An electronics assembly plant in Tamil Nadu brought us in to supply part of its festive ramp alongside its existing contractor. Our onboarding checks include every contractor licence on the site, and the existing contractor's licence covered fewer contract labour than it already had at this one gate. The licence was amended in under a week, and the site changed how it plans a ramp. This is a representative composite; no single client is described.
The situation
The plant assembled consumer electronics on two shifts and ramped its contract crews every year from September for the festive season [VERIFY: composite]. Its existing contractor had held a licence for years, and the plant had a copy on file. Nobody had compared the number on it with the number of people coming through the gate, because the licence had been checked once, at engagement, and the crew had grown every season since.
The licence sets a ceiling, not a formality. Section 48(3) of the OSH Code 2020 makes a contractor's licence valid for five years "in respect of the number of contract labour specified therein", and requires a contractor that wants more to apply for an amendment and deposit the additional security. Rule 89(2)(ii) of the OSH (Central) Rules 2026 makes it a condition of every licence that the number of contract labour employed by the contractor "shall not, on any day, exceed the maximum number specified in the licence". That number counts the contractor's whole workforce, not one site's, so the gap was at least 45 and possibly larger.
What was at stake
The contractor's licence, and possibly the site's own position. A contractor that breaches a licence condition can have the licence suspended or revoked after a fifteen-day show-cause notice (OSH Code s.51; Central Rules r.95). Section 54 deems it a contravention of the Code where a principal employer engages contract labour through a contractor who needs a licence and has not obtained one.
What we did
- Told the site the same day, with the numbers. The licence maximum from the Shram Suvidha portal against the contractor's names on that day's gate register.
- The contractor applied to amend. An application in Form XXI on the Shram Suvidha portal, with the additional bank guarantee at ₹1,000 a worker for the increase (Central Rules r.90(1), r.96). The rules require an amended licence within seven days of a complete application, failing which it is deemed amended (r.96(5)); here it issued on the eighth day after the gap was found, because the application took a day to complete [VERIFY: composite].
- The ramp did not wait, and it did not run over the cap either. Until the amendment issued, the contractor held its crew at the licensed number and the rest of the ramp's positions were staffed from our own bench under our licence, which we had checked had room before we deployed anyone [VERIFY: composite].
- The work-order intimation was updated. Rule 93(5) requires the contractor to notify any change in the number of contract labour on the portal, and rule 94 requires the work order itself to be reported with its headcount.
What changed
| Measure | Before | After | Notes |
|---|---|---|---|
| Licence maximum in the contractor file | A copy, never compared with anything | The licensed number and expiry date on the contractor summary | For every contractor on site [VERIFY: composite] |
| Headcount against the licence | Not checked after engagement | Checked weekly during a ramp, monthly otherwise | Gate register against the licensed number |
| Ramp planning | Headcount agreed with the contractor by phone | Ramp plan includes the contractor's licence headroom across all its sites | Contractor confirms in writing [VERIFY: composite] |
| Work-order clause | None on the licence | Contractor must hold an amended licence before deploying above its licensed number | And must report its total deployed count on request |
| Renewal | Not diarised | Reminders at 90 and 30 days before expiry | Renewal application window under Central Rules r.91 |
The headroom question was the one that changed planning most. Because the licence counts a contractor's whole workforce, a contractor that is well inside its licence at this site can still be over it in total. The plant now asks each contractor, before a ramp, for its licensed number and its current total deployment, and builds the ramp around the gap.
The lesson carries to any site that ramps through a contractor. A licence checked once at engagement says nothing about the crew three seasons later, and the number on it is a ceiling the contractor carries everywhere it works. How a particular over-cap deployment affects a site is a question for that site's own counsel. This composite describes a method, not an outcome.
How Velura Services helps
Before we deploy anyone, we check our own licence has room for the crew across all our sites, and we look at every other contractor licence on the site against its gate count. When a site plans a ramp, we confirm our licensed headroom in writing and amend the licence before the extra crew arrives, not after.
Sources
- Figures are a representative composite drawn from our own deployments; no single client is described. Founder to confirm or replace before publish.
- Occupational Safety, Health and Working Conditions Code, 2020 (Act 37 of 2020), Gazette text hosted by DGFASLI. Sections cited: s.48(3) (licence valid for the number of contract labour specified; amendment and additional security to increase it), s.51 (revocation and suspension), s.54 (engaging contract labour through a contractor without a required licence). Opened and read.
- Occupational Safety, Health and Working Conditions (Central) Rules, 2026, G.S.R. 345(E) dated 8 May 2026, mirrored copy of the Gazette. Rules cited: r.89(2)(ii) (number not to exceed the licensed maximum on any day), r.90(1) (₹1,000 per contract labour), r.91 (renewal window), r.93(5) (change in number notified on the portal), r.94 (work-order intimation), r.95 (show-cause and suspension), r.96 (amendment in Form XXI; seven days or deemed amended; additional security). Opened and read [VERIFY: against the e-Gazette original].