A contractor supplying labour to a site has five things to get right every month: wages paid electronically by the 7th and reported to the principal employer, the provident fund ECR filed and paid by the 15th, the ESI contribution paid within 15 days of month-end, the wage and attendance registers kept current, and the licence and security deposit kept valid. The principal employer should see evidence of each, because the Code makes the site liable for the first three when the contractor fails.
Everything below recurs on a monthly wage period, which is what almost every industrial deployment runs on. The table gives the instrument, the deadline and the piece of paper, or the screen, that proves it was done.
| Filing | Instrument | Deadline | What the principal employer should see |
|---|---|---|---|
| Wages paid | Code on Wages 2019, s.17(1); OSH Code 2020, s.55 [VERIFY: s.55 number from secondary sources] | Before the 7th of the following month, by bank transfer or electronic mode | Bank or electronic payment confirmation, plus the electronic intimation the contractor sends the site |
| Provident fund ECR and remittance | Code on Social Security 2020, s.16 [VERIFY]; EPF Scheme para 38 for the 15-day window [VERIFY] | By the 15th of the following month | ECR acknowledgement with the TRRN, and the paid challan |
| ESI contribution | Code on Social Security 2020, Chapter IV; ESI (Central) Rules 1950, r.51 [VERIFY: rule number] | Within 15 days of the last day of the calendar month (ESIC) | ESIC challan and the contribution history for the site's IP numbers |
| Registers and wage slips | OSH (Central) Rules 2026 [VERIFY: rule numbers for registers] | Continuous; wage slips issued electronically each wage period | Register extracts on request; a sample wage slip |
| Licence and security deposit | OSH Code 2020, s.47; OSH (Central) Rules 2026, rr.85–90 [VERIFY: rule numbers from secondary sources] | Licence valid five years; deposit held for its life | A copy of the licence and the deposit receipt, checked once and re-checked at renewal |
| State levies (Tamil Nadu) | Tamil Nadu Tax on Professions, Trades, Callings and Employments Act 1992; Tamil Nadu Labour Welfare Fund Act 1972 [VERIFY: both instruments and their periodicity] | Professional tax half-yearly; welfare fund annually [VERIFY] | Payment receipts at the half-year and year-end |
Wages: paid by the 7th, electronically, and reported
For a monthly wage period the employer must pay wages before the expiry of the seventh day of the succeeding month. That is section 17(1) of the Code on Wages 2019, and it sets the same deadline for a contractor paying contract labour as for a site paying its own rolls. The Code on Wages also allows the appropriate government to set a different limit for particular circumstances, so a state notification can move the date; none applies to ordinary industrial employment in Tamil Nadu that we are aware of [VERIFY: check the Tamil Nadu Code on Wages rules for any variation].
The OSH Code adds the method and the reporting. The contractor pays contract labour through bank transfer or another electronic mode, and informs the principal employer electronically of the amount paid. That intimation is the document the site should file each month, because if the contractor fails to pay, or pays short, the principal employer pays the wages in full and recovers the sum from the contractor afterwards. A site that never sees the intimation finds out about a short payment from the workers, which is the expensive way.
Provident fund: the ECR by the 15th
The contractor files an Electronic Challan cum Return on the EPFO unified portal and pays it by the 15th of the month following the wage month. The employee's share is 12% of basic wages plus dearness allowance, and the employer matches it at 12%, of which 8.33% goes to the pension scheme and the balance to the provident fund, with a further 0.5% for the deposit-linked insurance scheme [VERIFY: rates under the Code on Social Security 2020 and the schemes made under it; the EPFO primary could not be opened]. The pension component is calculated on wages capped at ₹15,000 a month, so the employer's pension contribution never exceeds ₹1,250 [VERIFY: statutory wage ceiling and cap].
Every worker on the ECR needs an Aadhaar-linked Universal Account Number, and a worker without one cannot be included in the return [VERIFY: current EPFO ECR validation rules]. The month a contractor deploys new workers is therefore the month the site should ask how many of them have a UAN on day one, because the gap between deployment and enrolment is the gap in which a contribution goes unpaid.
The principal employer is liable for provident fund contributions in respect of contract labour and may recover them from the contractor; the contractor may deduct only the employee's share from wages [VERIFY: section 17 of the Code on Social Security 2020, from secondary sources]. Late remittance attracts interest and damages, which under the repealed 1952 Act ran to 12% a year plus damages of up to 25% of the arrears [VERIFY: the equivalent provisions under the Code on Social Security 2020, ss.128 and 129, and current rates].
