What is in force
| Code | Commencement | What it replaces |
|---|---|---|
| Code on Wages, 2019 | S.O. 5322(E), 21 November 2025: sections 1 to 41, 43 to 66 and 68, and most of sections 42, 67 and 69, with a few listed exceptions | Payment of Wages Act, Minimum Wages Act, Payment of Bonus Act and Equal Remuneration Act |
| Industrial Relations Code, 2020 | S.O. 5320(E), 21 November 2025: the whole Code | Trade Unions Act, Industrial Employment (Standing Orders) Act and Industrial Disputes Act, repealed from the same date |
| Code on Social Security, 2020 | S.O. 5319(E), 21 November 2025, as corrected by S.O. 5936(E) of 19 December 2025; some provisions were already in force under S.O. 2060(E) of 3 May 2023 | Nine laws, including the EPF Act, the ESI Act, the Payment of Gratuity Act and the Maternity Benefit Act |
| Occupational Safety, Health and Working Conditions Code, 2020 | S.O. 5321(E), 21 November 2025: the whole Code | Thirteen laws, including the Contract Labour (Regulation and Abolition) Act |
The Industrial Relations Code (Amendment) Act, 2026, deemed in force from 21 November 2025, made the repeal of the three older industrial relations Acts effective from that date, while letting existing tribunals and authorities continue until their successors under the Code are functioning.
Rules: central and Gujarat
Much of the detail, including forms, registers, thresholds and procedures, sits in rules. The Ministry of Labour and Employment pre-published draft central rules under all four codes on 30 December 2025. The Industrial Relations (Central) Rules, 2026 were notified in final form on 8 May 2026 (G.S.R. 342(E)). Check the current status of the other central rules before relying on a draft.
Central rules apply where the Central Government is the appropriate Government; State rules apply where the State is. For most private employers in Gujarat, many matters fall to the State, so Gujarat's rules under each code matter as much as the central ones. Confirm, subject by subject, which Government is appropriate for the unit and which rules have been notified. Until rules are final, the Ministry's guidance fills some gaps. For example, the existing ESI wage ceiling of Rs 21,000 a month continues to determine ESI coverage.
What changes for an IFSC employer
- Wages. The codes' definition of wages applies from 21 November 2025. Where excluded components exceed half of total remuneration, the excess is added back. The Ministry's FAQs say annual performance-based incentives are not wages for this purpose, and that gratuity is calculated on the revised definition from 21 November 2025.
- Payment. Monthly wages are paid before the seventh day of the following month, and all dues on exit within two working days (Code on Wages, sections 6 and 17).
- Appointment letters to all employees (OSH Code, section 6).
- Registration. An establishment with ten or more employees registers electronically within sixty days (OSH Code, section 3).
- Social security. Provident fund applies to establishments with twenty or more employees, without the old scheduled-employment limit; ESI to establishments with ten or more.
- Gratuity. Payable after five years' continuous service, and to a fixed-term employee after one year.
- Grievance redressal. A committee is required where twenty or more workers are employed (IR Code, section 4).
- Women at night. Women may work before 6 a.m. or after 7 p.m. with their consent and the prescribed safeguards (OSH Code, section 43).
Several protections, such as overtime and leave encashment, attach to "workers" or to employees whose minimum wage is fixed, and not to managerial staff. Check how each role is classified.
State law and the SEZ
State laws continue alongside the codes. The Gujarat Shops and Establishments Act, 2019 applies across the State, including GIFT City, and its exclusions do not mention SEZs. Professional tax is also a State levy. See Gujarat registrations. As an SEZ unit, an IFSC unit should also check whether any labour functions for the zone are exercised by the zone administration rather than the State labour department.
Practical steps
- Review pay structures against the codes' definition of wages, and re-cost gratuity and contributions.
- Issue appointment letters that meet the codes, and update contracts and policies.
- Register the establishment under the OSH Code and for provident fund and ESI as thresholds are crossed, and complete the Gujarat registrations.
- Set up registers, wage slips and notices in the forms the applicable rules prescribe.
- Track central and Gujarat rule notifications through the year.
IFSCA's requirement that principal officers and other KMPs be based in the IFSC interacts with these rules. See KMP qualifications and certification and hiring foreign nationals.