On December 30, 2025, the Ministry of Labour and Employment pushed out a quiet-but-massive regulatory moment: draft "Central Rules" for multiple labour codes were published for public objections and suggestions. The Draft Industrial Relations (Central) Rules, 2025 set a 30-day window for feedback, with objections addressed to Govind Ram (Deputy Secretary), IR(PL) Section, Shram Shakti Bhawan, New Delhi, including the email irpl-mole@gov.in. In parallel, draft rules for the Code on Wages, Code on Social Security, and OSHWC Code each carry a 45-day window - and they even name the desks and emails HR leaders can write to: Under Secretary Nitesh Bhasin (wagecell@nic.in) for wages, Deputy Secretary Supriya Ranjan Datta (sr.datta@nic.in, tezveer.singh@nic.in) for social security, and Under Secretary Ravishankar Nirala (fasli@dgfasli.nic.in, ravis.nirala@nic.in) for OSHWC. This is not just "policy news". This is the rulebook that will decide how your audits feel in 2026.
HR teams will read this and feel a specific kind of dread: not because they hate change, but because they know what happens when rules move faster than systems. Payroll will ask "Is our wage definition clean?" Operations will ask "Are night shifts and rest days documented?" Legal will ask "How long do we keep records now?" And employees - the people who actually carry the cost - will feel it first through small humiliations: the payslip that doesn't match, the overtime that becomes an argument, the complaint that becomes a "process", the termination that turns into a decade-long scar. When laws change, good organisations upgrade controls. Bad organisations improvise, and employees become collateral damage. The real emotional core here is trust: if HR cannot explain the rules simply and execute them consistently, the workplace becomes a lottery where compliance is optional until it hurts someone.
From a compliance and leadership lens, these draft rules are a flashing sign 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: how you structure employment relationships, misconduct inquiries, standing orders, wage slips, deductions, registers, inspections, and dispute handling. The Code on Social Security, 2020 draft rules explicitly knit together frameworks that HR already treats as separate silos (ESI, EPF, gratuity, maternity benefit, employment exchanges) into one compliance map. The OSHWC draft rules carry a message many founders avoid: safety is not a poster - it is documented competence, and the absence of it becomes personal liability. The leadership lesson is simple: submit feedback if the drafts create unworkable friction, and simultaneously run an internal "pre-enforcement audit" - because the organisations that prepare now will not just avoid penalties, they will avoid moral injury to employees caused by sloppy, inconsistent compliance.
Source: @LabourMinistry, Gazette of India (Draft Labour Codes Central Rules, Dec 30-31, 2025)
If HR had one ethical duty during a major law transition, is it "protect the company from risk" or "protect employees from process failures" - and what does that look like in real decisions?
What would a practical 30-day response plan look like inside your organisation: who reads the drafts, who maps gaps, who owns submissions, and how do you prove readiness to auditors without creating bureaucracy?
HR teams will read this and feel a specific kind of dread: not because they hate change, but because they know what happens when rules move faster than systems. Payroll will ask "Is our wage definition clean?" Operations will ask "Are night shifts and rest days documented?" Legal will ask "How long do we keep records now?" And employees - the people who actually carry the cost - will feel it first through small humiliations: the payslip that doesn't match, the overtime that becomes an argument, the complaint that becomes a "process", the termination that turns into a decade-long scar. When laws change, good organisations upgrade controls. Bad organisations improvise, and employees become collateral damage. The real emotional core here is trust: if HR cannot explain the rules simply and execute them consistently, the workplace becomes a lottery where compliance is optional until it hurts someone.
From a compliance and leadership lens, these draft rules are a flashing sign 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: how you structure employment relationships, misconduct inquiries, standing orders, wage slips, deductions, registers, inspections, and dispute handling. The Code on Social Security, 2020 draft rules explicitly knit together frameworks that HR already treats as separate silos (ESI, EPF, gratuity, maternity benefit, employment exchanges) into one compliance map. The OSHWC draft rules carry a message many founders avoid: safety is not a poster - it is documented competence, and the absence of it becomes personal liability. The leadership lesson is simple: submit feedback if the drafts create unworkable friction, and simultaneously run an internal "pre-enforcement audit" - because the organisations that prepare now will not just avoid penalties, they will avoid moral injury to employees caused by sloppy, inconsistent compliance.
Source: @LabourMinistry, Gazette of India (Draft Labour Codes Central Rules, Dec 30-31, 2025)
If HR had one ethical duty during a major law transition, is it "protect the company from risk" or "protect employees from process failures" - and what does that look like in real decisions?
What would a practical 30-day response plan look like inside your organisation: who reads the drafts, who maps gaps, who owns submissions, and how do you prove 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.
From India, Gurugram
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.
From India, Gurugram
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