Contract Labour Compliance in India: Licensing, Payment Rules & Penalties

1. What is Contract Labour?

Contract labour is a system of employment where workers are hired by a contractor to perform work at an establishment belonging to the principal employer. Unlike regular employees who are directly employed by the establishment, contract workers have a tripartite relationship involving the worker, the contractor (who is their direct employer), and the principal employer (who benefits from their work).

India has an estimated 50+ million contract workers spread across manufacturing, construction, IT services, facility management, security, logistics, and other industries. The practice of engaging contract labour is widespread because it allows businesses to scale their workforce up or down based on demand, access specialised skills for specific projects, and reduce the administrative burden of direct employment.

The primary legislation governing contract labour in India is the Contract Labour (Regulation and Abolition) Act, 1970 (CLRA Act). This Act was enacted to regulate the working conditions of contract labour and to provide for its abolition in certain circumstances. The Act imposes obligations on both the principal employer and the contractor.

Key Definition: Contract Labour A worker is classified as contract labour when they are hired in connection with the work of an establishment by or through a contractor, with or without the knowledge of the principal employer. The distinguishing factor is the intermediary role of the contractor between the worker and the principal employer.

The Tripartite Relationship

• Principal Employer: The owner or occupier of the establishment where contract labour is employed. This includes factories, mines, plantations, commercial establishments, and government departments.
• Contractor: A person who undertakes to produce a given result for the establishment through contract labour. The contractor directly employs the workers and is responsible for their wages and working conditions.
• Contract Worker: The person employed by the contractor to work at the principal employer’s establishment. They do not have a direct employment relationship with the principal employer.

2. CLRA Act 1970: Applicability & Threshold

The Contract Labour (Regulation and Abolition) Act, 1970 applies to two categories of entities: establishments that employ contract workers through contractors, and the contractors who supply these workers.

Applicability Criteria

• Establishment threshold: The CLRA Act applies to every establishment that employs or has employed 20 or more contract workers on any day during the preceding 12 months.
• Contractor threshold: The Act also applies to every contractor who employs or has employed 20 or more contract workers on any day during the preceding 12 months.
• Continued applicability: Once an establishment or contractor is covered under the Act, it continues to remain covered even if the number of contract workers subsequently falls below 20. This is a critical point that many employers overlook.
• Government establishments: The Act applies to government departments, public sector undertakings, and private sector establishments equally.

Labour Codes 2025 Update: Threshold Change Under the new Occupational Safety, Health and Working Conditions Code, 2020 (expected implementation from 2025), the threshold for applicability has been increased from 20 to 50 workers for both principal employers and contractors. This means smaller establishments employing between 20 and 49 contract workers will be exempted from the formal licensing requirements. However, basic wage and welfare protections will continue to apply.

Industries Heavily Dependent on Contract Labour

The following industries in India rely significantly on contract labour and must pay special attention to CLRA compliance:

• Manufacturing and assembly plants
• Construction and infrastructure projects
• IT and ITES companies (housekeeping, security, pantry services)
• Facility management and property maintenance
• Mining and quarrying operations
• Plantation and agriculture
• Logistics, warehousing, and supply chain
• Hospitals and healthcare support services
• Hotels and hospitality (housekeeping, kitchen staff)
• Government departments and PSUs

3. Dual Compliance: Registration vs Licensing

The CLRA Act establishes a dual compliance structure where both the principal employer and the contractor have independent obligations. Understanding the difference between registration (for principal employers) and licensing (for contractors) is fundamental to compliance.

