Contract Labour (CLRA) Compliance: Registers, Returns and Renewals
Contract labour compliance starts after registration and licence. From then on, the principal employer and every contractor keep registers, check wage payments, file half-yearly and annual returns and renew on time. We run that calendar for you under the OSH Code, 2020 and the rules your state still applies.
What it is
Contract labour compliance is the year-round work that follows registration. The principal employer, the business where the work is done, and the contractor who supplies the workers each have records to keep, payments to check and returns to file.
For decades this sat in the Contract Labour (Regulation and Abolition) Act, 1970 and its rules. Since 21 November 2025, the Occupational Safety, Health and Working Conditions Code, 2020 has replaced the CLRA Act. The OSH (Central) Rules, 2026 were notified on 8 May 2026 by G.S.R. 345(E), while Haryana’s own rules under the Code were still in draft at the end of July 2026. Until they are final, the older state forms and portal continue.
This page covers the ongoing compliance. If you still need the principal employer registration or the contractor licence, start with our contract labour licence service.
Who it applies to
You use workers through contractors
Factories, offices, hospitals, warehouses and sites that use workers through contractors and are registered for contract labour. You file the annual return and stand behind the contractor on wages and amenities.
You supply workers under a licence
Manpower, housekeeping, security, loading and maintenance contractors holding a licence. You keep the registers, pay wages on time and file the half-yearly return.
Your headcount hovers near 50
Under the OSH Code, the contract labour chapter applies at 50 or more contract workers on any day in the past 12 months. Think of a Faridabad forging unit that adds loaders every Diwali season. One busy day can pull it in.
Why it matters
Unpaid wages become your bill
The contractor pays wages. If it fails, the principal employer must pay and recover the amount from the contractor. Under the Central Rules, that payment is due within 15 days.
Amenities fall back on you
Drinking water, latrines, first aid and, at 100 or more workers, a canteen. If the contractor does not provide them, the principal employer must.
Inspections start with records
An inspector asks for the registers and returns first. Clean records keep the visit short, and strong contract labour compliance starts there.
Documents required
From the principal employer
- Registration certificate and list of contractors
- Work orders and contract values
- Records of wage payment checks
From each contractor
- Licence and its validity date
- Register of workers, attendance and wages
- Wage slips and bank transfer proof
- PF and ESI challans and returns for the workers
For the returns
- Number of workers by month
- Days worked, wages paid and deductions
- Amenities provided and any accidents
How it works
List every contractor and licence
We list each contractor with licence number, expiry date, headcount and work order, so your contract labour compliance calendar has one source.
Put one register format in place
Section 33 of the OSH Code requires registers of workers, attendance, wages and leave, kept electronically or otherwise. Here is the catch: three contractors usually means three formats. We give them one that feeds the returns directly.
Check wages before paying the contractor
Before you release the contractor’s bill, we match wages, PF and ESI challans against attendance. Say a housekeeping agency bills for 60 workers but the challan shows 45: you find out now, not at an inspection. This ties into your payroll compliance work.
File half-yearly and annual returns
We prepare the contractor’s half-yearly return and the principal employer’s annual return in the form your state uses, and file them on time.
Renew and report changes
We diarise licence renewals and report changes in ownership, management or closure within 30 days.
Returns: old rules vs new rules
| Return | CLRA Central Rules, 1971 | OSH (Central) Rules, 2026 |
|---|---|---|
| Contractor’s return | Form XXIV, half-yearly, within 30 days of the half-year’s close | Form XVIII, half-yearly, within 30 days of the half-year’s close |
| Principal employer’s / establishment’s annual return | Form XXV, by 15 February after the year ends | Form XVII, by the last day of February |
| Registers | Separate CLRA registers | Form XIII (employees), XIV (attendance), XV (wages); electronic wage slips in Form XVI |
| Contractor licence | Renewable licence | Five-year licence (Forms XXI and XXII) |
Which column applies depends on who the “appropriate government” is. The Central Rules cover establishments under the Central Government. For a private unit in Haryana, the state’s rules govern, and those were still in draft in July 2026. In practice, a Faridabad unit keeps filing on the Haryana Labour Department portal, where contractor licences are renewed every year, and switches forms once Haryana’s final rules arrive.
