The key dates
- 21 November 2025: the Occupational Safety, Health and Working Conditions Code, 2020 came into force, along with the other three labour codes.
- 8 May 2026: the OSH (Central) Rules, 2026 came into force.
- 2026: Maharashtra has published draft state rules for factories. Until they are final, existing rules framed under the repealed laws continue to apply where they are consistent with the Code.
Who counts as a factory now
The worker threshold has doubled. Some smaller units may no longer be factories under the Code, but many other obligations still apply.
| Factories Act, 1948 | OSH Code, 2020 | |
|---|---|---|
| With power | 10 or more workers | 20 or more workers |
| Without power | 20 or more workers | 40 or more workers |
Registration
- New establishments register within 60 days of the Code applying to them, on the Shram Suvidha portal.
- Establishments already registered under a central labour law are deemed registered, but must update their particulars within six months of the Rules commencing.
- Changes in particulars must be updated within 30 days.
Safety officers
A safety officer is mandatory for factories with 500 or more workers, and for factories carrying on a hazardous process with 250 or more workers.
Hazardous processes
Before starting a new hazardous process, the occupier must notify the Chief Inspector-cum-Facilitator at least 30 days in advance. Failing to do so can lead to penalties and cancellation of the factory licence.
Inspections
Inspectors are now Inspector-cum-Facilitators, and inspections move to a web-based, randomised scheme. Well-kept records matter more than ever.
What to do now
- Confirm whether your establishment is a factory under the new thresholds.
- Update or complete registration on the Shram Suvidha portal.
- Check whether you need a safety officer.
- Review your legal register against the Code and the Maharashtra draft rules.
