Labour Law · EPF & ESI · Labour Codes · Ludhiana · Gurugram

Wednesday, 28 October 2026

Labour Codes: States Expected to Notify Rules by 31 October 2026 and What Employers Should Prepare

The Central Government has said that it expects every State and Union Territory to publish its rules under the four Labour Codes by 31 October 2026, which is now only three days away. For employers in Punjab, Haryana and the National Capital Region, the date marks the point at which the long transition from the old labour statutes to the new framework is meant to be substantially complete, and it is therefore the most closely watched development in labour law this week.

Where the Labour Codes stand

The four Codes, namely the Code on Wages, the Industrial Relations Code, the Code on Social Security and the Occupational Safety, Health and Working Conditions Code, replaced twenty-nine central labour laws and came into force in November 2025. The Centre notified its rules under the Codes in May 2026. Because labour is a subject on the Concurrent List, however, the day-to-day working of the Codes depends equally on the rules framed by each State. Speaking at a seminar organised by PHDCCI and Grant Thornton Bharat on 24 September 2026, the Labour Secretary stated that ten States had by then published their rules, while the remaining States and Union Territories had issued draft rules for consultation, and that the Centre hoped all of them would be in place by 31 October.

What the simplification is expected to achieve

The report presented at the same seminar describes the reduction in compliance burden that the Codes and rules are intended to bring about. The number of rules is said to fall from 1,436 to 351, the number of returns from 31 to a single consolidated return, the number of forms from 181 to 73, and the number of registers from 84 to eight. The Government also indicated that a pilot of the Labour Stack, the digital platform meant to support this consolidation, would begin shortly and be tested in at least one State or Union Territory before wider expansion.

ItemPosition
Date the Codes came into forceNovember 2025
Central rules notifiedMay 2026
States with final rules (as stated on 24 September 2026)Ten
Date by which the Centre expects all States and Union Territories to publish rules31 October 2026
Stated consequence of missing the dateNone specified; it is an expectation and not a statutory deadline

Questions that remain unsettled

Three practical questions continue to await clear answers. The first is whether the requirement to pay wages within two working days of separation extends only to statutory wages or also to the full and final settlement. The second is how managerial, administrative and supervisory roles are to be classified, since the Codes do not define them with precision. The third is how registration and contributions will operate for gig and platform workers. Until the State rules and any clarificatory instructions are available, employers should adopt a cautious reading and document the basis on which they have settled each of these points.

Other developments in the past fortnight

Several other instructions have been issued recently and deserve attention in the same compliance review. EPFO has extended the due date for filing the September 2026 return and paying the related contributions to 31 October 2026, which we discussed in our earlier note. A central circular dated 21 October 2026 directs intensified Aadhaar seeding of ESI insured persons and their beneficiaries. An office memorandum dated 20 October 2026 clarifies the application of the Provident Fund and ESI Acts to apprentices. Uttar Pradesh has finalised its Industrial Relations Rules, 2026 by a notification dated 16 October 2026, and a number of States, including Uttarakhand, Jharkhand, Odisha and Chhattisgarh, have revised their minimum wages in October. We have noted these items by their published titles and recommend that each be read in its official text before action is taken.

What employers should do now

Establishments should first identify which State rules apply to each of their units, and whether those rules are final or still in draft, by checking the notification issued by the Labour Department of the State concerned. Employment contracts, appointment letters, wage structures, attendance and overtime practices and contractor agreements should then be reviewed against the Codes and the rules in force. Where a State has not yet finalised its rules, the Central rules and the Codes themselves continue to guide compliance, and employers should keep a record of the draft provisions that are likely to apply so that the transition is orderly once they are notified.

Kanoon Mitra Solutions assists establishments with Labour Code compliance, payroll configuration, contract labour arrangements and statutory returns across Punjab, Haryana and the National Capital Region. Please write to kanoonmitrasolutions@gmail.com for a unit-wise compliance review.

Official sources and further reading

Employers should read the Codes, the Central rules and the relevant State notifications in their official text on the portals of the Ministry of Labour and Employment, the Chief Labour Commissioner (Central), EPFO and the e-Gazette of India. Press and professional coverage consulted for this note includes Business Standard on the 31 October expectation, SightsinPlus on the States' timeline and the Labour Code Advisor notifications tracker.

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