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Nine more states notify rules under the Labour Codes — and they do not match

Karnataka, Gujarat and Tamil Nadu publish diverging registers, thresholds and return formats, confirming that Central consolidation has not produced ground-level uniformity.

Nine further states have notified their rules under the four Labour Codes. Reading them together confirms what employers with multi-state operations suspected: the consolidation happened at Central level and stopped there.

Where the divergence is

We compared the notified rules across Karnataka, Gujarat, Tamil Nadu, Maharashtra and Telangana against the Central draft rules. The substantive differences cluster in four places.

Register formats. The Central draft contemplated a common register. Four of the five states have prescribed their own formats with different columns. An employer operating in all five maintains five registers, not one.

Applicability thresholds. Contract labour licensing thresholds, canteen requirements and welfare officer appointment triggers differ by state — in some cases by a factor of two.

Return frequency and timing. Annual returns are due at different dates, and two states have retained half-yearly returns that the Central draft dropped.

Inspection scheme. Web-based random inspection allocation has been adopted differently, with some states retaining jurisdictional inspector discretion.

What this means practically

The operating assumption in most HR functions through 2024 and 2025 was that the Codes would allow consolidation of state compliance into a single national process. That assumption should now be retired.

What is genuinely simplified is the statutory architecture — four Codes instead of twenty-nine Acts, which makes the law easier to read. What is not simplified is compliance execution, which remains a state-by-state exercise with state-specific registers, returns, thresholds and inspectors.

The wage definition problem, again

Separately, the revised definition of wages continues to cause difficulty. Because the definition caps excluded allowances at fifty percent of total remuneration, a large number of Indian salary structures require restructuring to avoid an increase in provident fund and gratuity liability.

This is not an HR policy change. It is a payroll system change, an actuarial revaluation for gratuity, and a communication exercise with every affected employee. Organisations that treated it as a policy update will find the numbers do not reconcile at year end.

Table: selected divergences

ItemCentral draftKarnatakaGujaratTamil Nadu
Combined register formatCommonState formatState formatCommon
Annual return due1 February30 April31 January1 February
Welfare officer threshold250250500250
Half-yearly returnDroppedRetainedDroppedRetained

What Regulens customers see

State rules are maintained as separate obligation sets with the delta against the Central position made explicit. Customers with sites in the affected states received a scoped assessment identifying which registers and returns change per location, routed to the site HR owner rather than to a group distribution list.

How Regulens customers received this

This item was scoped against every customer footprint within 15 minutes of publication. Customers to whom it applies received it routed to the named owner for the relevant theme, with the obligations decomposed, the affected entities identified and any prior assessment carried forward with the delta highlighted. Customers to whom it does not apply saw nothing — with the suppression reason recorded and auditable.

This analysis is provided for information only and does not constitute legal advice. Read it alongside the primary source it cites. Where a source reference is given (State Gazette notifications), that is the authoritative text.

Get this filtered to your own footprint

Of the items we published this month, a typical customer sees fewer than twenty — scoped to their entities and licences, with the suppression reasoning available for every item they did not see.