Labour Licence and Establishment Registration under the OSH Code, 2020 — Contract Labour, Shops & Establishments, BOCW
Video Explanation & Insights
Related from our channel: factory licence — documents, fees, inspection, renewal
3 videos on this topic
What changed on 21 November 2025, and what a labour licence now means
Until November 2025 a labour licence meant the contractor's licence and principal employer's registration under the Contract Labour (Regulation and Abolition) Act, 1970, triggered at 20 contract workers. On 21 November 2025 the Government brought the four Labour Codes into force. The Occupational Safety, Health and Working Conditions Code, 2020 (OSH Code) now consolidates 13 laws — contract labour, factories, building and construction workers, inter-state migrant workers, beedi and cigar, plantations, mines, motor transport, working journalists and others — into one registration, one licence, one return and 20 forms in place of 55.
Three numbers now decide compliance. Every establishment with 10 or more workers takes a single electronic registration. A contractor who supplies or engages 50 or more contract workers needs a licence, which can be a single all-India licence valid for five years. Factories need a licence at 20 workers with power or 40 without. State rules under the Codes are being aligned, so the portal and fee schedule depend on whether the appropriate government for your establishment is the Centre (Shram Suvidha) or the state.
You need a labour registration or licence if you
- •Run any establishment — office, shop, warehouse, site, hospital, hotel — with 10 or more workers
- •Supply manpower, security, housekeeping, canteen, loading or project labour of 50 or more workers to a principal employer
- •Engage contractors' workers as a principal employer and must register and list your contractors
- •Execute building or construction work with 10 or more workers (BOCW registration and 1% cess)
- •Run a factory with 20 or more workers with power, or 40 without
- •Open a shop or commercial establishment (state Shops and Establishments registration, usually within 30 days of starting)
Thresholds and requirements under the OSH Code
| Compliance | Threshold / requirement | Source |
|---|---|---|
| Establishment registration | 10 or more workers (universal threshold); electronic registration within the time prescribed by rules; one registration replaces six | Section 3, OSH Code 2020; PIB, November 2025 |
| Contractor licence | Contractor employing or supplying 50 or more contract labour; work-specific or single all-India licence, valid 5 years; security deposit and fee per rules | Chapter XI, OSH Code; threshold raised from 20 |
| Principal employer | Registered establishment must declare contractors and contract labour; joint liability for wages if the contractor defaults | Sections 47–55 |
| Factory licence | 20 workers with power / 40 without power; permission for construction or expansion within 30 days with deemed approval | Section 2(w), Chapter on factories |
| BOCW | Building or other construction work with 10 or more workers: registration and 1% cess on construction cost | OSH Code and BOCW Cess Act 1996 |
| Inter-state migrant workers | Establishment must indicate the number of ISMW at registration and licence; journey allowance once in 12 months | OSH Code |
| Hazardous occupations | Government may extend the Code to an establishment with even one employee | Section 1(4) |
Documents required for labour licence and registration
Establishment / principal employer
- •PAN, GST and constitution documents
- •Address proof of the establishment (rent agreement / ownership, utility bill)
- •Nature of work, number of workers (direct, contract, migrant), male/female
- •EPF and ESIC registration numbers
- •Details of manager / occupier and authorised signatory
- •List of contractors with work orders (for principal employer)
Contractor licence
- •Work order / agreement with the principal employer
- •Form/certificate from the principal employer (as per rules)
- •Number of contract workers and period of work
- •PAN, GST, Udyam, EPF and ESIC of the contractor
- •Security deposit and licence fee payment
- •Details of wages, facilities and safety arrangements
BOCW / factory
- •Site or factory plan, approvals from local authority
- •Estimated construction cost (for cess) / installed power (for factory)
- •Safety officer and welfare arrangements where thresholds apply
How the licence and registration are obtained
- 1Day 1–2 — Applicability: headcount, contract workers, work type and appropriate government identified; the exact registrations and licences listed with fees and deposits.
- 2Day 2–5 — Filing: application on the Shram Suvidha portal (central sphere) or the state labour portal with documents, fee and security deposit; principal-employer particulars linked.
- 3Day 5–20 — Scrutiny: the licensing officer may seek clarifications or inspect; replies filed. Where the rules provide deemed approval, the certificate issues on expiry of the period.
- 4Day 15–30 — Grant: registration certificate / licence issued electronically; displayed at the establishment.
- 5Ongoing — Registers of workers, wages, attendance and overtime maintained electronically; single annual return filed; licence renewed before the five-year expiry; amendments filed when workers or work orders change.
Fees, validity and renewal
| Item | Amount / period | Notes |
|---|---|---|
| Registration / licence fee | Slab based on number of workers, as prescribed by the central or state rules | Charged at actuals; quoted before filing |
| Security deposit (contractor) | Per contract worker, as prescribed | Refundable on expiry / surrender |
| BOCW cess | 1% of construction cost | Paid by the employer to the Welfare Board |
| Validity | Single all-India licence 5 years; registration continues subject to amendments and returns | OSH Code |
| BookMyCA professional fee | Fixed fee per registration / licence | Includes returns set-up |
| Timeline | 15–30 days | Deemed approval where provided |
Worked example: a facility-management contractor in Jaipur
A private limited company supplies 120 housekeeping and security staff to three IT parks. Under the 1970 Act it held a separate licence for each site. Under the OSH Code it registers its own establishment (it has more than 10 workers), applies for a single licence covering all sites since it supplies more than 50 contract workers, pays the security deposit on the declared headcount, and links each work order to the principal employers, who in turn record it in their registrations. The company files one annual return instead of several, and its licence runs for five years with amendments when a new client is added.
Mistakes to avoid
- •Assuming the old 20-worker trigger; the contractor licence threshold is now 50, but establishment registration starts at 10
- •Splitting one contract into several to stay below thresholds; workers across sites are counted
- •Missing the appointment letters, wage registers and overtime records the Codes make mandatory
- •Engaging contractors without a valid licence as a principal employer; liability for wages falls on you
- •Letting the five-year licence lapse mid-contract
Frequently asked questions on labour licence
No. The Contract Labour (Regulation and Abolition) Act, 1970 was subsumed into the Occupational Safety, Health and Working Conditions Code, 2020, which came into force on 21 November 2025. Existing licences continue for their term; new ones are issued under the Code.
Fifty or more contract labour, up from 20 under the old Act. Establishment registration applies at 10 or more workers regardless.
The single all-India licence under the Code is valid for five years. Registration continues, subject to returns and amendments.
Yes, where the state Act applies to shops and commercial establishments; it is a state registration usually required within 30 days of starting. Many states have merged it into the labour portal.
The establishment that engages contract labour through a contractor. It must be registered, list its contractors, ensure facilities and, if the contractor fails to pay wages, pay them and recover from the contractor.
Work order and principal-employer certificate, number and period of contract workers, PAN, GST, EPF and ESIC registrations, security deposit and fee.
Usually 15 to 30 days; the Codes provide deemed approval where the authority does not act within the prescribed period.
Official sources this page is based on
- Occupational Safety, Health and Working Conditions Code, 2020 — Ministry of Labour & Employment
- Shram Suvidha Portal — registration and licence under the Labour Codes
- Rajasthan Labour Department — state registrations and licences
Fees, thresholds and timelines above are taken from these Acts, Rules, notifications and official portals; where the authority's current notification differs, the notification prevails.