Navigating the 30-Day Challenge: Understanding the Impact of New Labour Codes Draft Rules on HR Teams and Developing a Response Plan

On December 30, 2025, the Ministry of Labour and Employment introduced draft "Central Rules" for multiple labour codes, marking a significant regulatory moment. The Draft Industrial Relations (Central) Rules, 2025, opened a 30-day window for public feedback. Objections were to be addressed to Govind Ram, Deputy Secretary, IR(PL) Section, Shram Shakti Bhawan, New Delhi, via the email irpl-mole@gov.in. Concurrently, draft rules for the Code on Wages, Code on Social Security, and OSHWC Code were published, each with a 45-day feedback window.

This is not just "policy news". It's the rulebook that will shape your audits in 2026. HR teams may feel apprehensive, not because they resist change, but because they understand the consequences when rules outpace systems. Payroll, operations, and legal departments will have questions, and employees will bear the brunt of any inconsistencies. When laws change, good organisations upgrade controls, while bad ones improvise, often at the expense of employees. Trust is at the core of this issue: if HR cannot simplify and consistently apply the rules, the workplace can become a compliance lottery.

From a compliance and leadership perspective, these draft rules are a warning for proactive risk owners. The Industrial Relations Code, 2020 and the Code on Wages, 2019 are not just "HR laws" - they are operational design constraints. The Code on Social Security, 2020 draft rules consolidate frameworks that HR currently treats as separate entities into one compliance map. The OSHWC draft rules send a message many founders ignore: safety is not a poster - it is documented competence, and the lack of it can lead to personal liability. The leadership lesson is clear: provide feedback if the drafts create friction, and simultaneously conduct an internal "pre-enforcement audit". Organisations that prepare now will not only avoid penalties but also prevent harm to employees caused by inconsistent compliance.

If HR had one ethical duty during a major law transition, would it be "protect the company from risk" or "protect employees from process failures" - and what would that look like in real-life decisions?

What would a practical 30-day response plan look like in your organisation: who reads the drafts, who identifies gaps, who is responsible for submissions, and how do you demonstrate readiness to auditors without creating bureaucracy?

The ethical duty of HR during a major law transition is twofold: to protect the company from risk and to shield employees from process failures. These duties are not mutually exclusive; in fact, they are interdependent. Protecting the company from risk involves ensuring compliance with new laws, which inherently includes preventing process failures that could harm employees.

A practical 30-day response plan might look like this:

1. Assign a team to read and understand the drafts. This team should ideally include representatives from HR, legal, and operations. They should dissect the drafts, understand the implications, and identify areas of concern or ambiguity.

2. Identify gaps in current practices. The team should compare the draft rules with current practices to identify gaps. This will involve a thorough review of existing policies, procedures, and systems.

3. Assign responsibility for submissions. Someone with a good understanding of the organisation's operations and the draft rules should be responsible for drafting and submitting feedback. This person should collaborate with the team to ensure all concerns are addressed.

4. Demonstrate readiness to auditors without creating bureaucracy. This involves creating a detailed compliance roadmap, including changes to policies, procedures, and systems, and a timeline for implementation. It also includes training programs for employees to understand the new rules.

5. Conduct a "pre-enforcement audit". This internal audit should assess the organisation's readiness for the new rules and identify areas for improvement.

Remember, the goal is not just to avoid penalties, but also to ensure a smooth transition for employees. This requires clear communication, comprehensive training, and consistent application of the new rules. It's also important to provide channels for employees to voice their concerns and ask questions. This approach will not only ensure compliance but also build trust and confidence among employees.