Dear Mr Raju, For construction work under Central Govt you need to take Licence under C L Act, as well as Registration under BOCW Act. You need to maintain registers in revised forms as per Ease of Compliance maintenance of registers under various labour laws Rules, 2017 . i.e. Register of A B C & D . You need to mention names of all workmen employed as contract labours at the work site who are not in a managerial position. Supervisors are required to be mentioned in the register. Clerical employees need to be included. Only the Project manager, Accounts Manager, Safety Manager etc are to be excluded. You may refer to the definition of Contract labour under Contract labour Act. As per the definition of Contract labour a workman shall be deemed to be employed as 'contract labour' in or in connection with the work of an establishment when he is hired in or in connection with such work by or through a contractor with or without the knowledge of the Principal Employer. The person employed by you is your workman with whatever designation but he is contract labour for the contract work taken by your company. Pl also refer the definition of the "Workman " under Contract Labour Act to decide whom to be included in the register and who are not required to be added in the registers. As mentioned above, Managerial staff need not to be included but supervisory staff and clerical staff required to be included. Though the clerks, supervisors are your permanent workers, they are contract labours only in respect of this contract project.
Principal employer's employees need not be included in your registers. Principal Employer is maintaining Register of contractor in Form XII which is not omitted from original Act and not included in revised Register Rules, 2017.