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India's Labour Codes Took Six Years to Become Law. The Rules That Enforce Them Are Still Rolling Out State by State

Wednesday, September 16, 2026

Parliament passed India's four labour codes in 2019 and 2020, consolidating 29 laws into four. They came into force on 21 November 2025 — with no rules yet written to operate them. The Central Rules that make them enforceable took another five and a half months; as of the most recent count, barely a third of India's states had notified their own.

Labour & Employment · Regulatory Reform · Federal Rollout

India's Labour Codes Took Six Years to Become Law. The Rules That Enforce Them Are Still Rolling Out State by State

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Revised · v1.0.0 · what changed

2019–2025years between the first code's passage and all four coming into force
29 → 4central labour laws consolidated into the four codes
~11 of 28states with final rules notified, per the most recent single-date tracker found
60.4% → 75.5%government's targeted rise in the formal-workforce share, once fully rolled out

India's four labour codes — the Code on Wages (2019), and the Industrial Relations, Social Security, and Occupational Safety, Health & Working Conditions Codes (all September 2020) — consolidate 29 separate central labour laws into four. Parliament finished passing all of them more than five years ago. They only came into legal force on 21 November 2025, and that date is itself a starting gun, not a finish line: the notification that made them "in force" carried no operative rules, and India's labour-code rollout has been happening in slow, uneven layers ever since.

North Block on Raisina Hill, New Delhi, one of the central secretariat buildings housing Union government ministries
The Union government notified the labour codes into force and wrote the Central Rules that operate them — but for most Indian workers, whether anything actually changes now depends on each state's own rulemaking. Source: Pinakpani, Wikimedia Commons, CC BY-SA 4.0.
Updated 27 October 2026. This piece said the original target for the codes was financial year 2024 (around April 2023) and that the delay came from centre–state disagreements over jurisdiction. The original target was 1 April 2021; it was deferred because most states had not framed their rules (labour is on the Concurrent List), and later 2021 dates slipped amid trade-union opposition. The text has been corrected.
Updated 22 October 2026. This post's latest count, from a 9 July 2026 tracker, put 11 states at final rules notified. On 24 September 2026, Labour Secretary Chandra Bhushan Kumar said ten states had published their rules and all other states and union territories had published draft rules, as reported by Business Standard. He said the Centre hoped every state and UT would notify rules under all four codes by 31 October 2026. That is one national target, not the per-state dates this post recommends. Counts differ by source and by whether all four codes are covered. An October 2026 law-firm newsletter says Bihar, Gujarat, Rajasthan and Uttar Pradesh had notified further rules. Sources: Business Standard, AMS Shardul newsletter. The original text below is unchanged.

Six years from passage to "in force"

The government's original target was to bring all four codes into effect from 1 April 2021. That date was deferred because most states had not yet framed their own rules, which they must do because labour is on the Concurrent List, and later dates in 2021 slipped too amid opposition from trade unions over job-security and worker-rights concerns. The codes stayed passed but dormant for years. The government notified them into force on 21 November 2025 — the date most coverage cites as "when India's labour reform happened."

What "in force" did not mean. A code "coming into force" is a legal trigger, not an operating system. The November 2025 notification activated the codes' text, but none of the detailed rules — wage calculation methods, dispute-resolution procedures, registration and compliance forms — that employers and regulators actually need to apply them existed yet.

"In force" without rules: the five-and-a-half-month gap

Draft Central Rules were published for public comment on 30 December 2025 — a 30-day objection window for the Industrial Relations Code's rules, 45 days for the other three. Government officials indicated the final rules would be notified by 1 April 2026. They were not. The Ministry of Labour and Employment actually notified the final Central Rules under all four codes on 8 May 2026 (G.S.R. 343(E)) — five weeks past even the extended target, and five and a half months after the codes' own "in force" date.

Central Rules cover a minority of India's workforce

The May 2026 Central Rules apply only where the central government is the "appropriate government" under India's labour-law framework: banking, insurance, telecommunications, mining, air transport, railways (including metro), major ports, oilfields, and central public-sector undertakings. Labour is a Concurrent List subject in India's constitution — the much larger share of the workforce, employed in sectors that fall under state jurisdiction, is governed by separate State Rules that each state and union territory has to frame and notify on its own. The Central Rules notification did not, by itself, operationalise the codes for most Indian workers.

The state rollout, state by state

Tracking exactly how many of India's 28 states have finished this is harder than it should be: no single, continuously updated government tracker was found, and secondary trackers disagree with each other depending on their snapshot date and on whether "notified" means all four codes or just some. The most recent single-date count located, dated 9 July 2026, put 11 states at final-rules-notified: Madhya Pradesh, Uttar Pradesh, Gujarat, Karnataka, Haryana, Uttarakhand, Jharkhand, Odisha, Bihar, Chhattisgarh and Assam. An earlier March 2026 snapshot listed a different, overlapping set of six states with all four codes' rules notified (Gujarat, Arunachal Pradesh, Haryana, Madhya Pradesh, Karnataka, Maharashtra) — the discrepancy between the two lists is itself evidence of how unevenly this is being tracked, not just how unevenly it is being rolled out. Separately, as of the most recent Parliament reply located, at least 17 states had taken some concrete implementation step (draft or final rules for at least one code), out of India's 28 states.

