Labour Codes in 2027: a compliance checklist for warehouses and fulfilment centres

Is your fulfilment centre a factory?

Most D2C teams would say no.

They store, pick, pack and ship. Nothing is made there.

The OSH Code reads it differently. Its definition of a manufacturing process includes packing any article "with a view to its use, sale, transport, delivery or disposal".

Checked against official sources on 28 October 2026.

My short answer: the four Labour Codes have been in force since 21 November 2025, and the State rules that make them work are arriving one State at a time. For 2027, a warehouse should first decide whether it is an establishment or a factory. Then it should give everyone an appointment letter, seasonal staff included, settle its contract-labour position for the festive peak and note the dates in its own State rules. In Rajasthan, one of those dates is a health-check deadline of 30 April 2027.

Our own factory is in Jaipur, so the Rajasthan rules below are the ones we work under too. We read them as an employer, with our own floor in mind.

I am a manufacturer, not a labour lawyer. Please treat this as a checklist to take to your HR adviser, not as legal advice.

What is in force, and what is still with the States?

1. The Code on Wages, the Industrial Relations Code, the Code on Social Security and the Occupational Safety, Health and Working Conditions (OSH) Code came into force together on 21 November 2025. They replace 29 central labour laws (PIB, 21 November 2025).
2. Existing rules and schemes continue during the transition, until new rules are in place.
3. The central rules under the four Codes were reported as notified on 8 May 2026 (KPMG flash news). They apply where the Centre is the appropriate government. Most private warehouses follow their State rules.
4. States are notifying their own rules. Rajasthan published its OSH rules on 30 June 2026.

So the honest answer to "what applies to us" has three parts.

It is the Code, plus your State rules, plus any older rules your State still keeps during the transition.

Is your warehouse an establishment or a factory?

The OSH Code has two tests, and many warehouses meet the first without ever asking about the second. The definitions are in section 2 of the OSH Code as published in the Gazette of India (29 September 2020).

1. An establishment is a place where any trade or business is carried on with 10 or more workers. Most D2C warehouses are at least this.
2. A factory is premises with 20 or more workers where a manufacturing process runs with the aid of power, or 40 or more without power.

Three details decide the factory question for a fulfilment centre:

1. The Code counts packing as a manufacturing process. It lists printing processes too.
2. Workers are counted on any day of the preceding twelve months, and all workers in different groups and relays on a day are added together. Two shifts of 12 people make 24.
3. Where a State law in force before the Code set a different number, the State number applies until that State changes its law.

Put together, this is how we read it. A fulfilment centre with sealing machines, conveyors or label printers, and 20 or more people across shifts on its busiest day, may well be a factory in law. One festive season can put you over the line for a whole year.

I am not saying every warehouse is a factory.

I am saying the question deserves a written answer from someone who knows your State rules.

The checklist

Points A to H come from the PIB backgrounder on the OSH Code (22 November 2025) unless I say otherwise.

A. Registration and licence

1. One electronic registration for an establishment with 10 or more workers. It replaces six separate registrations.
2. A factory licence if you meet the factory test above. The threshold rose from 10 to 20 workers with power, and from 20 to 40 without.
3. One return instead of many, and far fewer registers to keep.

B. Appointment letters

1. Every employee gets an appointment letter in the prescribed format, with designation, category, wages and social security details.
2. That includes fixed-term and seasonal staff. In Rajasthan, Rule 29 says no one may be employed without one.

C. Contract labour

1. A contractor needs a licence only with 50 or more contract workers. The old threshold was 20.
2. Contract labour is allowed even in core activities in three cases. One of them is a sudden increase in volume that has to be done in a set time, which describes a festive peak.
3. The principal employer must give contract workers health, safety and welfare facilities, and must pay their wages if the contractor does not.

Point 3 is the one that hurts later. We suggest collecting proof of wage payment from every contractor each month, before anyone has a reason to dispute it.

D. Hours, overtime and leave

1. No more than 8 hours a day and 48 hours a week. With the consent of the worker, the week can run as four 12-hour days, five 9.5-hour days or six 8-hour days.
2. Overtime only with consent, and paid at twice the normal wage rate. The State fixes the overtime limit.
3. Paid annual leave once a worker has worked 180 days in the calendar year. It used to be 240.

E. Night shifts and women workers

1. Women may work in all establishments and in all types of work, with safeguards.
2. They may work before 6 am and after 7 pm with their consent. The employer must arrange safety, facilities and transport.

For a festive night shift, I would write down the consent, the transport arrangement and the supervisor on duty before the first night, not after it.

F. Health check-ups

1. Every employee is entitled to a free annual health check-up. The rules set the age and frequency.
2. In Rajasthan, Rule 28 makes this concrete for factories: a free medical examination every year for each employee who has completed 40 years of age, within 120 days from the start of the calendar year. For 2027 that window closes on 30 April. The ESIC facility may be used.

G. Welfare and safety

1. A creche, separate or shared, where an establishment has more than 50 workers. It now covers the children of all workers, men included.
2. A safety committee in a factory with 500 or more workers.

H. If something is missed

1. A first offence punishable only with a fine can be settled by paying 50% of the maximum fine. Where imprisonment is also possible, it is 75%.
2. For several offences that are now civil, the employer gets a 30-day notice to comply before any legal action.

That is no excuse to be late.

But a missed register is a fixable problem, if you find it first. We would rather find our own gaps than have an inspector find them.

The Rajasthan example

Rajasthan notified its Occupational Safety, Health and Working Conditions Rules, 2026 on 30 June 2026 (Rajasthan Gazette, S.O. 23, copy hosted by SGCMS). Two rules matter to every Rajasthan factory in 2027:

1. Rule 28: the yearly medical examination for employees aged 40 and above, on Form-12, within 120 days from 1 January. For 2027, that is 1 January to 30 April.
2. Rule 29: no one employed without an appointment letter. Existing employees without one had three months from the rules coming into force, which ran to about the end of September 2026.

If you are in another State, look for the same two things in its rules: a dated health check, and an appointment-letter deadline. In my view they are the easiest to miss and the easiest for an inspector to check.

What to do before 30 April 2027

If I ran a fulfilment centre, I would start with step 1 this week. It takes an hour, and every other step depends on it.

1. November 2026: count your workers on your busiest day of the last twelve months, contract staff and both shifts included. Write the number down with the date.
2. December 2026: get a written opinion on your factory status under your State rules.
3. January 2027: check that every employee, including festive hires still with you, has an appointment letter in the prescribed format.
4. January to April 2027: in Rajasthan, finish the medical examinations for factory workers aged 40 and above by 30 April. Book the clinic or ESIC dates in January, before March year-end work takes over the office.
5. By June 2027: plan the festive team with contractor licences, night-shift consent and transport decided in advance (see the festive peak 2027 capacity plan).

Your team will also handle customer data on the same floor. That is a separate law with its own 2027 date, covered in customer data on shipping labels and packing slips.

This is general information, not legal advice. Labour rules differ by State and change as States notify them, so please confirm each point with a labour-law professional.

If your State has published a rule that changes this checklist, tell us through the contact page. We will add it to this guide.