Aspect	Principal Employer (Registration)	Contractor (Licensing)
Application Form	Form I	Form IV
Certificate Issued	Form II (Registration Certificate)	Form III (License)
Applied To	Registering Officer (Deputy Labour Commissioner)	Licensing Officer (Assistant Labour Commissioner)
Prerequisite	None	Form V from Principal Employer (mandatory)
Security Deposit	Not applicable	Rs 30 per worker (Rs 5 for cooperative societies)
Validity	Remains valid unless revoked	Usually 1 year; must be renewed
Scope	Covers the entire establishment	Separate license for EACH principal employer
Penalty for Non-Compliance	Fine up to Rs 25,000 (Sec 23)	Fine up to Rs 25,000 (Sec 23)

Important: Independent Obligations Non-compliance by one party does not absolve the other. If a contractor operates without a license, the principal employer can still be penalised for failing to verify the contractor’s license before engagement. Similarly, a contractor cannot claim exemption because the principal employer lacks registration. Both must comply independently.

4. Principal Employer Registration Process

Every principal employer who employs or intends to employ contract labour through a contractor must obtain registration under Section 7 of the CLRA Act. The registration process involves submitting Form I to the Registering Officer of the area.

Step-by-Step Registration Process

1. Prepare Form I Application: Fill in the prescribed Form I with complete details of the establishment, including name, address, nature of industry, and the type of business or trade carried on.
2. Provide Contract Labour Details: Mention the maximum number of contract workers to be employed on any day, the nature of work to be performed by contract labour, and details of all contractors engaged or to be engaged.
3. Calculate and Pay Registration Fee: The registration fee is based on the maximum number of contract workers. Pay the prescribed fee along with the application.
4. Submit to Registering Officer: The application must be submitted in triplicate to the Registering Officer (typically the Deputy Labour Commissioner) of the area where the establishment is located.
5. Receive Form II Certificate: Upon approval, the Registering Officer issues the Registration Certificate in Form II. This certificate must be prominently displayed at the establishment.

Documents Required for Registration (Form I)

• Completed application in Form I (triplicate)
• Establishment name, address, and nature of industry
• Maximum number of contract workers to be employed
• Details of all contractors engaged
• Nature of work performed by contract labour
• Registration fee (varies by state and number of workers)
• Proof of establishment (trade license, GST registration, etc.)
• PAN and address proof of the principal employer

Form V: Certificate to Contractor

One of the most important obligations of the principal employer is to issue Form V to each contractor engaged. This form certifies that the contractor has been engaged by the principal employer and is a mandatory prerequisite for the contractor to obtain their license. Without Form V, a contractor’s license application will be rejected outright.

5. Contractor Licensing Process

Every contractor who employs or intends to employ contract workers in connection with the work of an establishment must obtain a license under Section 12 of the CLRA Act. The licensing process is more detailed than registration and involves multiple requirements.

Step-by-Step Licensing Process

• Obtain Form V from Principal Employer: Before applying for a license, the contractor must first obtain Form V (Certificate of Principal Employer) from each principal employer they intend to supply workers to. This is a non-negotiable prerequisite.
• Prepare Form IV Application: Complete the application in Form IV with details of the contract, nature of work, maximum number of workers, and duration of the contract.
• Calculate Security Deposit: Deposit the security amount of Rs 30 per worker (or Rs 5 per worker if the contractor is a cooperative society). This deposit is refundable when the license is cancelled or not renewed.
• Pay License Fee: Pay the prescribed license fee based on the number of contract workers (see fee structure table below).
• Submit to Licensing Officer: Submit the application to the Licensing Officer (typically the Assistant Labour Commissioner) along with all supporting documents, security deposit receipt, and Form V.
• Receive Form III License: Upon approval, the Licensing Officer issues the License in Form III. This license specifies the principal employer, nature of work, maximum workers allowed, and validity period.

Critical Rule: Separate License for Each Principal Employer A contractor must obtain a separate license for each principal employer they supply workers to. For example, if a security services contractor supplies guards to three different factories, they need three separate licenses. Each license application requires a separate Form V from the respective principal employer and a separate security deposit.

License Renewal

Contractor licenses are typically valid for one year (the period may vary by state). Contractors must apply for renewal at least 30 days before the expiry date. Failure to renew on time means operating without a valid license, which attracts penalties under Section 23 of the CLRA Act.

