations into four comprehensive codes with the aim of streamlining compliance, enhancing worker protection, and modernizing industrial relations. 

The Code on Wages establishes a uniform definition of wages and ensures timely payment and a statutory floor wage across sectors. The Industrial Relations Code restructures the framework for trade unions, dispute resolution, and conditions for layoffs and closures, balancing flexibility for employers with safeguards for workers. The Code on Social Security integrates provisions for provident fund, insurance, gratuity, and maternity benefits, extending coverage to gig and platform workers for the first time. The Occupational Safety, Health and Working Conditions Code harmonize standards for workplace safety, health, and welfare across industries, while simplifying registration and compliance requirements. 

Together, these codes seek to reduce complexity, foster ease of doing business, and provide a more predictable and equitable environment for both employers and employees, marking a decisive shift toward a unified labour law regime in India.

The motive of these amendments is to balance worker welfare along with ease of doing business. Increasing standard minimum wages, better precautionary steps for health and welfare of workers are central points of these amendments along with many others. 

Another significant aspect is the recognition of changing employment patterns. The introduced framework extends social security coverage to gig and platform workers, promotes fixed-term employment, and improves inclusivity by enabling flexible working conditions, including provisions for women to work night shifts with adequate safeguards. These changes reflect an effort to align Indian labour laws with global practices while addressing domestic economic realities.

On the Central Government level, these labour laws have been effectuated, but there are certain amendments that are also done on state level, which will be discussed in this brief note particularly concerning 5 states:

  1. Haryana
  2. Uttar Pradesh
  3. Puducherry
  4. Maharashtra, 
  5. Delhi (NCT)

1. Haryanah

The Haryana Cabinet approved a 35% hike in minimum wages across categories of workers, a table of monthly wage for each category of workers has been provided below:

Minimum rates of wages (in Rs) with effect from 1st April, 2026 in respect of all the Employments in the State of Haryana.

S.NoCategory of workersBasic minimum rate of wages
Per monthPer Day
1Unskilled15220.71585.41
2Semi-skilled16780.74645.41
3Skilled18500.81711.56
4Highly Skilled19425.85747.14

Haryana Shops and Commercial Establishments (Amendment) Act:
The act has been revised by the government to make it more modernise in its regulatory framework. The following changes have been made in the act:

  • It introduces a clear distinction between establishments employing 20 or more workers and those employing less than 20 workers.
  • The amendment clarifies that the provision of this act will apply to larger establishment, but with introduction of section 13A, the smaller establishments will be governed by simplified “intimation system”
  • Further, section 7 and 8 has been amended. Daily working hours has been increased from 9 to 10 hours, Maximum overtime hours per quarter increased from 50 to 156 hours and rest interval extended from 5 to 6 hours
  • Section 13 is replaced to introduce revamped fully digital registration mechanism of establishments.
  • Employers of establishments with 20 or more workers will now apply online for registration within one month of commencing business, furnishing details such as the employer’s name, GPS-based address, employee count, and nature of business.
  • The Inspector is required to verify and issue online certificates within the timelines prescribed under the Haryana Right to Service Act, 2014.
  • Employers will report any changes within 7 days and notify closure of the establishment within 30 days.
  • Penalties for non-compliance of laws has been amended as follows:
    INR 3,000/- to INR 10,000/- for first violation
    INR 5,000/- to INR 25,000/- for second violation
    INR 500/- for continuous violation.
  • The amended Section 26 introduces a revised penalty structure:
    INR 3,000/- to INR 10,000/- for the first violation
    INR 5,000/- to INR 25,000/- for the second violation
    INR 500/- per day for continued subsequent violations, as imposed by the competent authority.
  • Newly added Section 13A applies to establishments with less than 20 workers, requiring an online intimation that generates a Basic Information Performa ID, thereby reducing compliance burden while maintaining digital records
  • The Act now mandates two key employee related document, with introduction of following sections.
    Section 20A – This deals with appointment letters with employee photograph and
    Section 20B – This deals with identity cards containing prescribed particulars.
  • Section 21(2) is substituted, imposing a penalty of INR 3,000 to INR 10,000 on anyone who obstructs the inspecting authority, or prevents employees from appearing before or being examined by the authority.

2. Uttar Pradesh

(i) On 10th March 2026, the Hon’ble Governor of Uttar Pradesh issued the draft Uttar Pradesh Code on wages Rules, 2026 for public consultation. 

  • The rules provides that minimum wage should be fixed based on skill level (unskilled semi-skilled, skilled and highly skilled), nature of work and geographical location while also considering needs of a working class family to ensure decent standard of living.
  • The Rules emphasize on uniform applicability of minimum wages to all employees across sectors, removing earlier limitation of “scheduled employments”, and mandate timely payment of wages without unauthorized deductions. The Rules also regulates working hours, rest intervals, and overtime wages, ensuring workers are compensated fairly for extra work.
  • Further, provisions are made for bonus payment, maintenance of registers and records by employers, and issuance of wage slips, promoting transparency and accountability. Inspector cum facilitators are empowered to ensure compliance, and mechanisms for claims, dispute resolution, and penalties for non-compliance are clearly defined.

