Factory Act Compliance: Registers, Returns and Inspections
Factory act compliance begins where your licence ends: now come registers, working hours, overtime, health check-ups, safety committees, returns and licence renewal. Since 21 November 2025 this runs under the OSH Code, 2020, with the old factory rules continuing until each state notifies its own. We handle it for manufacturing units in Haryana and across India.
What it is
Factory act compliance is the set of duties an occupier and manager carry every working day. It covers hours of work, weekly offs, overtime wages, annual leave, health and safety arrangements, welfare facilities, statutory registers and periodic returns to the labour department.
For decades this came from the Factories Act, 1948. From 21 November 2025, the Occupational Safety, Health and Working Conditions Code, 2020 (OSH Code) replaced it along with 12 other laws. During the transition, the existing rules, forms and notifications continue in force until the state’s own OSH rules are final. Haryana published draft rules in May 2026, so Haryana factories still follow the Punjab Factory Rules framework for most paperwork, alongside the Code. Need a licence first? See our factory licence service.
Who it applies to
Power-driven units with 20 or more workers
Under the OSH Code, a factory is premises with 20 or more workers where manufacturing uses power, counting any day in the preceding twelve months.
Units without power with 40 or more workers
Where the process runs without power, the threshold is 40 workers, on the same twelve-month test.
Occupiers and factory managers
The occupier, usually a director or partner, and the named manager answer personally for compliance and inspection notices.
Why it matters
Workers stay safe
Health check-ups, safety committees and capped hours prevent injuries. The paperwork proves those systems run.
The occupier stays protected
After an accident, the first question is whether the factory followed the rules. Records are the occupier’s main defence.
Buyers and lenders check it
Export buyers, large customers and banks often audit labour compliance before placing orders or renewing limits. A clean file shortens those audits. Contractor workers matter here too, so keep your contract labour licence papers in the same folder.
Documents required
Licence and approvals
- Factory licence and approved building plan
- Fire safety certificate, where applicable
- Pollution control consents, where applicable
- Login for hrylabour.gov.in
Workforce data
- Worker list with age, gender, joining date and wages
- Shift timings, attendance and overtime records
- Contractor details and contract worker lists
Health and safety
- Health check-up reports
- Accident and dangerous occurrence records
- Safety committee minutes and training records
Key OSH Code duties for factories
| Area | Rule under the OSH Code, 2020 |
|---|---|
| Daily hours | No worker more than 8 hours a day (Section 25), with weekly limits and rest intervals |
| Overtime | Paid at twice the ordinary rate of wages (Section 27), with the worker’s consent |
| Annual leave | One day for every 20 days worked, once the worker has 180 days in the year (Section 32) |
| Canteen | Where 100 or more workers are employed (Section 24) |
| Creche | Where 50 or more workers are employed (Section 24) |
| Welfare officer | Where 250 or more workers are employed (Section 24) |
| Safety committee | Factories with 500 or more workers, or 250 or more where a hazardous process runs (Section 22) |
| Health check-up | Free annual health check-up for workers above 40 years |
| Women at night | Allowed in all types of work with consent and required safeguards |
Each of these needs a record behind it. Take an auto-parts unit in Faridabad’s industrial sectors that grows from 90 to 110 workers after a new order. Once it employs 100, a canteen becomes a legal duty, not a perk.
How it works
Find the gaps first
We review your factory act compliance status: licence, plan approval, headcount, shifts, registers and welfare facilities, on site or remotely. You get a gap list ranked by risk.
Set up registers and notices
We set up registers for workers, attendance, overtime, leave and accidents, kept electronically where the rules allow, along with the notices that must be displayed.
File returns and renewals
We prepare and file the annual and half-yearly factory returns on the state portal (Form 21 and Form 22 under the Punjab Factory Rules as applied in Haryana) and track licence renewal.
Coordinate health and safety records
We schedule health check-ups through your empanelled doctor, keep safety committee minutes and track training. Medical and technical work is done by qualified practitioners and safety professionals.
