Section 05 · Compliance calendar
The obligations that arrive whether or not anyone is watching for them
Set out below is the recurring cycle for a Delhi establishment covered by the Employees' Provident Funds Act, the Employees' State Insurance Act and the Contract Labour (Regulation and Abolition) Act, and employing ten or more workers for POSH purposes. Dates are stated as customarily observed; where a due date falls on a holiday, confirm the portal position rather than assuming an extension.
Every month, without exception
Three obligations recur monthly and account for the majority of interest and damages levied on employers who are otherwise compliant. Provident fund contribution is remitted through the Electronic Challan cum Return on the Unified Portal by the fifteenth of the following month. Employees' State Insurance contribution is remitted by the fifteenth of the following month. Wages are to be paid within the period prescribed under the Payment of Wages Act, 1936 — before the expiry of the seventh day after the last day of the wage period where fewer than a thousand persons are employed, and the tenth day otherwise.
A fourth monthly discipline is not statutory but is, in our view, indispensable for principal employers: collect the contractor's EPF and ESI challans for the preceding month, together with the wage register extract, before releasing the contractor's invoice. An employer who releases payment first and collects challans later has, in effect, no leverage and no evidence.
| Obligation | Due | Channel | Authority |
|---|---|---|---|
| EPF contribution and ECR filing | 15th of following month | EPFO Unified Portal | EPF Act, 1952; EPF Scheme, 1952, para 38 |
| ESI contribution | 15th of following month | ESIC portal | ESI Act, 1948; ESI (General) Regulations, reg. 31 |
| Payment of wages for the wage period | 7th or 10th, by headcount | Bank transfer, wage register updated | Payment of Wages Act, 1936, s. 5 |
| Contractor challan and wage-register collection | Before releasing invoice | Vendor file | Practice; CLRA, 1970, s. 21 exposure |
| Muster roll and wage register posting | Continuous | Forms XVI and XVII at site | Central Rules, 1971, rr. 78 and 79 |
Month by month across the year
Monthly remittances are assumed and are not repeated below. What follows is the additional obligation that arises in each month.
- JanuaryCalendar-year close
The CLRA year closes on 31 December. Begin compiling the principal employer's annual return in Form XXV — contractor-wise workman numbers, man-days worked and wages paid. Ask each contractor for the data now rather than in the second week of February. Reconstitute any Internal Committee whose three-year term expires in the coming year.
- FebruaryForm XXV; POSH annual report
File the annual return in Form XXV with the Registering Officer, ordinarily by the fifteenth, and retain the acknowledgement. Submit the Internal Committee's annual report for the preceding calendar year to the District Officer under Section 21 of the POSH Act, 2013 — including where the report is nil. Delhi's revised variable dearness allowance ordinarily takes effect from 1 February and should be applied to wage sheets in this month, not at the following revision.
- MarchFinancial-year close
Close the financial year. Reconcile EPF and ESI contributions remitted against the wage register for all twelve months and resolve differences before the audit. Verify that bonus provision under the Payment of Bonus Act, 1965 has been computed on the allocable surplus. Confirm that gratuity provision reflects the current strength and salary.
- AprilNew year; ESI contribution period opens
The ESI contribution period April to September opens. Employees whose wages have crossed the ceiling continue to contribute until the end of the period in which the increase occurred. Review the leave-with-wages entitlement carried forward under Section 22 of the Delhi Shops and Establishments Act, 1954, and post opening balances in the leave register.
- MayFactory licence and register review
Where the establishment is a factory, review the licence particulars against actual installed horsepower and maximum workers, and initiate amendment where either has changed. Verify that statutory testing certificates for pressure vessels and lifting tackle are current. Review the health register where any hazardous process is carried on.
- JuneHalf-year planning
Open renewal files for every licence and registration expiring between July and December — sixty days ahead of expiry is the discipline we recommend. Confirm the named custodian for each registration number and reassign where the previous custodian has left. This month is also a sensible point to run the mid-year contractor reconciliation described in the licences section.
- JulyCLRA half-yearly return; POSH workshops
Contractors file the half-yearly return in Form XXIV for the period ending 30 June, ordinarily within thirty days. Principal employers should collect a copy for the vendor file. Schedule the first half of the year's POSH awareness programmes; sessions run before the monsoon shutdown periods tend to achieve better attendance on factory floors.
- AugustVDA revision; bonus computation
Delhi's second variable dearness allowance revision ordinarily takes effect from 1 August. Re-run wage sheets for all employees at or near the minimum, including every contract worker on site, and pay arrears from the effective date rather than from the date the notification reached payroll. Begin bonus computation for payment within the statutory period.
- SeptemberBonus payment; ESI period closes
Bonus under the Payment of Bonus Act, 1965 is payable within eight months of the close of the accounting year; for a year ending 31 March that period expires on 30 November, and paying in September ahead of the festive season is common practice. The ESI contribution period April to September closes at month end.
- OctoberFestive contract labour; ESI period opens
The month in which retail, warehousing and logistics establishments most often cross the contract-labour threshold without noticing. Count peak-day deployment against the licensed number on the contractor's Form VI and against the numbers stated in the Form I certificate, and amend before deployment rather than after. The October to March ESI contribution period opens.
- NovemberBonus deadline; register audit
Last month for bonus payment in respect of an accounting year ended 31 March. Conduct an internal audit of statutory registers ahead of the calendar-year close — the register of workmen in Form XIII against the gate register, the muster roll against attendance, the wage register against the current notified minimum for each skill category.
- DecemberYear close; renewals
Renew factory licences expiring at year end and any Shops and Establishments registration falling due. Close the CLRA year on 31 December and freeze contractor data for the Form XXV return. Confirm that the Internal Committee has met and that its minutes for the year are complete before the annual report is drawn up in February.
On the VDA revisions
Delhi revises the variable dearness allowance component of minimum wages twice each year, ordinarily with effect from 1 February and 1 August. Arrears run from the effective date of the notification, not from the date on which payroll became aware of it. Establishments that discover a revision in the third month owe three months of arrears to every affected worker, including those on a contractor's rolls.
References: EPF Scheme, 1952 (para 38); ESI (General) Regulations, 1950 (reg. 31); Payment of Wages Act, 1936 (s. 5); CLRA Central Rules, 1971 (rr. 82(1) and 82(2)); POSH Act, 2013 (s. 21) read with POSH Rules, 2013 (r. 14); Payment of Bonus Act, 1965 (s. 19); Minimum Wages Act, 1948 (s. 5) and the notifications issued thereunder by the Government of the NCT of Delhi. Due dates are stated as customarily observed and are subject to notification.
A calendar with no named custodian against each line is a document, not a control.
We maintain client calendars with the registration number, issuing office, expiry date and the person answerable for each obligation, and open renewal files sixty days ahead.