(ii)Uttar Pradesh Dookan aur Vanijya Adhishthan Adhiniyam, 1962

  • The Hon’ble Legislative Assembly of Uttar Pradesh has passed the Uttar Pradesh Dookan Aur Vanijya Adhishthan (Sanshodhan) Adhiniyam Bill, 2025. The bill seeks to amend the Uttar Pradesh Dookan aur Vanijya Adhishthan Adhiniyam, 1962 (the “Act”). The said Bill proposes to repeal the Uttar Pradesh Dookan Aur Vanijya Adhishthan (Sanshodhan) Ordinance, 2025 in order to align with the Central Occupational Safety, Health and Working Conditions Code, 2020
  • The Bill seeks to exempt establishments employing less than 20 employees from the applicability of the Act. 
  • According to the Bill, the establishment which have 20 or more employees in an establishment are required to submit an online registration application within 6 months of commencement of the business on the required departmental portal along with all necessary documents. The Bill, however does not touch upon what existing establishment have to do which already possess subsisting registration.
  • The definition of commercial establishment has been widened with inclusion of establishment of any medical practitioner, architect, service providers including delivery services etc. The definition of employee has been expanded to include person engaged through outsourcing agencies for manual, skilled, technical or clerical work and other kind of work.
  • The maximum daily working hours of employees has been increased from 8 to 9 hours, subject to 48 hours in a week, overtime hours limit increased from 10 to 11 hours and from 50 hours to 144 hours in a quarter.
  • The night shift timings of female workers are set from 7am to 6pm, subject to her written consent. Certain conditions are made compulsory for establishment for women to work. For instance rest rooms, crèche, safety measures for their protection and transportation services. 
  • Further, it has been stated that before prosecution is initiated, the inspector would give an opportunity to the defaulting employer to comply with provisions of the Act, by giving 15 day written improvement notice. If the employer complies with this direction, prosecution will not be initiated. Except for offences under section 20(1) of the Act.
  • The amended general penalty provision has been set out under the Act, ranging from fine of INR 2000/- for 1st time offence to INR 10,000/- for every subsequent commission of offence.

(iii)  Revision of Minimum Wages 

  • In view of the labour unrest in Noida and Greater Noida in the Gautam Buddha Nagar district, and for ensuring industrial harmony and maintenance of peace, the State Government constituted a high level committee which held discussions with all relevant stakeholders concerned including workers, occupiers/representatives of various industrial establishments and contractors and came to the following conclusion.
  • The Code on Wages, 2019 has been notified and commenced by the Government of India, and the process for notification of the Uttar Pradesh Code on Wages Rules, 2026 is underway. As per the provisions of the said Code, State Governments are empowered to determine differential rates of wages based on geographical conditions, cost of living, nature of work and other relevant factors. Accordingly, keeping in view the geographical diversification of Uttar Pradesh, status of industries, urban infrastructure and cost of living, the Department of Labour has proposed classification of the State into three categories for the purposes of fixation of minimum wage rates.
  • That in this classification, Gautam Buddha Nagar and Ghaziabad districts have been included in Category-l; all districts having Nagar Nigam (excluding Gautam Buddha Nagar and Ghaziabad districts) are proposed under Category-II; and all remaining districts are proposed under Category-III. This proposal has been agreed upon by both employers and workers.
  • Mentioning the aforesaid, the Hon’ble Governor  has directed the amount of minimum wages for the proposed categories as below:

Minimum Wage Rates for Gautam Buddha Nagar and Ghaziabad Districts (Category-I)

CategoryEffective from date 01-04-2026 Basic Wage ()Variable Dearness Allowance 

(INR) 

Total

(INR) 

Unskilled1288580513690
Semi-Skilled1417388615059
Skilled1587699216868

Minimum Wage Rates for Districts having Nagar Nigam (Category-II)

CategoryEffective from date 0104-2026 Basic WageVariable Dearness Allowance 

(INR)

Total 

(INR)

Unskilled1224176513006
Semi-Skilled1346484214306
Skilled1508294316025

Minimum Wage Rates for other than Category-I and II Districts (Category-III)

CategoryEffective from date 0104-2026 Basic WageVariable Dearness Allowance (INR)Total (INR)
Unskilled1162972712356
Semi-Skilled1279179913590
Skilled1432889615224

