For decades, every manufacturing unit in India worked under the Factories Act, 1948. That law has now been replaced. The four new Labour Codes came into force on 21 November 2025, and factories are now governed by the Occupational Safety, Health and Working Conditions Code, 2020 (OSH Code).
The OSH Code combines 13 older labour laws into one. For factory owners, three changes matter most.
1. New worker thresholds for a "factory"
| Type of unit | Old Factories Act | New OSH Code |
|---|---|---|
| Manufacturing with power | 10 or more workers | 20 or more workers |
| Manufacturing without power | 20 or more workers | 40 or more workers |
Small units below these numbers are no longer "factories" under the law. But they are not free of compliance – they may still need registration under the OSH Code (see below), plus fire NOC, Pollution Control Board consent, local trade licence and other approvals.
2. One registration instead of many
Earlier, a unit could need separate registrations under the Factories Act, the Contract Labour Act, the Inter-State Migrant Workmen Act and others. Under the OSH Code:
- Every establishment employing 10 or more workers needs a single registration.
- A new establishment must register within 60 days of the Code applying to it.
- The Central Rules (notified on 8 May 2026) provide for online registration and deemed registration if a complete application is not processed within the time limit.
- A common licence covers a factory and engagement of contract labour.
3. Existing units: update, don't restart
If your unit is already registered or licensed under the old laws, you generally do not need to start from scratch. You need to update your existing registration with the details asked for under the OSH Code. However, many owners are not aware of this and are missing the deadline. Please check your status.
State rules still matter
Factories are a subject where state governments make their own rules. Each state is notifying its own OSH Rules, forms, fees and portals (for example, Rajasthan, Madhya Pradesh and Uttar Pradesh each have their own process). Until a state's rules and portal are fully in place, transitional provisions apply. That is why the exact procedure for your factory depends on where it is located.
What you will usually need
- Building plan / layout of the factory approved by the competent authority
- Stability certificate from a competent person
- Fire NOC from the state fire department
- Pollution Control Board consent (CTE/CTO)
- List of manufacturing processes, machinery and power load
- Maximum number of workers proposed
- Details of occupier and manager, and identity documents
- Proof of ownership or lease of premises
Safety obligations that come with registration
- Safe machinery guarding, ventilation, lighting and drinking water
- Free annual health check-up for workers of prescribed age
- Appointment letters for every worker
- Safety committee and safety officer above prescribed worker numbers
- Maintenance of registers and filing of returns, increasingly online
How ClearPath Compliance India can help
We check whether your unit falls under the new factory definition, get your building plans and stability certificate in order, file your OSH Code registration or licence on the state portal, migrate existing registrations, and set up the registers and returns you need to stay compliant.
This article is for general information. State rules under the OSH Code are still being notified and may change; please confirm the current position for your state before acting.