ESI: within 15 days of month-end
The contractor pays the ESI contribution to the Corporation within 15 days of the last day of the calendar month in which it fell due. The employee's contribution is 0.75% of wages and the employer's is 3.25%, both with effect from 1 July 2019, and an employee whose daily average wage is up to ₹176 is exempt from paying their own share while the employer still pays the employer's share. Those three figures come from the ESIC's own contribution page.
Coverage applies to employees earning up to ₹21,000 a month in gross wages, a ceiling set by the ESI (Central) Rules 1950 with effect from 1 January 2017 and unchanged since [VERIFY: rule 50 and the 2016 amendment notification]. Contributions run in two six-month contribution periods, April to September and October to March, each tied to a later benefit period; a worker who is enrolled late in a period loses benefit eligibility in the corresponding window, which is a cost that lands on the worker rather than on either employer.
Each contract worker needs an ESIC insurance number, and the contractor's monthly challan should reconcile to the headcount on the site's gate register. A challan that covers fewer people than walked through the gate is the single most common finding when a principal employer starts checking.
Registers, licence and the deposit
The OSH (Central) Rules 2026, notified on 8 May 2026, replaced the register regime of the 1970 Act and its Central Rules. A contractor keeps a wage register and an attendance record for the contract labour, issues wage slips electronically, and files the consolidated annual return through the Shram Suvidha portal [VERIFY: rule numbers, register forms and the annual return due date; the rules themselves could not be opened]. The registers are not monthly filings in the sense of a challan, but they are what an inspector-cum-facilitator asks for first, and a contractor who cannot produce a current wage register has usually not filed the ECR either.
The licence is a once-in-five-years filing with a monthly consequence. A contractor who employed 50 or more contract labour on any day in the preceding twelve months holds a single national licence, applied for electronically in Form XXI and treated as granted if no objection is raised within 45 days [VERIFY: rule 88, Form number and timeline from a secondary summary]. It carries a security deposit of ₹1,000 per contract labour [VERIFY: rule 90, from a secondary summary]. Engaging a contractor without the licence is the principal employer's contravention as well as the contractor's, so the site checks the licence once at engagement, records its expiry, and re-checks it at renewal.
What to ask for, and what it tells you
A monthly evidence pack from the contractor needs five items and fits in one email: the ECR acknowledgement with its TRRN and the paid challan, the ESIC challan, the bank payment proof and the electronic wage intimation, a current extract of the wage register, and, at engagement and renewal only, the licence and the deposit receipt. In our own engagements this is what the Management stage is built around, and it is the reason a contractor who resists sending it is a contractor whose obligations the site is about to inherit.
- ECR acknowledgement plus challan tells you the provident fund was filed and paid, and for how many workers.
- ESIC challan tells you the same for ESI; reconcile the headcount to the gate register.
- Wage intimation tells you wages went out on time and in full, before a worker has to tell you they did not.
- Wage register extract tells you the intimation matches the book, and that the register exists.
- Licence and deposit receipt tell you the contractor is one the Code lets you engage at all.
How far the site's liability runs when a contractor has filed some of these and not others, and what the recovery right is worth against a contractor who has closed, are questions for the reader's own counsel on the facts of the engagement.
Sources
- Employees' State Insurance Corporation, Contribution — rates of 0.75% and 3.25% w.e.f. 01.07.2019, the 15-day payment window, the ₹176 daily-wage exemption and the two contribution periods (page opened and read)
- Code on Wages, 2019 (Act 29 of 2019), s.16 and s.17(1) [VERIFY: section text confirmed from a secondary mirror]
- Occupational Safety, Health and Working Conditions Code, 2020 (Act 37 of 2020), ss.47 and 55 [VERIFY: section numbers from secondary sources; primary returned 403/404]
- Occupational Safety, Health and Working Conditions (Central) Rules, 2026, notified 8 May 2026, rr.85, 86, 88, 90 and the register and return provisions [VERIFY: rule numbers, Form XXI, the 45-day timeline and the ₹1,000 deposit are from a law-firm summary; the Gazette notification could not be opened]
- Code on Social Security, 2020 (Act 36 of 2020), ss.16, 17, 128, 129 and Chapter IV [VERIFY: section numbers from secondary sources]
- Employees' Provident Fund Scheme, para 38, and the statutory wage ceiling of ₹15,000 [VERIFY: the EPFO employer pages returned 404 after a domain move; figures from secondary sources]
- ESI (Central) Rules, 1950, r.50 as amended with effect from 1 January 2017 (wage ceiling ₹21,000) [VERIFY: amendment notification]
- Ministry of Labour and Employment, FAQs on the OSH Code, 2020 (January 2026), Q2 on the 50-worker licensing threshold