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Why promoters, PMCs, and contractors can’t treat this as “just a compliance change” On 21 November 2025, India finally implemented its four long-awaited Labour Codes on Wages, Industrial Relations, Social Security, and Occupational Safety & Health replacing 29 central labour laws in one stroke. (The Times of India)

For a sector that runs on subcontracting, migrant labour and tight margins, construction will feel these changes more sharply than most. Some see this as a huge compliance headache; others as a once-in-a-generation chance to formalise and professionalise the workforce. The Reality is: it’s both.

1. Quick refresher: What has changed?

India’s four Labour Codes are:

  • Code on Wages, 2019 – Common rules for minimum wages, timely payment, and a standardised definition of “wages” applicable across sectors. (Ministry of Labour & Employment)

  • Industrial Relations Code, 2020 – Governs strikes, layoffs, retrenchments, fixed-term employment and dispute resolution. The threshold for prior government approval for layoffs has been raised from 100 to 300 workers in many establishments. (Reuters)

  • Code on Social Security, 2020 – Brings unorganised workers, building & construction workers, gig and platform workers under a unified social security framework (PF, ESI, insurance, pension, etc.). (Ministry of Labour & Employment)

  • OSHWC Code, 2020 (Occupational Safety, Health and Working Conditions) consolidates 13 laws, including the Building and Other Construction Workers (BOCW) Act, into one framework for safety, health, welfare, and working conditions. (DG FASLI)

Together, these codes aim to simplify compliance for employers while expanding protections for workers. Whether that balance is achieved on the ground will depend heavily on how industries like construction respond.

2. Impact on Construction: Six big shifts

(a) Formalisation of site labour

Letters of appointment, clearer wage records and standardized definitions of “employee” and “wages” are now non-negotiable even for site workers (Taxscan)

For construction, this means:

  • Less room for “nameless” daily wagers and cash payments.
  • Project owners will increasingly demand worker registers, digital muster rolls, and proof of wage compliance from contractors.
  • Tier-2 and Tier-3 subcontractors will need help (and pressure) from main contractors to upgrade documentation systems.

This will initially increase admin work, but it will also reduce disputes, wage-related claims, and reputational risk.

(b) Wages, overtime and cost structure

The new wage definition broadens what counts as “wages” and affects PF, gratuity, bonuses, and other benefits. For many contractors, “cost to company per worker” will go up, even if the nominal daily wage looks similar. (Karmika Spandana)

The Codes also allow up to 12-hour shifts, provided weekly hours remain capped at 48, and overtime is paid at twice the normal rate. (Reuters)

For construction this translates to:

  • Need to re-work BOQs, rate analyses and bids factoring higher social security outgo and overtime liabilities.
  • More structured shift planning, especially for night concreting, shutdowns and fast- track jobs.
  • Greater scrutiny from clients on how contractors are managing fatigue and safety when pushing 10–12 hour shifts.

(c) Safety, health and welfare at sites

The OSHWC Code makes safety and welfare obligations much more explicit: registration, risk assessments, welfare facilities, safe accommodation for migrant workers, and stricter oversight on hazardous activities. (DG FASLI)

For building and infrastructure projects, expect:

  • Tighter requirements on PPE, scaffolding, work at height, lifting operations, and confined space entry.
  • Better provisions for sanitation, potable water, rest areas and crèches on large sites.
  • Increased accountability of principal employers/owners, not just labour contractors, for accidents and unsafe conditions.

This will push construction firms to move from “paper safety” to visible safety culture or face penalties, stoppages and reputation damage.

(d) Social security for building and construction workers

The Social Security Code retains and integrates the framework for cess and welfare schemes for building and other construction workers, while expanding coverage to a wider set of unorganised workers. (Ministry of Labour & Employment)

Implications:

  • No more “token” registration Boards and inspectors are likely to demand accurate worker counts and cess contributions.
  • Better access (at least in principle) to insurance, pension, health and education benefits for site workers and their families.
  • Contractors will have to digitally register workers, update details and ensure cess is factored into pricing and cash flow.

Done well, this can become the backbone of workforce mainstreaming for millions of construction workers who currently live without any safety net.

(e) Industrial relations and subcontracting dynamics

With the Industrial Relations Code, mid-sized construction and EPC firms get more flexibility around layoffs and closure (100 → 300 workers threshold), and clearer rules on fixed-term employment. (Reuters)

Practically, for construction:

  • Companies can ramp up or wind down project-linked teams more easily—if they also handle notice, compensation and communication professionally.
  • Expect more use of fixed-term contracts for specialists, but also more attention from unions and civil society where misuse is suspected. (Reuters)
  • Transparent subcontracting chains will become critical: disputes at one layer (labour contractor vs worker) can quickly escalate to principal employer or client.

(f) Compliance risk vs brand opportunity

Trade unions are already calling the new Codes a “fraud on workers” and planning protests, while business sees both opportunities and cost pressures. (Reuters)

For the construction industry, this is a reputation crossroads:

  • One path is minimum compliance doing the bare legal minimum, hiding behind contractors and hoping enforcement stays weak.
  • The other is to use this moment to differentiate as a responsible employer: transparent wages, safe sites, social security coverage and decent living conditions for migrant workers.

The second path is harder in the short term but it will attract better talent, better clients and better capital.

3. What progressive construction leaders should do now

If you are a project owner, EPC contractor, or large subcontractor, here’s a practical action list:

Next 3–6 months

  • Run a Labour Code Impact Assessment for your projects: contracts, rate analyses, HR policies, wage structures, and safety systems.
  • Map your entire labour supply chain down to small subcontractors and identify where documentation and compliance are weakest.
  • Start digital worker registries (even a disciplined Excel + QR system is a start) to track identity, attendance, wages, and social security contributions.