3. Delhi (NCT)

  • The Department of Law, Justice and Legislative Affairs, Government of National Capital Territory of Delhi, vide notification dated 11 March 2026, has published The Delhi Shops and Establishments (Amendment) Act, 2026 (Act No. 03 of 2026) after the Act received the assent of the President of India on 23 February 2026.
  • The amendment deals with Applicability of act, working hours, overtime limits, Employment of women during night shifts, spread over for working hours, Minimum age provision.
  • Previously, the Delhi Shops and Establishments Act were generally applicable to all shops and establishments irrespective of employee strength. Through this amendment, the legislature has introduced a threshold requirement, restricting the applicability of the Act to establishments employing twenty or more employees.
  • The minimum age threshold for employment under the Act ranges from 12 years to 14 years of age. The amendment is consistent with the principles of the Child Labour (Prohibition and Regulation) Act, 1986, and reflects the policy objective of discouraging child labour and promoting education among minors.
  • The permissible daily working hours has been fixed to 10 hours inclusive of rest interval and lunch break. It provides greater flexibility in structuring daily work schedules, particularly in sectors like retail, hospitality, IT, E- commerce operation, and customer service, etc.
  • An employee may work up to 6 hours continuously before being entitled to a rest interval. This change reflects modern workplace practices and operational flexibility in commercial establishments.

4. PUDUCHERRY

All shops and establishments in Puducherry are exempted from restrictions under section 10(1) and section 16(1) of Puducherry shops and establishments act, 1964. Therefore, all shops are permitted to remain open 24×7 throughout the year in Puducherry.

Some of the compliances for an employer to undertake are given below:  

  • Every employee will be given one day holiday in a week on rotation basis, and the details of every such employee may be provided as per section 26 of the Occupational Safety, Health and Working Conditions Code, 2020
  • Every employer will exhibit details of the employees who are availing holiday/leave on daily basis, in a conspicuous place in the shop/establishment.
  • The wages including overtime wages of the employees will be credited to their respective Savings Bank Account.
  • If, employees are found working on any holiday or after normal duty hours without proper indent of overtime, appropriate action is liable to be initiated against the Employer/Manager as per Section 27 of the Occupational Safety, Health and Working Conditions Code, 2020.

Compliances for employers in case of night shifts in respect to female worker i.e., between 8.00 p.m. to 6.00 a.m are hereby reproduced herein: 

  • The written consent of the woman worker is mandatory.
  • No woman is to be so employed in violation of the maternity benefit provisions laid down under the Social Security Code, 2020
  • Employers shall provide accessible washroom, and safe and clean drinking facilities, with CCTV surveillance installed on routes leading to such facilities. Additionally, sufficient lightning should be there at the workplace, ensuring utmost safety of female workers.
  • Women helpline and emergency helpline numbers shall be prominently displayed at the workplace premises.
  • The provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 shall be followed with utmost sincerity. 

Occupational Safety, Health and Working Conditions Code, 2020

The Hon’ble Government of Puducherry with the objective of ease of doing business have introduced single-common registration system for shops and establishments under OSH code, 2020.

Pursuant thereto, all shops and establishments registered under the Occupational Safety, Health and Working Conditions Code, 2020 (“OSH Code”) have been exempted from:

  • The requirement of registration under Section 7 of the Puducherry Shops and Establishments Act, 1964; and 
  • Consequently, the applicability of all provisions of the Puducherry Shops and Establishments Act, 1964. 
  • The Employer shall comply with all duties, obligations and conditions relating to occupational safety, health, working conditions, hours of work, welfare provisions, maintenance of registers, records and returns, as prescribed under the Occupational Safety, Health and Working Conditions Code, 2020 and the rules made thereunder.

5. Maharashtra

 The Hon’ble Maharashtra Government has revised minimum wages by updating the Special Allowance/Variable Dearness Allowance (“VDA”) payable to employees in scheduled employments. This revision has been made under the Minimum Wages Rules, 1948. Then notification does not alter structure of law, but enhances wage rates payable to workers. The Employer must now pay Basic minimum wage along with revised special allowance together, to be now considered as Total minimum wage

  • The notification has updated more than 67 scheduled employments/Industries including shops and commercial establishment, Factories, Engineering Industry, Hospitals, Hotels/Restaurants, construction, Road work, agriculture, public motor transport, manufacturing industries, Legal profession and judicial establishment etc.
  • The State will continue with zone based wage structure. It has been divided  into Zone I, Zone II, and Zone III. It is significant to divide it into zones because wage rates vary depending on geographical. 
  • Further, all workers are further classified into Unskilled, Semi-skilled, Skilled and highly Skilled. The revised wages are provide below:

(i) Shops and establishment

CategoryZone 1Zone 2Zone 3
Skilled₹15,532₹14,936₹14,340
Semi-Skilled₹14,756₹14,160₹13,564
Unskilled₹13,921₹13,325₹12,728

(ii) Factories (Factories Act establishments)

CategoryZone 1Zone 2Zone 3
Skilled15,98015,14514,630
Semi-Skilled14,82014,17513,535
Unskilled13,72513,08012,375

(iii) Road construction Industry

CategoryZone 1Zone 2Zone 3
Skilled24,68923,81922,954
Semi-Skilled23,17422,30421,439
Unskilled22,09421,22920,359

 

Author – Mr. Ketan Joshi, Associate Partner
Co-Author – Ms. Navya Saxena, Associate