The Government of Maharashtra has recently issued an important clarification regarding registration requirements under the OSH Code 2020 and the Maharashtra Shops and Establishments Act 2017. 

This clarification aims to remove confusion and reduce duplication in compliance for businesses.

What has changed?

Single Registration for Establishments with 10 or more Employees

If your establishment employs 10 or more employees, you are required to register under the OSH Code (once fully implemented).

No separate registration under the Maharashtra Shops Act is required.

This is because the OSH Code is a central law that already covers registration related to labour welfare, safety, and working conditions.

Why this change?

The principle is straightforward:

• The OSH Code is a central legislation
• It overrides conflicting state provisions
• It provides a uniform system of registration across India

This removes duplication and simplifies compliance for employers.

Important: Shop Act still applies

While registration under the Shops Act is not required for establishments covered under the OSH Code:

• Other provisions of the Shops Act continue to apply
• This includes working hours, leave rules, and employee welfare provisions

So compliance continues, but the requirement of registration is removed.

What about small establishments?

If your business has less than 10 employees:

• OSH registration is not required
• However, you must give intimation of commencement under the Shops Act

Quick Summary

Employees Requirement
Less than 10 Shop Act intimation
10 or more OSH registration only
After OSH registration No Shop Act registration needed

Practical takeaway for businesses

This clarification is a welcome move towards ease of doing business:

• It eliminates duplicate registrations
• It reduces compliance burden
• It promotes a unified labour law framework

However, businesses must remember that compliance obligations remain. Only the registration process has been simplified.

Final Thought

As labour laws continue to evolve in India, such clarifications help businesses reduce ambiguity and focus on efficient compliance. Employers should align their processes accordingly and stay updated as the OSH Code rules are fully implemented.