What the template contains
- Contractor identification block: legal name, registered address, PAN, GST number, contact person, and any existing licence number with its validity dates
- Applicability and threshold check: a short prompt to record the number of contract labour engaged and confirm whether a licence is required under the Code and the state's notified rule
- Contractor entity documents section: incorporation or partnership or proprietorship proof, PAN, GST registration, and authorised signatory proof
- Statutory registration proofs section: EPF registration, ESI registration, Professional Tax registration where the state levies it, Shops and Establishment registration for the firm's own office, and PSARA licence if the firm supplies security guards
- Principal employer documents section: certificate from the principal employer, principal employer registration or details, and a copy of the work order or contract
- Licence application section: the contractor licence application, particulars of the number of contract labour, and the nature and location of the work
- Fees and security deposit section: proof of licence fee payment and proof of the security deposit lodged
- Worker particulars and wage section: number of contract labour to be engaged, wage rates and wage period, and the wage payment mode (bank or electronic)
- Ongoing compliance and renewal section: work order intimation to the authority, registers and returns to be maintained, and the renewal reminder with the licence expiry date
- Tracking columns on every row: status (obtained or pending), file or link location, responsible person, date obtained, expiry date, and remarks
- Verification and sign-off block: name, designation, signature and date of the person who checked the file
How to use it
- Fill the contractor identification block at the top so the whole file is tagged to your firm and, where relevant, to the specific client engagement
- Complete the applicability and threshold check first: record how many contract labour you will engage and confirm against your state's notified rule whether a licence is required, since thresholds vary by state
- Work down each section and tick every document, noting where the original or scan is stored in the file or link column
- Prepare a separate set of principal employer documents for each client, because a separate licence is generally needed for each principal employer
- Before filing, verify the exact form numbers, licence fee and security deposit amount against your state's current notified rules, as these differ between states and are not universal
- Confirm the wage particulars and the bank or electronic payment mode are recorded, since the contractor stays responsible for paying wages
- Enter the licence expiry date and set a renewal reminder well ahead of the five-year validity so placements are never left uncovered
- Have the responsible person sign the verification block, then keep the completed checklist with the application and licence copy so it is ready for any inspection or client audit
Key fields and clauses
| Field or clause | What to put |
|---|---|
| Contractor licence requirement | Under Section 47 of the OSH Code a contractor must hold a valid licence before supplying or engaging contract labour or executing work through contract labour. |
| Applicability threshold | Section 45 sets out where the Part applies, with the Code stating fifty or more contract labour, but state notified thresholds vary and must be checked before you assume a number. |
| Contractor licence application | The application records the number of contract labour and the nature of the work; confirm the current form number against your state's notified rules before filing. |
| Certificate from the principal employer | The principal employer's certificate is required to support the contractor's licence application for that client; confirm the current form number against your state's notified rules. |
| Separate licence per principal employer | A contractor generally needs a distinct licence for each principal employer, so this checklist is run once per client engagement. |
| Number of contract labour and nature of work | The licence is tied to the number of workers specified; increasing that number needs an amendment to the licence. |
| Licence fee and security deposit | Proof of the fee paid and the security deposit lodged must be on file; amounts are set by the state's notified rules, so verify them and do not assume a figure. |
| Licence validity and renewal | A licence issued under Section 47 is valid for five years under Section 48, so track the expiry date and start renewal early. |
| Work order intimation | Section 50 requires the contractor to intimate each work order received from an establishment to the authority within the prescribed time. |
| No fee or commission from workers | Section 49 prohibits the contractor from charging any fee or commission, in whole or in part, from the contract labour. |
| Wage responsibility and principal employer backstop | Section 55 keeps the contractor responsible for paying wages, and if the contractor defaults the principal employer must pay and can recover from the contractor or the licence security deposit. |
| Statutory registration proofs | EPF, ESI, Professional Tax, Shops and Establishment, and PSARA (for security services) proofs sit alongside the licence file as the firm's standing registrations. |
Why this document matters
This checklist supports compliance with the contract labour provisions of the Occupational Safety, Health and Working Conditions Code, 2020 (the OSH Code), Chapter XI, Part I. The labour codes came into force on 21 November 2025 and the earlier Contract Labour (Regulation and Abolition) Act, 1970 has been subsumed into the OSH Code, so a staffing firm's contract labour licence is now governed by this Code. Section 47 requires a contractor to hold a valid licence before supplying or engaging contract labour, and Section 54 makes it a contravention for a principal employer to engage contract labour through a contractor who does not hold the required licence, which is why clients increasingly ask to see the licence file. Section 45 describes where the Part applies (the Code refers to fifty or more contract labour on any day in the preceding twelve months), though state notified rules and thresholds vary and must be checked. A licence under Section 47 is valid for five years (Section 48), the contractor may not charge any fee or commission from workers (Section 49), must intimate each work order to the authority (Section 50), and remains responsible for wages with the principal employer as a backstop (Section 55). Exact form numbers, fees, security deposit amounts and thresholds are set by each state's notified rules and must be confirmed against your state before filing; this document is a practical business checklist, not statutory interpretation.
Get the editable template
Download this format and the full staffing compliance kit. ZeniaHR generates and stores these documents for your whole deployed workforce automatically.
Get the templateCommon questions
Do I still need a contract labour licence now that the old Contract Labour Act is gone?
Yes. The Contract Labour (Regulation and Abolition) Act, 1970 has been subsumed into the OSH Code, 2020, and Section 47 of that Code requires a contractor to hold a valid licence before supplying or engaging contract labour. The requirement continues, it is now just located in the Code rather than the old Act. Confirm the current application form and process on your state's notified rules and portal.
Do I need one licence for my firm or one for each client?
A contractor generally needs a separate licence for each principal employer it supplies workers to, so most staffing firms complete this checklist once per client engagement rather than once for the whole business. Keep the principal employer's certificate and the work order for that client with each licence file, and verify the specific requirement against your state's notified rules.
How many workers trigger the licence requirement?
The OSH Code refers to fifty or more contract labour, and Section 45 describes where the Part applies, but state notified thresholds vary and the earlier Act used a lower figure of twenty. Treat any single number as a starting point only and confirm the exact threshold, fee and security deposit against your own state's notified rule before you decide you do or do not need a licence.