6–18 months

  • Integrate Labor Code requirements into tender conditions, pre-qualification criteria and contractor performance evaluations.
  • Build site-level dashboards for safety incidents, overtime hours, and social security coverage to review in monthly project reviews.
  • Invest in training for site engineers, supervisors and contractors on the new Codes and on humane people management not just checklists.

Longer term

  • Position your company as a “Workforce Mainstreaming” champion linking skills, safety, social security and career pathways for workers.
  • Use data from your compliance systems to engage with clients, investors and government on policy improvements and practical challenges.

Closing thought

India’s new Labour Codes are not just a legal reform they are a mirror held up to how we build our cities, highways, airports and factories. For the construction ecosystem, the real question is not “How do we avoid penalties?” but “How do we build projects without bankrupting the dignity, safety and future of the people who build them?”

Leaders who answer that question honestly and redesign their systems accordingly will be the ones who truly benefit from this historic reform.

BLOGS

Anand V

Anand is a seasoned Project Controls and Planning Manager with over three decades of experience and a skilled professional with a strong foundation in engineering and computer science. With a proven track record of success in large-scale projects, has expertise in planning, scheduling, and project management. Served as an in-house training faculty at L&T, sharing their knowledge through effective training programs and lectures.

Education

  • Bachelor of Engineering (Civil Engineering) – Karnataka Regional Engineering College, Surathkal (1985 – 1989)
  • Master of Technology (Industrial Structures – JSS Science and Technology University, Mysuru (2021-2023)

Expertise

  • Project Management
  • Project Controls
  • Contracts Administration
  • Training and Development – Approved in-house Training Faculty at L&T on Project Management and Planning

Professional Experience

Larsen & Toubro Limited, Construction Division (1989 -2022)
  • 2020-2022: Project Manager, Wipro, IT SEZ Project, Bengaluru
  • 2019-2020: Project Controls, Planning, Contracts Administration, Al Rayyan FIFA Stadium, Qatar
  • 2016-2018: Project Controls, Planning, Contracts Administration, Wipro, IT SEZ Project, Bengaluru
  • 2013-2015: Project Controls, Planning, Contracts Administration, Shell’s New Technology Centre, Bengaluru
  • 2009-2012: Planning, Mixed-used Development Project – Seawoods Grand Central
  • 2006-2008: Project Controls, Mogul Gardens Residential Buildings, Dubai
  • 2003-2005: Internal System Compliance & Management Information System, Project Schedule Monitoring, Electricity & Water Training Institute Project, Kuwait
  • 1998-2003: Tender to project handover, Tarapur Atomic Power Project-3&4, Head of Technical Office
  • 1989-1997: Graduate Trainee to Planning Manager, Kaiga Atomic Power Project-1&2, Precision surveying, Fabrication of Embedded Parts, Construction Methods Planning, Construction of ReEngineered Prestressed Concrete Dome

Bhagya S Nair

Co-founder InCoBAN Ecosystem

Director & VP Operations, Synergasia BE-NEX Private Limited

Ms. Bhagya has 15+ years of experience in construction project management in infrastructure, commercial, institutional, residential buildings etc. She has successfully driven change initiatives at organisational level like Integrated PM, Lean Construction, Project Digitalisation, Risk Management etc. She also volunteers with professional bodies and has mentors young and experienced professionals on project controls.

Education

  • 2022, Chevening Gurukul fellowship program on leadership and excellence from the University of Oxford, UK
  • 2021-2022, Advance Masters in Public Policy from Indian School of Business
  • 2008 – 2010, Master of Technology in Construction Technology & Management from Indian Institute of Technology, Madras
  • 2002 – 2006, Bachelor of Technology in Civil Engineering from College of Engineering, Trivandrum

Volunteering

  • Secretary – AACEI India Section, 2019 – 2022

Licenses & Certifications

  • Earned Value Professional from AACE International
  • Analyzing and Visualizing Data with Microsoft Power BI from Microsoft

Expertise

  • Integrated Project Management
  • Project Controls
  • Public Policy
  • Project Digitalisation
  • Earned Value Management
  • Planning & Scheduling

Professional Experience

  • Co-founder-InCoBAN, Director & VP Operations Synergasia BE-NEX Pvt. Ltd., 2023 – Present
  • AGM – Project Management, Real Estate Bangalore International Airport Ltd., 2020 – 2023
  • Project Control Lead, Karle Infra Pvt. Ltd., 2017 – 2019
  • Planning Manager, Larsen & Toubro, 2006 – 2017

Publications & Achievements

  • RICS South East Asia Best Project Management Team Award, Bengaluru Airport City Ltd., 2023
  • “BIM-Specific Prequalification Criteria in Construction Projects: Exploring the Nature and Timeline of Their Inclusion” – Journal of Legal Affairs and Dispute Resolution in Engineering and Construction
  • “Re-thinking Earned Value Management from a practitioners perspective” – Indian Lean Construction Conference – ILCC 2021
  • CII DX Award for Best Practices in Digital Transformation, Bengaluru Airport City Ltd., 2021
  • Poster presentation on “Risk Analysis & Contingency Determination Methods” at PMPC, 2017
  • Project Risk Management Team Award, L&T Construction, 2016
  • George Oomen Memorial Prize in 17th Indian Engineering Congress, 2013 – “An Application of Lean Construction Techniques to MEP Systems in Indian Building Construction Projects”