Labour Codes Compliance Calendar for Small Manufacturers (2026)

If you run a small factory in India, your labour compliance now sits under the four Labour Codes that came into force on 21 November 2025, but most of your day-to-day deadlines still look familiar: a monthly PF and ESIC cycle, a yearly factory return, and a handful of state-specific filings. This guide turns that into a working calendar you can paste into your diary, with the decisions you must make first and the points where states are still catching up.

It is written for owners and accounts or HR managers of units with roughly 10 to 200 workers. It is a planning aid, not a substitute for reading your own state's rules, because the Codes leave many dates and forms to the appropriate Government.

What actually changed on 21 November 2025

The Government brought the four Labour Codes into force together: the Code on Wages, the Industrial Relations Code, the Code on Social Security and the Occupational Safety, Health and Working Conditions Code (OSH Code). For a manufacturer, three changes matter most.

• The OSH Code replaced the Factories Act, 1948 and the Contract Labour (Regulation and Abolition) Act, 1970, among other laws. Your factory licence and contract labour licence are now issued under the OSH Code read with central or state OSH rules.
• The Code on Social Security replaced the old PF and ESI statutes. The EPF Scheme, 1952 has been replaced by the Employees' Provident Funds Scheme, 2026 (G.S.R. 525(E), 29 June 2026), and ESIC coverage is now pan-India for establishments with 10 or more employees.
• The Code on Wages brought in a single definition of wages that applies across wage payment, PF and ESIC. Payroll structures that park too much pay in allowances deserve a second look.

Rules are uneven across states. Uttar Pradesh notified its OSH rules in August 2026, while Delhi and Haryana OSH rules were still in draft when this guide was reviewed. Always confirm which version applies to your unit on your state labour portal.

Step zero: decide which rules apply to you

Before you build a calendar, answer five questions. The answers decide which rows of the calendar are yours.

1. Is your unit a factory? Under the OSH Code the thresholds are 20 or more workers where power is used, or 40 or more where it is not. Count workers on any day in the preceding twelve months, including workers supplied by contractors. See factory licence registration for the full test.
2. Do you use contract labour? If you engage workers through a contractor above the notified threshold, both you (principal employer) and the contractor have registration and licence duties. Read contract labour licence before the first work order.
3. How many employees are on payroll and what do they earn? This decides PF registration and ESIC registration. ESIC applies to employees earning up to the wage ceiling, which continued at Rs 21,000 per month in the Labour Ministry's March 2026 FAQs. PF contributions are mandatory on wages up to Rs 15,000 per month.
4. Which state are you in? Professional tax, labour welfare fund, shop or factory forms, and minimum wages are state subjects.
5. Do you buy from micro or small suppliers? If yes, the payment-time and MSME Form 1 rules in the calendar below apply to you.

The compliance calendar at a glance

The table groups obligations by frequency. Dates marked "state" differ by state, and dates marked "verify" come from older rules or secondary summaries and should be checked against the notified rules before you hard-code them in a reminder.

Month by month: the recurring cycle

Wages, registers and payroll cut-off

Set a payroll lock date. Attendance, overtime and deductions should be final several days before the month ends, because every later filing pulls from that sheet. Keep the registers of workers, attendance, wages, overtime, leave and accidents in the form your state requires, and move to electronic registers where the rules permit.

A good internal habit is a one-page monthly reconciliation: headcount by category (employee, contract, apprentice), total wages, PF wages, ESIC wages. When these four numbers do not agree with each other, you will find the reason before an inspector does.

PF: the 15-day window

Upload the ECR (the electronic challan-cum-return) and pay contributions within fifteen days of the end of the month. Report joiners, transfers and exits in the same window. The standard rate is 12 percent from the employee and 12 percent from the employer on wages up to Rs 15,000, with the EPS share of 8.33 percent forming part of the employer's share. Contributions above that wage level are voluntary. Keep each worker's UAN and Aadhaar and bank KYC current, since a failing KYC is the most common reason an ECR or a claim bounces. The detailed filing steps are in the PF return filing guide.

ESIC: contributions and the half-year tests

The ESIC rates have been 3.25 percent from the employer and 0.75 percent from the employee on wages up to the ceiling, with workers earning an average daily wage up to Rs 176 exempt from their own share. Confirm current rates on the portal before each payment cycle, because they are set by notification. Contribution periods run April to September and October to March, and an employee who crosses the wage ceiling mid-period is generally treated from the start of the next period. Practical steps are in ESIC return filing.

