By Dr. Gyan Pathak
The Union Minister of Labour and Employment Dr Mansukh Mandaviya announced implementation of the four controversial labour codes on November 21, 2025, and the government said that the codes are made “effective”. Twelve days after, on December 3, 2025, he said while addressing CII IndiaEdge 2025 event in New Delhi that the Codes are likely to be fully operational from April, 2026.In between the times, the government has realized that it was easier said than done.
The country is not prepared to implement the codes right now which is creating numerous hurdles in the way of implementation, apart from stiff resistance from the Central Trade Unions and unwillingness of certain states to implement them without further consultations with them. As many as seven States and UTs are delaying it.
With the four labour codes — Code on Wages, 2019, Industrial Relations Code, 2020, Code on Social Security, 2020 and the Occupational Safety, Health and Working Conditions Code, 2020 – notified on November 21, 2025, the Union Ministry of Labour and Employment has begun the process for enforcing rules, and stumbling on every step.
To make “law on paper” into “law in practice” is obviously going to take months, even beyond the “transition window” from November 21, 2025 to April 1, 2026, presumed by the Centre, since full implementation would require finalisation of rules, making administrative machinery ready, compliance by employers, social security enrolments, inspection and enforcement mechanisms, workers acceptance, and convergence across states.
Dr Mansukh Mandaviya has said on December 3, 2025 that draft rules under the four labour codes will be pre-published shortly. He admitted that the they were pre-published long back, but now there was a need for bringing draft rules again in sync with present times.
A senior officer of the Union Ministry of Labour and Employment has been quoted saying that after pre-publishing the draft rules, the government will give 45 days time for public comments and feedbacks before firming up those for final notification.
As of now, few states and UTs have either formally refused to implement the new notified labour codes or have not completed necessary rule-framing which effectively stalls implementation. They have actually signalled non-implementation or delays, and that is what “not implementing” means in their case.
Kerala government has explicitly stated that it will not implement the central labour codes. The Minister of Labour of the state has said that they will not implement it before a further consultation with CTUs.
As per the Union Ministry of Labour and Employment data, West Bengal, Meghalaya, Nagaland, and Lakshadweep (UT) have not pre-published draft “rules” required under at least one of the four codes. Without these state-level rules, operationalising the codes in those states/UTs remains incomplete.
Until recently NCT of New Delhi has pre-published only the draft rules under the “Code on Wages, 2019”. The other codes (Industrial Relations; Social Security; OSH) either lack rules or are not fully notified.
As for Tamil Nadu, it has not yet pre-published draft rules under one of the four codes (the Code on Social Security, 2020), which means full implementation remains pending there.
Because labour is on the Concurrent List under India’s Constitution, both central and state governments need to notify implementing rules under the new Codes. States/UTs that don’t pre-publish draft rules, or refuse to implement, effectively block many provisions of the Codes from operating for workers/employers in that region.
Even if the Codes are “in force” at the Centre, state-level inaction means no forms, no procedures, no licences, possibly no enforcement — thereby creating uncertainty for workers whether the protections promised under the new Codes will apply locally.
Political differences, trade-union resistance, and concerns about worker rights (especially around layoffs, collective bargaining, gig-worker protections) have driven some states — especially Kerala — to outright reject the Codes.
Under these circumstances, between November 21, 2025 and April 1, 2026, only some parts of the codes will be functional. For making the codes fully functional government needs to take additional steps. The notification on November 21 only means that the previous system has been replaced by a unified framework in place of 29 old central labour laws. In theory, the new “codes” are now the law of the land. Government’s declaring it “effective” does not mean “everything works seamlessly from day one”.
Centre expects that preparation to fully operationalise the notified Labour Codes could be completed and the administrative and procedural machinery will be put in place in the next four months. They are trying to fully align the enforcement of the codes from the beginning of the fiscal year 2026-27, which will be better for compliance, payrolls, social security schemes, labour inspections, etc.
Nevertheless, the codes’ real impact will depend significantly on how each state implements them. Employers need time to revise their internal HR, payroll, contract-labour policies, working-hours & shift norms, compliance processes, social security enrolment, record-keeping, etc. The new codes change many definitions (who qualifies as “worker/employee”), working-hour norms, wage definitions, social security coverage, safety standards, etc. Employers also need to align with the new rules.
The Joint Platform of the 10 CTUs – INTUC, AITUC, HMS, CITU, AIUTUC, TUCC, SEWA, AICCTU, LPF and UTUC–have demanded rollback of the four labour codes and threatened to launch the fiercest and most United resistance in history. They held a nationwide protest on November 26 against unilateral implementation of the codes. Their numerous protests, marches, meetings, burning copies of the new codes in public etc shows their readiness to mobilize workers for stiff resistance of implementation of the codes. The CTUs have said they will escalate demonstrations if the government proceeds with full implementation.
The next few months will likely see intensified protests and union actions, especially as the government works to notify detailed rules and move toward full implementation from 1 April 2026. (IPA Service)
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