Which Registers Must a Staffing Firm Keep?

The governing provision

The OSH Code 2020, Chapter VIII is titled Maintenance of registers, records and returns, and section 33 (Maintenance of registers, records and filing of returns) places the duty on the employer to maintain registers and records and to file returns in such form and manner as may be prescribed. For contract labour and manpower supply this Code now governs: the labour codes came into force on 21 November 2025 and the Central Rules were notified on 8 May 2026, with the old Contract Labour (Regulation and Abolition) Act 1970 subsumed into the OSH Code (contract labour is governed by Chapter XI).

Why there is no single fixed list

The Code sets the obligation but leaves the actual content of each register, its columns and its form to the rules made by the appropriate government. So the specific register formats live in the notified rules, not in the Code text, and they can differ between the Central rules and each state's rules. Treat any named register or form as something to confirm against the rule that applies to your establishment rather than a universal set.

Records tied to your contractor licence

Under Chapter XI a manpower supply contractor operates under a licence and must keep the paperwork that supports it. Carried from the legacy forms into the rules: Form I is the principal employer's registration, Form IV the contractor's licence application, Form V the principal employer's certificate, and Form VI the licence itself, and a contractor needs a separate licence for each principal employer. Confirm the exact form numbers against your state's notified rules. The Code also requires: intimation of each work order to the designated authority (section 50); a wage-disbursement record, since wages must be paid by bank transfer or electronic mode and the amount paid intimated to the principal employer (section 55); and an experience certificate issued on demand to the contract labour (section 56).

Wage and social-security records you keep regardless

Separate from the OSH registers, a staffing firm keeps wage and contribution records under the other codes. Under the Code on Wages the employer fixes a wage period not exceeding one month (section 16) and pays within the section 17 time limits, which the wage records must evidence. For provident fund each worker has a portable Universal Account Number (UAN) and the employer files a monthly Electronic Challan cum Return (ECR) and deposits contributions; ESI is administered by ESIC. Keep these to the extent stated: the codes require the returns and contribution records, not extra steps beyond them.

The threshold and the exception

The contract-labour Part applies to an establishment with, or a manpower supply contractor employing, fifty or more contract labour on any day of the preceding twelve months (section 45(1)); it does not apply where the work is only of an intermittent or casual nature (section 45(2)), subject to the Code's own test for what is not intermittent. The fifty-worker figure is the threshold widely reported under the OSH Code, but thresholds are set by the Code and rules and state thresholds vary, so check the number notified for your state. Below the threshold a firm has lighter licence obligations but still keeps its wage, PF and ESI records.

What happens if you do not keep them

Non-maintenance is a specific offence. Section 96 of the OSH Code is the penalty for non-maintenance of registers and records and non-filing of returns, and section 98 punishes falsification of records. There is also the principal-employer backstop under Chapter XI: the principal employer must pay wages or benefits if the contractor fails and may recover the amount from the contractor, including from the licence security deposit (section 55). Your registers and records are what protect you in a wage or licence dispute.

Action step

Pull the register and return list from the rule that applies to your establishment (the Central rules or your state's rules), map each required register to who owns it and where it is stored, and reconcile it monthly against your licence, work-order intimations, wage records, ECR and ESI records. Where a form number, threshold or state levy is not settled here, verify it against your state's notified rule before you rely on it.

Last verified and disclaimer

Last verified: 20 September 2026. This page is general information for staffing and manpower firm owners, not legal advice, and is pending named legal review. Statutory positions are restated from the OSH Code 2020, the Code on Wages 2019 and the Code on Social Security 2020; state-specific register formats, form numbers and thresholds must be verified against the notified rule that applies to your establishment. Reviewer byline: pending named legal review.

Key points

• The duty to maintain registers, records and returns is set by section 33 of the OSH Code 2020 (Chapter VIII), in the form and manner prescribed by the appropriate government.
• The Code fixes the duty, not one universal list: the exact register formats, columns and forms live in the notified rules and vary between the Central rules and each state's rules.
• Contractor-licence paperwork carried from legacy into the rules: Form I, Form IV, Form V, Form VI (confirm numbers), a separate licence per principal employer, plus work-order intimation (s.50), a wage-disbursement record (s.55) and an experience certificate on demand (s.56).
• Keep wage records under the Code on Wages (wage period s.16, payment timelines s.17) and PF/ESI records (portable UAN, monthly ECR; ESI via ESIC) regardless of the contract-labour Part.
• The contract-labour Part applies at fifty or more contract labour (s.45) and not to purely intermittent or casual work; the threshold is set by the Code and rules and varies by state, so verify yours.
• Non-maintenance is penalised under s.96 and falsification under s.98; the principal-employer wage backstop (Chapter XI) makes your records your protection in a dispute.

Related questions

Check for your state

• Exact register and return formats, columns and form numbers are set by the notified rules and vary between the Central rules and each state's rules; not fixed in the Code and to be confirmed against the applicable rule.
• The contract-labour applicability threshold (widely reported as fifty workers under the OSH Code) is set by the Code and rules and varies by state; verify the number notified for your state.
• Whether the OSH Code consolidates the multiple legacy registers into a single combined register is determined by the rules and is not confirmed here.
• Professional Tax and Shops and Establishment registers, slabs, thresholds and forms vary by state; confirm against each state's law.
• Legacy form numbers (Form I, IV, V, VI) are carried into the rules but must be confirmed against the applicable notified Central or state rules.
• If the firm also supplies security guards, PSARA 2005 licensing applies additionally (separate licence per state); its record and licensing detail is out of scope of this page.