Compliance

How to audit your contractor each month

Reconcile four records against your gate register: wage intimation, Form XI, the PF ECR and the ESIC challan. What each mismatch usually means.

A hand holding a magnifying glass over a printed ledger form on a wooden table, the heading enlarged in the lens.

A monthly contractor audit is four comparisons, made in order against your own gate register: the wage intimation, the contractor's Form XI, the PF Electronic Challan-cum-Return (ECR), and the ESIC challan. Every document arrives between the 7th and the 15th of the following month. A site that runs the checks before filing its own Form XII on the 20th finds a missing worker in the month it happens, not at inspection.

The monthly calendar the audit follows

The deadlines are set by the rules, so the audit can follow a fixed calendar. For a calendar-month wage period:

ByWhat arrives or is dueInstrument
7thWages paid by bank transfer; the contractor's payment intimation to the siteOSH Central r.98(2), (4), (6)
10thForm XI from the contractor: name, UAN, wages and contributions for each contract workerEPF Scheme 2026, para 27(3)
15thPF ECR filed and paid; joiners and leavers uploaded on the EPFO portalEPF Scheme 2026, paras 24(2), 28(3)
15thESI contribution paid for the monthESIC contribution rules (within 15 days of month-end)
20thThe site's Form XII: total deducted from contract workers and total employer contributionEPF Scheme 2026, para 27(4)
Day 22If wages were not paid by the 7th, the site must have paid them (15 days after the missed payday)OSH Central r.98(8)

Every six months the contractor also files a half-yearly return in Form XVIII within 30 days of the half-year's end (r.98(7)). It is a useful cross-check on the headcount the monthly records add up to.

Four reconciliations, in order

Start from the record the site controls, the gate or attendance register, and work outward. Each step compares one document with the one before it, so a gap shows up at the step where it first appears.

CompareWhat should matchA mismatch usually means
1. Gate register → wage intimationSame people, and days worked consistent with days paidWorkers on the floor but off the payroll; days under-recorded; a sub-contractor's crew paid by someone else
2. Wage intimation → Form XISame names; wages in Form XI consistent with wages paidPF calculated on basic rather than Code wages; workers paid but left out of the PF return
3. Form XI → PF ECRSame UANs, wages and contribution amountsA worker without an Aadhaar-seeded UAN dropped from the ECR; a contractor reporting to the site one set of figures and to EPFO another
4. Wage list → ESIC challanEvery worker on Code wages up to ₹21,000 a month coveredNew joiners not yet registered; ESI worked out on the wrong wage; workers wrongly treated as above the ceiling

Most mismatches are small and have a reason the contractor can show in writing: a joiner registered on the 14th, a leaver whose last wages fell in the next period. The ones that matter repeat month after month, or follow a pattern such as the same names missing each time, PF on a wage that never changes, or an ESIC count well below the payroll.

What to check on the wage line

Check that PF and ESI are worked out on Code wages, not on a basic figure. Under the Code on Wages 2019, s.2(y), allowances above half of total pay count back into wages, and the Code on Social Security uses the same definition (s.2(88)). A contractor that splits pay into a low basic and large allowances, then remits PF on the basic alone, produces an ECR that reconciles neatly to Form XI and still underpays. Sample three or four workers a month and recompute their Code wages from the payslip.

Check the rate against the notified minimum for your industry, zone and skill category too. Tamil Nadu resets the dearness allowance every April, and a payroll that was correct in March can be short from April.

When the records do not match

Ask for a written explanation, and hold the bill only where the contract allows it. The law already gives the site its levers. It can recover PF it pays for a contractor's workers from the contractor's bill or as a debt (Code on Social Security s.17(1)), and the same for ESI (s.31(6)). It can require the contractor's register before settling an account (s.31(7)). If wages are unpaid, the site pays them within fifteen days and recovers from the bill or the security deposit (r.98(8)).

  1. Write it down. Record the month, the documents compared and the gap, by name or UAN.
  2. Ask the contractor to explain or correct before the next bill, with the corrected ECR or challan as proof.
  3. Use the contract. Apply the set-off or hold the contract provides for, and no more.
  4. Escalate a repeat. Two months with the same gap is a pattern, and a reason to review the engagement.

Whether a particular gap creates liability for the site, and how much, depends on the facts and the contract terms, and is a question for the site's own counsel.

How Velura Services helps

We send each site its evidence pack on the statutory calendar: payment intimation by the 7th, Form XI by the 10th, the ECR and ESIC challans by the 15th. We reconcile them to your gate register before you see them, and flag any gap by name with the reason and the fix. That leaves your Form XII on the 20th a check rather than a chase.

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Sources

Frequently asked questions

What documents should a principal employer collect from a contractor each month?

The wage payment intimation, Form XI with each worker's name, UAN, wages and contributions, the PF ECR and challan, and the ESIC challan. Form XI is due by the 10th under the EPF Scheme 2026, and PF and ESI are paid by the 15th. The site files its own Form XII by the 20th. Compare all of them against the site's gate register.

How do I check that a contractor is paying PF for all workers?

Compare your gate register with the contractor's wage intimation, then the wage list with Form XI, then Form XI with the PF ECR. Every person who worked should appear in each, with the same UAN and consistent wages. A worker on the floor but missing from the ECR, or PF calculated on a basic far below Code wages, is the usual gap.

What happens if the contractor's records don't match?

Ask for a written explanation and corrected filings. The Code on Social Security lets the site recover PF and ESI it pays from the contractor's bill or as a debt, and require the contractor's register before settling an account. If wages are unpaid, rule 98(8) of the OSH Central Rules requires the site to pay within fifteen days and recover the amount.

Why reconcile against the gate register and not just the contractor's documents?

Because a contractor's own documents can agree with each other and still leave people out. Only the site's register shows who actually worked. Starting the audit there catches workers who were on the floor but off the payroll, a sub-contractor's crew, or under-recorded days, which the contractor's records alone would never reveal.