Timelines
Half-yearly contractor return
Under the 1971 Central Rules, Form XXIV reaches the licensing officer within 30 days of the close of each half-year.
Annual principal employer return
Form XXV by 15 February under the 1971 Central Rules; Form XVII by the last day of February under the 2026 Central Rules.
Report changes within 30 days
Under Section 3 of the OSH Code, changes in ownership, management or registered particulars are reported within 30 days.
What happens if you miss it
Prosecution under the old Act
For contraventions while it applied, Section 23 of the CLRA Act allowed imprisonment up to three months or a fine up to ₹1,000, or both.
Wage claims land on you
Unpaid contract workers can claim from the principal employer, who then has to recover from the contractor.
Licence trouble for contractors
A contractor whose licence lapses cannot lawfully supply workers, and your work stops with it.
Frequently asked questions
Is the CLRA Act still in force in 2026?
No. The Occupational Safety, Health and Working Conditions Code, 2020 replaced it on 21 November 2025. The Central Government notified its OSH (Central) Rules, 2026 on 8 May 2026, but states such as Haryana were still working on their own rules in July 2026. During the transition, existing rules and forms continue where new ones are not yet in place. Your duties carry on; only the forms change.
Who files the annual return, the contractor or the principal employer?
The principal employer files the annual return; the contractor files the half-yearly return. Under the 1971 Central Rules these were Form XXV by 15 February and Form XXIV within 30 days of each half-year’s end. Under the 2026 Central Rules, the annual return is Form XVII by the last day of February and the contractor’s half-yearly return is Form XVIII, within 30 days of each half-year’s close. We prepare both from one set of records.
How many contract workers bring us under the OSH Code?
Fifty. The contract labour chapter of the OSH Code applies to establishments, and contractors, employing 50 or more contract workers on any day in the past 12 months. The CLRA Act used 20. The count is the peak on any single day, not an average. If your numbers sit near 50 during peak season, we track them monthly so you know exactly where you stand.
What happens if the contractor does not pay wages?
The principal employer must pay the workers and can recover the amount from the contractor, by deduction from bills or as a debt. Under the 2026 Central Rules, the principal employer pays within 15 days of the default and can use the contractor’s security deposit. So check wage proof every month before you release the contractor’s bill.
Which registers must be kept for contract workers?
Registers of workers, attendance and wages, plus wage slips. Section 33 of the OSH Code allows these to be kept electronically. Under the 2026 Central Rules they are Form XIII (employees), Form XIV (attendance) and Form XV (wages), with electronic wage slips in Form XVI. The contractor usually maintains them for its workers. We give a single format that serves the registers and the returns together.
How often is a contractor licence renewed?
It depends on the rules that apply. On the Haryana Labour Department portal, contractor licences are renewed every year. Under the OSH Code and the 2026 Central Rules, a licence can run for five years, and a work-specific licence is tied to one contract. Until Haryana’s final rules arrive, plan for annual renewal. We diarise each expiry date and start the renewal well before it.
Do contract workers need PF and ESI?
Yes, where the contractor’s establishment is covered, contract workers get PF and ESI like direct employees. The contractor deducts and deposits the contributions by the 15th of the following month. If it does not, the principal employer can be asked to pay. So ask for challans and ECR copies with each bill. It takes minutes a month.
Which amenities must be provided to contract workers?
Drinking water, latrines, washing facilities, first aid and, where 100 or more workers are employed, a canteen. Rest rooms are needed where workers halt at night. The contractor provides them first; if it fails, the principal employer must and may recover the cost. Many principal employers open their existing facilities to contract workers. Walk the site each quarter to check.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
On the Haryana portal, the licence fee is worked out automatically from the number of workers and can be paid online or by treasury challan.
Ready to begin?
Send us your contractor list and licence dates, and we will build your contract labour calendar for the year.