The Occupational Safety, Health and Working Conditions (OSH) Code, 2020 replaces 13 central labour laws — including the Factories Act, Mines Act, and Contract Labour Act — with a single, unified regulation. Its implementation at the State level places a new, comprehensive set of duties on every employer, regardless of whether you run a manufacturing plant, a logistics firm, or a large office.

Compliance is no longer just about industrial safety; it's about the holistic well-being and formalisation of your workforce. Failure to comply can result in substantial penalties, including fines and, for serious offenses, potential imprisonment.

⚠️ Penalty Risk

Non-compliance with the OSH Code can result in significant monetary fines and, in cases of serious injury or death, courts may direct that at least 50% of any fine be paid as compensation to the victim or their heirs.

1. Statutory Registration & Formalisation

The OSH Code emphasises ease of doing business through a single, electronic registration, but also mandates formalisation of all employment.

Compliance StepAction RequiredZiacPay Solution
Unified RegistrationRegister your establishment electronically on the State's Shram Suvidha portal (replacing multiple old registrations).Provides all required data points for seamless electronic registration and compliance reporting.
Mandatory Appointment LettersIssue a formal Appointment Letter to every worker, regardless of role or tenure, clearly stating designation, wages, and social security benefits.Automated generation of statutory, compliant appointment letters for all new hires and existing employees.
Applicability ThresholdCheck your employee count: the Code broadly applies to establishments with 10 or more workers.Tracks your employee count in real-time to alert you when you cross regulatory thresholds.
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2. Worker Welfare and Working Hours

The Code introduces critical updates to working hours, overtime, and provisions for specific worker categories, including women and migrant workers.

Work Hours & Overtime

  • Daily/Weekly Limits: No worker is allowed to work more than 8 hours a day or 48 hours a week.
  • Overtime Consent & Pay: Overtime requires the worker's prior written consent and must be compensated at twice the normal wage rate.
  • Overtime Cap: Ensure overtime does not exceed the limit set by your State rules (typically 125 hours in a quarter as per draft rules).

Women & Welfare Facilities

  • Night Shift for Women: Women are permitted to work between 7 PM and 6 AM, but only with their consent and subject to the employer providing adequate safety, lighting, and mandatory transportation.
  • Basic Amenities: Provide separate, secure, and clean washrooms, bathing places, and locker rooms for male, female, and transgender employees.
  • Canteens/Restrooms: Establish and maintain canteens, first-aid facilities, and rest areas as required by your State's rules based on employee strength.

3. Mandatory Health & Safety Provisions

This is the core of the OSH Code, requiring proactive measures to prevent accidents and occupational diseases.

Area of ComplianceChecklist ItemPenalty Risk
Health Check-upsArrange free, annual health check-ups for all workers above 45 years of age (and all workers in hazardous industries, regardless of age).Non-compliance with worker welfare and health provisions.
Safety CommitteeIf your establishment employs 500 or more workers, you must constitute a statutory Safety Committee with equal representation from employers and workers.Failure to provide a mechanism for worker consultation on safety matters.
Hazard AssessmentImplement a documented system for identifying and mitigating workplace hazards (physical, chemical, ergonomic).Fines for unsafe working conditions leading to injury or illness.
Training & PPEEnsure mandatory safety training (especially for handling chemicals/machinery) and provide appropriate, well-maintained Personal Protective Equipment.Non-compliance can lead to massive liability in case of a workplace accident.

4. Documentation, Audits, and Penalties

Streamlined Documentation

Move away from the 84 separate registers previously required to maintain a simplified set of records, focusing on:

  • Register of Workers (Attendance, Wages, Leave, Overtime)
  • Register of Accidents, Injuries, and Dangerous Occurrences
  • Medical Examination Records and Safety Audit Reports

Penalties & Enforcement

The new system replaces traditional 'Inspectors' with 'Inspector-cum-Facilitators', focusing on guidance over immediate penalty. However, penalties remain severe for non-compliance.

⚠️ Penalty Structure

Courts are empowered to direct that at least 50% of any fine imposed be paid as compensation to the victim or their heirs in cases of serious injury or death.

The ZiacPay Solution: Mitigating OSH Risk

ZiacPay provides a comprehensive compliance framework built around the OSH Code's requirements:

  • Integrated Safety Training Module: Track and schedule all mandatory OSH trainings across your workforce, with automated reminders for renewals.
  • Appointment Letter Automation: Generate and distribute statutory, compliant appointment letters for every new hire in minutes.
  • Working Hours Tracker: Real-time overtime monitoring with automatic alerts when employees approach legal limits, preventing costly violations.
  • Digital Register Maintenance: Maintain all required OSH registers in digital format, instantly available for inspection by State labour inspectors.
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Conclusion

The OSH Code represents a step change in how India expects employers to treat their workforce. By taking a proactive, technology-driven approach to compliance, your SME can avoid penalties while simultaneously building a safer, more productive workplace.

AP

Anjali Patel

Senior Compliance Analyst, ZiacPay

Anjali specialises in occupational safety law and HR policy for Indian manufacturing and services SMEs. She helps organisations navigate the OSH Code's requirements through practical, audit-ready compliance frameworks.