GST, TDS and professional tax

These are not labour-code obligations, but they share the same payroll and vendor data, so schedule them in the same week. If you are registered under GST, check the GST return filing requirements. Professional tax is a state levy on employees and employers; some states require monthly payment and others annual, so use your state's schedule and see professional tax return.

Half-yearly and annual items

MSME Form 1 and supplier payment

Companies that owe micro or small enterprises beyond 45 days must report the outstanding amounts in MSME Form 1 on a half-yearly basis. The deadlines have conventionally fallen at the end of the month after each half-year closes, but confirm the current dates on the MCA portal. Details are in MSME Form 1 return.

Labour welfare fund

Several states, including Delhi, Haryana and Uttar Pradesh, run a welfare fund with employer and employee contributions. Frequency and amounts are state-specific. If you are expanding into a new state, add it to the calendar on day one. Registration steps are at labour welfare fund registration.

Factory annual return

The OSH Code requires an annual return through the designated portal. Under the Uttar Pradesh OSH rules, the annual return is Form-17 with a 31 January date according to the secondary summaries we reviewed. Other states have used the same date historically, but confirm for yours. The practical advice is to build it as a roll-up of your twelve monthly reconciliations. See factory annual return.

Environment and fire

If your unit holds pollution consent, the annual Environmental Statement (Form V) has traditionally been due by 30 September, and consent conditions often require periodic stack or effluent monitoring. Fire safety certificates in Delhi, Haryana and Uttar Pradesh each carry annual or half-yearly declarations or certificates that differ by state. Read pollution NOC and fire NOC for what applies to you.

Licence renewal

Factory licences are issued for a chosen period. Delhi lets you pick 1, 5 or 10 years, Haryana has auto-renewal for 5 or 10 years where particulars are unchanged, and under the UP rules the first licence is for one year and renewal can run up to ten years, with a surcharge for late renewal. Read the validity printed on your own licence and set a reminder 90 days before it.

Event-based triggers small units forget

Calendars capture recurring dates, but most inspection findings come from events:

• Headcount crossing a threshold. Crossing 10 employees (ESIC), the PF threshold, or the factory threshold triggers registration. Register as soon as you cross, because arrears are computed from the date of coverage.
• New machine or higher load. Adding power or machinery changes your licence slab and may need amendment or fresh plan approval before installation.
• Change of occupier, director or address. File an amendment and update PF, ESIC, GST and Udyam so that the records match.
• Accidents. Report within the prescribed time and preserve registers.
• Contractor changes. A new contractor needs verification of licence, PF and ESIC code before the first day.
• Closure. Close each registration formally. Dormant codes keep generating notices.

Time-bound reliefs worth checking

The 2026 PF framework includes one-time relief windows: the Employees' Enrolment Campaign 2026 (valid until 31 October 2026), the VISHWAS 2026 scheme for older contribution defaults, and the AMNESTY 2026 scheme for exempted establishments. Each has eligibility conditions and a deadline, so take advice before you rely on one.

Common mistakes small manufacturers make

• Counting only payroll staff. Contract workers count towards factory thresholds and appear in contractor compliance.
• Different headcounts in different returns. PF, ESIC, the factory return and the GST-linked payroll should tell the same story.
• Treating Code transition as a pause. Old guides still quote the Factories Act thresholds of 10 and 20. Use the OSH Code and your state's rules.
• Relying on one person's memory. A signatory who leaves with the only DSC token stops your PF filing.
• Paying minimum wages from an old notification. State minimum wages are revised, so check the current notification each period.

A simple setup that works

1. Build a master sheet with one row per obligation: authority, form, frequency, due date, owner, backup owner.
2. Set each reminder five working days before the due date, not on it.
3. Keep a folder per month holding the challans, acknowledgements and registers.
4. Review the sheet every quarter and every time a state notifies new rules.
5. Keep an annual list of licence expiry dates, DSC expiry dates and insurance renewals in one place.

When to bring in professional help

Take advice when you are crossing a threshold, moving from legacy licences to Code-era rules, dealing with notices, or running units in more than one state. A short review of your registrations against your actual headcount often finds the gaps before the inspector does.

Reviewed by Satyam Gupta, Company Secretary (CS) & Advocate

8+ years of industry experience. Last reviewed 16 October 2026. Always confirm current rules and fees on the official portal before acting.