Reading this section. Treat the 11-state and 17-state figures as snapshots from specific, cited dates, not as a live count. Given the pace of notifications through 2026, either number is likely stale by the time this is read — the direction (most states not yet fully done, more than nine months after the codes' "in force" date) is the reliable part, not the precise count.
Nine Months In, Most States Aren't Done India's 28 states, labour-code state-rules rollout (most recent snapshots located) All Indian states 28 the denominator every count below is measured against Took at least some step 17 draft or final rules for at least one of the four codes, per Parliament reply Final rules notified 11 per a 9 July 2026 state-wise tracker snapshot Source: employmentlaw.lkslaw.com state-wise tracker (9 Jul 2026 snapshot) and a Parliament-reply figure as reported in trade coverage.
More than nine months after the codes came into force, well under half of India's states had finished notifying their own rules.

What the reform is meant to deliver, once complete

The government's stated goals for full rollout: formal protection for more than 90% of informal workers, a rise in the overall formal-workforce share from an estimated 60.4% to a targeted 75.5%, and social-security coverage reaching 85%. Every one of these is a target tied to full implementation — Central Rules plus every state's own rules — not a description of where the rollout stands today.

The net read

"India's labour codes took effect on 21 November 2025" is true and also not the whole story. The Central Rules that actually operationalise the codes took another five and a half months, and even they only reach the minority of the workforce under central jurisdiction. For most Indian workers, whether and when the codes change anything in practice depends on their own state government finishing a rulemaking process that, nine months after the "in force" date, a majority of states had not yet completed.

Sources: PIB's 21 November 2025 notification and contemporaneous coverage (DD News, News on Air) for the codes coming into force and the 29-laws-into-four consolidation. Legal-industry alerts (KPMG, DLA Piper, EY, BDO, Lexology, JSA) for the 30 December 2025 draft-rules publication, the 30/45-day comment windows, the 1 April 2026 target, and the actual 8 May 2026 Central Rules notification (G.S.R. 343(E)) and its scope (central "appropriate government" sectors only). The pre-2025 delay history (original 1 April 2021 target, deferred because states had not framed rules, and later 2021 dates that slipped amid union opposition) per ThePrint (2021) and Business Standard (31 March 2021); corrected 27 October 2026 from an earlier version that gave an FY2024 target. State-rules counts per employmentlaw.lkslaw.com's state-wise tracker (9 July 2026 snapshot: 11 states) and a separate March 2026 snapshot reported via search (6 states with all four codes' rules); the 17-states figure is from a government (Parliament reply) source as summarised in trade coverage. Formalisation targets (90% informal-worker protection, 60.4%→75.5% formal-workforce share, 85% social coverage) per SBI Research as reported in trade press. None of the state-count figures were independently verified against a primary government tracker for this post — see the note above.

Revision history.
  • v1.0.0 — 16 September 2026 — first published.
Related on this blog: India's E-Commerce Inventory Ban Just Got Its First Real Exception — For Exports Only — another piece where a law or ban took years to reach the specific exception or state-level rule that actually matters.

What would fix this

  • The Ministry of Labour and Employment should maintain a public tracker showing, for every state and union territory, the gazette date of draft and final rules under each of the four codes, so the 11-state and 6-state counts from private trackers stop being the only way to see where the rollout stands.
  • The Ministry of Labour and Employment should name the states, code by code, whenever it reports implementation progress to Parliament, so a figure such as 'at least 17 states have taken some step' can be checked and compared with later replies.
  • The Ministry of Labour and Employment should agree and publish target dates with each state that has not notified final rules, since the central rules missed their 1 April 2026 target by five weeks and most workers depend on state rules that have no published deadline.
  • The Ministry of Labour and Employment should publish an official baseline and annual figures for formal-workforce share and social-security coverage, so the stated goals of moving from 60.4% to 75.5% formal employment and 85% coverage can be tracked against government data rather than one bank's research note.

These are proposals from this blog, not recommendations any agency has adopted.

About this article: Researched, written and edited by Umashankar Triplicane Dwarakanathan, with AI research assistance; every figure is meant to trace to the primary source cited. See the Editorial Policy for how sourcing, AI use and corrections work.

Umashankar Triplicane Dwarakanathan
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Umashankar Triplicane Dwarakanathan
Investment Promotion & Energy-Sector Leader · Chennai, Tamil Nadu, India
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