India’s new labour codes, effective November 21, 2025, trigger immediate accounting changes for companies from the December quarter. ICAI advises recognizing higher gratuity liabilities and reworking compensation structures under the new wage definition. Leave entitlements ease, but supporting rules are pending—requiring prudent disclosures and interim adjustments in Q3 FY26 results.
India’s four consolidated labour codes—Wages, Social Security, Industrial Relations, and Occupational Safety—came into effect on November 21, 2025, modernizing 29 legacy laws and tightening wage definitions that directly impact cost structures and employee benefits. Employers must prepare for accounting adjustments even as detailed rules are awaited.
ICAI has advised companies to recognize the increase in gratuity liabilities and cost implications in interim financial statements for the December quarter (Q3 FY26). The wage definition now requires at least 50% of total remuneration to be counted as “wages,” which can enlarge benefit-linked bases and associated liabilities.
Operationally, paid annual leave thresholds drop from 240 to 180 days, expanding eligibility sooner and affecting provisioning. With rules pending notification, firms should prioritize transparent disclosures, sensitivity analyses, and compensation redesigns to stay compliant while managing earnings volatility.
Major takeaways and notable updates
Effective date: Labour codes implemented on Nov 21, 2025; detailed rules pending notification.
Accounting impact: Recognize higher gratuity liabilities and cost effects from the December quarter (Q3 FY26).
Wage definition: Minimum 50% of remuneration as “wages”—raises bases for benefits and liabilities.
Leave eligibility: Threshold reduced to 180 days, expanding paid annual leave sooner.
Action items: Update compensation structures, enhance disclosures, and assess tax and payroll implications.
Sources: Financial Express; TaxGuru; Aquilaw; ClearTax; Conventus Law