Support inspections and notices
When the inspector-cum-facilitator visits or issues a notice, we prepare the records and draft your response within the time given.
Timelines
Daily and monthly
Attendance and overtime entries every day. Wages before the 7th of the next month under Section 17 of the Code on Wages, 2019, with PF and ESI through your payroll compliance cycle.
Half-yearly and yearly
Half-yearly and annual factory returns under the state rules. Health check-ups for workers above 40 once a year.
Licence period
In Haryana, a factory licence is issued for one or five years. Renewal is filed online on hrylabour.gov.in before expiry.
What happens if you skip it
General penalty of ₹2 lakh to ₹3 lakh
Section 94 of the OSH Code sets a penalty of not less than ₹2 lakh and up to ₹3 lakh for a contravention where no other penalty is specified.
₹2,000 a day if it continues
If the contravention continues after conviction, a further penalty of up to ₹2,000 a day can be imposed.
Personal exposure for the occupier
Accidents involving death or serious injury carry separate, heavier provisions. Without records, the occupier has little to show that the rules were followed.
Frequently asked questions
Is the Factories Act, 1948 still in force?
No, the OSH Code, 2020 replaced it from 21 November 2025, together with 12 other labour laws. During the transition, rules, forms and notifications made under the old Act continue until the state notifies its own OSH rules. Haryana issued draft rules in May 2026 and had not finalised them at our last check. So you follow the Code’s substance and the old paperwork for now.
Our unit has 15 workers with power. Are we still a factory?
Under the OSH Code, probably not. The threshold rose from 10 to 20 workers where power is used, and from 20 to 40 without power, counted over the preceding twelve months. A unit with 15 workers still has duties under the Labour Codes and the shops law. Here is the catch: a single day with 20 workers in the past twelve months brings you in.
How many hours can a factory worker work?
Not more than 8 hours in a day under Section 25 of the OSH Code, within weekly limits and with rest intervals. Work beyond that is overtime, needs the worker’s consent and is paid at twice the ordinary wage rate under Section 27. Keep an overtime register that matches payroll, so the wage paid can be traced to the hours logged.
Do we have to give free health check-ups?
Yes. The Labour Codes require employers to provide a free annual health check-up to workers above 40 years. Section 6 of the OSH Code makes health examination an employer duty, as prescribed by the appropriate government. Hazardous processes need closer medical surveillance. Book the check-ups with a qualified medical practitioner and keep the reports on file.
Which factory returns do we file in Haryana?
Haryana factories file an annual return in Form 21 and a half-yearly return in Form 22, under the Punjab Factory Rules as applied in Haryana. These continue during the OSH Code transition. The Labour Codes provide for a single return, which will take over once Haryana’s OSH rules are final. We file the current forms and move you to the new one when it starts.
When is a safety committee required?
Under Section 22 of the OSH Code, a factory with 500 or more workers must have a safety committee, or 250 or more if it runs a hazardous process. The committee has equal employer and worker representation and meets regularly. Keep minutes and action points from each meeting. A working committee also warns you early.
Can women work night shifts in our factory?
Yes. Under the OSH Code, women can work at night and in all types of work, subject to their consent and the safety measures the government prescribes, such as transport and security arrangements. Record the written consent and the measures you put in place. Keep both on file for the inspector.
What is the penalty for not complying?
Section 94 of the OSH Code sets a general penalty of ₹2 lakh to ₹3 lakh where no specific penalty is provided, plus up to ₹2,000 a day if the contravention continues after conviction. Accidents causing death or serious injury attract separate provisions. Paperwork gaps are the easiest lapses to fix before an inspection.
Do you also handle the technical safety work?
No. We handle the legal side: registers, returns, renewals, notices and coordination. Structural stability, machinery testing, medical examinations and safety audits are done by qualified engineers, doctors and safety professionals whom you appoint. We keep their reports organised so the full file is ready when the inspector asks.
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.
In Haryana, the labour portal calculates the licence and renewal fee automatically.
Ready to begin?
Share your factory licence and headcount, and we will tell you which registers, returns and safety records your unit needs today.