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Do Contract Staff Need Appointment Letters?

Answer: Yes. Since the labour codes came into force on 21 November 2025, issuing a written letter of appointment to every worker is a duty of the employer under the Occupational Safety, Health and Working Conditions Code, 2020, and contract staff are not exempt; the duty to issue it sits with the contractor, that is, the staffing firm, because in law the deployed worker is the contractor's worker, not the client's.

The rule, stated plainly

Yes, contract staff need a written letter of appointment. Since the labour codes came into force on 21 November 2025, issuing a letter of appointment to every worker is a duty of the employer under the Occupational Safety, Health and Working Conditions Code, 2020. There is no carve-out that lets a staffing or manpower firm skip the letter for the workers it deploys. The letter must be in writing and carry the worker's terms, in the form prescribed by the notified rules.

Who issues it: the contractor, not the client

For deployed staff, the employer who must issue the letter is the contractor, that is, your staffing firm. Under the Code on Social Security, 2020, contract labour is defined as a worker hired in or in connection with the work of an establishment by or through a contractor. In law the worker is the contractor's worker, so the appointment letter comes from you as the agency, not from the client where the worker is placed. The principal employer's contract-labour duties are different: providing welfare facilities on site, and stepping in to pay wages if the contractor defaults, recoverable from the contractor (OSH Code 2020, Chapter XI, Sections 53 and 55).

The exception that usually applies, and what it does not do

The exception owners reach for is that casual or intermittent engagements, or the fact that staff sit at a client site, remove the obligation. They do not. The intermittent or casual nature of work under Section 45(2) only affects whether the contract-labour Part of Chapter XI, including licensing, applies to the establishment; it does not switch off the general duty to give a worker their terms in writing. Likewise the 50-worker figure often quoted is the licensing threshold for the contract-labour Part, not a floor for the appointment letter. There is one genuine boundary, though: a worker who is regularly employed by the agency on mutually accepted standards of employment, including permanent engagement, periodical increments and social security coverage, is not treated as contract labour at all under the Code on Social Security, 2020 definition. Such a worker is your regular employee and gets a standard employee appointment letter.

What to put in the letter (action step)

Issue a written letter of appointment to every worker, your own office staff and your deployed staff alike, and keep a signed copy on record. Make it reflect the real terms: the wage components as defined in the Code on Wages, 2019; the wage period, which cannot exceed one month (Section 16); the payment timeline for that wage period (Section 17); and the worker's social security identifiers and coverage (EPF Universal Account Number and the monthly ECR, and ESI where the wage ceiling applies). Name the correct employer, which is your firm, and the place of deployment. The exact form and particulars are set by the notified Central and State rules, so confirm the template against your state's notified rule before you standardise it.

Related obligations to line up

The appointment letter sits alongside the rest of your contract-labour compliance: a contractor licence where the Chapter XI Part applies, with a separate licence for each principal employer and a licence valid for five years for the number of workers specified (OSH Code 2020, Sections 47 and 48); and an experience certificate to be issued on demand when a worker leaves (Section 56). Confirm the exact licensing threshold, the form numbers and any state additions, such as Professional Tax, Shops and Establishment registration and PSARA for a security agency, against your state's notified rules.

Sources, last verified and disclaimer

Last verified: 20 September 2026. This is general information for staffing and manpower firm owners in India, not legal advice, and is pending named legal review. Forms, thresholds and particulars vary by state and by the notified Central and State rules under the labour codes; confirm against your state's notified rule and the enacted Code text before acting. Reviewer byline: pending named legal review.

Key points

Related questions

Does the client company (principal employer) have to give our deployed staff an appointment letter?

Generally no. The contract worker is legally the contractor's worker, hired by or through the contractor, so the staffing firm issues the appointment letter. The principal employer's contract-labour duties are welfare facilities on site and a wage backstop if the contractor fails to pay, recoverable from the contractor (OSH Code 2020, Chapter XI). If the client actually directs and controls the worker as its own, that can be treated as direct employment, which is a separate risk to manage.

We have fewer than 50 contract workers. Do we still have to issue appointment letters?

Yes. The 50-worker figure is the threshold for the contract-labour licensing Part of the OSH Code, not a floor for the duty to give a worker their appointment terms in writing. Confirm the exact licensing threshold against your state's notified rule, since state thresholds vary and the number should not be assumed.

Is a verbal offer or an email enough?

No. The requirement is a written letter of appointment in the prescribed form, carrying the worker's terms. Keep a signed copy on record, and separately issue an experience certificate on demand when the worker leaves (OSH Code 2020, Chapter XI, Section 56).

Check for your state

Sources. Occupational Safety, Health and Working Conditions Code, 2020, employer-duties provision (Section 6, duties of employers): duty to issue a letter of appointment to every employee. Exact clause and prescribed form to be confirmed against the enacted Code and the notified rules.; Occupational Safety, Health and Working Conditions Code, 2020, Chapter XI (Contract Labour): Section 45 (applicability, including the intermittent or casual exception in 45(2)), Sections 47 and 48 (licensing of contractors, validity and separate licence per principal employer), Section 53 (principal employer welfare facilities), Section 55 (responsibility for payment of wages and principal-employer backstop), Section 56 (experience certificate on demand).; Code on Social Security, 2020, Section 2: definition of contract labour (clause 18, including the regular-employee carve-out) and definition of contractor (clause 19).; Code on Wages, 2019: definition of wages; Section 16 (wage period, not exceeding one month); Section 17 (time limit for payment of wages by wage period).; Ministry of Labour and Employment, Government of India: labour codes brought into force on 21 November 2025; Central Rules notified on 8 May 2026; CLRA 1970 subsumed into the OSH Code 2020.. Restated in our own words from the official text; nothing is copied. labour.gov.in, indiacode.nic.in.
This page is general information, not legal or tax advice. India's labour codes, the Central Rules 2026 and tax rules change and vary by state; confirm the current position on the relevant official portal (labour.gov.in, epfindia.gov.in, esic.gov.in, incometax.gov.in) or with a professional before you act.
Author: ZeniaHR Editorial Team. Last verified against official sources: 20 September 2026.

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