Introduction
When I first looked at the Occupational Safety, Health and Working Conditions Code, 2020, what stood out to me was not just the subject itself, but the larger idea behind it. Indian labour law had become too scattered, too sector-specific, and frankly too complicated to work smoothly in a modern economy. The Ministry of Labour’s own material says the Code was meant to consolidate 13 central labour laws into a single framework, reduce multiplicity of compliances, and bring uniformity across industries and States/UTs through things like single registration, all-India single licence, electronic filings, and time-bound approvals. It also extends to establishments with 10 or more workers, along with mines and docks.
Current Relevance and Enforcement
As of November 2025, the Government made the four labour codes effective, which makes this discussion especially relevant right now rather than only in theory. The official messaging around the reform has been that the labour codes are supposed to balance worker protection with a more business-friendly compliance structure.
Structural Shift in Labour Regulation
What I find interesting is that the Code is not just a replacement of old laws. It is really an attempt to change the way workplace safety is imagined. Under the earlier regime, safety law often felt fragmented, with different statutes handling factories, mines, contract labour, plantations, docks, and other workplaces separately. The new Code tries to pull all of that into one place. On paper, that sounds efficient. In practice, though, the question is whether efficiency and safety always move in the same direction.
Key Improvements
There are definitely some positive changes. The labour ministry’s handbook notes that the Code requires appointment letters, free annual health check-ups, safer working conditions, and safety committees, and it also lays down obligations around workplace hygiene, drinking water, toilets, first-aid, and shelter rooms. It also allows women to work in all establishments and all types of work, including night shifts, subject to consent and prescribed safeguards. These are not small reforms. They show that the law is at least trying to respond to the realities of modern work.
Shift from Protection to Compliance
At the same time, the Code feels very different from the older protective model of labour regulation. The older model relied more heavily on direct statutory controls and inspection-heavy enforcement. The new model seems to prefer simplification, digital compliance, and administrative flexibility. That is not automatically a bad thing, but it does raise a real concern: if the system becomes easier for employers to manage, does it become equally strong for workers who actually need protection? My own reading is that this is where the tension lies.
Comparison with International Standards
The comparison with international standards makes that tension even clearer. The ILO says Convention No. 155 is a fundamental convention and that it establishes the core framework for occupational safety and health at both national and workplace levels. The ILO also explains that Convention No. 161 is about occupational health services and is essentially preventive in nature. So, the international idea is not just “have some rules,” but create a safety culture, preventive systems, and stronger workplace-level health support. The Indian Code moves in that direction, but whether it reaches the same depth depends entirely on implementation.
Corporate Challenges and Implications
That is where the real corporate challenge begins. For companies, the Code does reduce paperwork in some ways because it pushes registration, licensing, filings, and approvals into a more streamlined system. But the same Code also expects employers to create safer workplaces, maintain records, issue appointment letters, conduct health checks, and comply with safety-related obligations in a much more structured way. So the burden has not disappeared; it has simply changed shape. For larger companies, that may be manageable. For smaller ones, it may feel like a serious compliance reset.
Efficacy and Ground Reality
The bigger problem, at least in my view, is efficacy. A law can look modern and still remain weak on the ground if the enforcement structure is not equally strong. The Standing Committee summary noted several concerns, including unclear distinctions between workers and employees, the fact that unorganised sector workers are not protected under the Code, and the need for broader coverage and clearer safety obligations in smaller establishments. It also recommended that safety officers should not be limited so narrowly and that the law should better address hazardous substances and contract labour. Those observations matter because they show that even before implementation, the Code had gaps that needed attention.
Critical Perspective
So when I think about the OSH Code, I do not see it as a perfect reform or a failed one. I see it as an unfinished one. It certainly modernises the language of workplace safety and gives the law a cleaner structure. But the deeper question is still unresolved: does it actually make work safer, or does it mainly make compliance easier to manage on paper? That, to me, is the real test of its success.
Conclusion
For me, the strongest way to read this Code is as a reform that is promising in form, but still uncertain in substance. The statute has the right ambition, and the timing of its enforcement makes it very current, but its real value will depend on whether the State can enforce it properly and whether employers treat safety as a real obligation rather than a box-ticking exercise. That is why the Code matters: not because it exists, but because the workplace conditions it is supposed to improve are still very much a live issue.
.References
• Ministry of Labour and Employment, Government of India – Occupational Safety, Health and Working Conditions Code Handbook
• Press Information Bureau – Labour Codes Implementation Updates
• International Labour Organization – Convention No. 155 and Convention No. 161
• PRS Legislative Research – Standing Committee Report on OSH Code
Author Name- Arinjay Vardhan Jain, is currently pursuing B.B.A. LL.B., 8th Semester.