6. License Fee Structure

The license fee payable by contractors under the CLRA Act is based on the number of contract workers. The fee structure is as follows:

Number of Contract Workers	License Fee (Rs)
Up to 20 workers	Rs 15
21 to 50 workers	Rs 30
51 to 100 workers	Rs 60
101 to 200 workers	Rs 90
201 to 400 workers	Rs 150
401 and above	Rs 225

In addition to the license fee, contractors must also pay a security deposit of Rs 30 per worker (Rs 5 per worker for cooperative societies). Some states may have slightly different fee structures, so it is advisable to check with the local Labour Department for the exact fees applicable in your state.

7. Payment Rules & Wage Compliance

Wage payment to contract workers is one of the most tightly regulated aspects of contract labour compliance. The CLRA Act and the new Labour Codes impose strict rules to ensure contract workers receive timely and fair compensation.

Key Wage Payment Rules

1. Payment Timeline: Under the Labour Codes 2025, wages must be paid on or before the 7th of the month following the wage period. For example, wages for June must be paid by July 7th.
2. Direct Payment to Workers: Wages must be paid directly to the contract workers, not through any intermediary or middleman. This prevents wage skimming by layers of sub-contractors.
3. Principal Employer’s Liability: If the contractor fails to pay wages within the prescribed period, the PRINCIPAL EMPLOYER is liable to pay the wages directly to the contract workers. The principal employer can then recover the amount from the contractor.
4. Wage Slips: Every contract worker must be issued a wage slip containing details of wages earned, deductions made, and net amount paid. This is a mandatory requirement under both the CLRA Act and the new Labour Codes.
5. Mode of Payment: Payment should preferably be made through bank transfer. Cash payments must be made in the presence of an authorised representative of the principal employer and must be properly recorded.
6. Minimum Wages: Contract workers are entitled to minimum wages as notified by the respective state government. The contractor cannot pay less than the applicable minimum wage rate for the skill category and zone.

Principal Employer’s Payment Obligation Section 21 of the CLRA Act places a direct and non-delegable obligation on the principal employer. If the contractor fails to pay wages, the principal employer must step in and pay the workers within the prescribed time. The principal employer can later recover this amount from the contractor’s bills or security deposit. This provision exists to protect contract workers from exploitation and ensure they are not left without wages due to a contractor’s default.

Deductions from Wages

The following deductions can be made from contract workers’ wages, provided they comply with the Payment of Wages Act:

• Provident Fund (PF) contribution (employee’s share)
• Employee State Insurance (ESI) contribution
• Income tax (TDS) where applicable
• Fines imposed in accordance with the standing orders
• Deductions for absence from duty
• Advances or loans given to the worker (with proper documentation)
• Court-ordered deductions (maintenance, debt recovery, etc.)

Note: Total deductions from wages (excluding PF and ESI) must not exceed 50% of the gross wages. Unauthorised deductions are a serious offence under the Payment of Wages Act.

8. Mandatory Welfare Facilities

The CLRA Act mandates the provision of certain welfare facilities for contract workers at the worksite. While the primary responsibility for providing these facilities lies with the contractor, the principal employer must ensure they are provided and step in if the contractor fails to do so.

Welfare Facility	When Required	Key Requirements
Canteen	100+ workers at a site	Subsidised food, hygienic conditions, adequate seating
Rest Rooms	Night shifts (before 6 AM / after 7 PM)	Separate rooms for men and women, adequate bedding
Drinking Water	All worksites (mandatory)	Clean, wholesome drinking water at convenient locations
Latrines & Urinals	All worksites (mandatory)	Separate facilities for men and women, properly maintained
First Aid	All worksites (mandatory)	First aid boxes at accessible locations, trained first aider
Creche	50+ women workers (Labour Codes)	Safe space for children, trained attendant, washing facilities

Principal Employer’s Fall-Back Responsibility: If the contractor fails to provide any of the mandatory welfare facilities within the prescribed time, the principal employer must provide them directly. The cost can be recovered from the contractor’s bills or security deposit. Under no circumstances can the absence of welfare facilities be excused because the contractor did not arrange them.

9. Records & Registers to Maintain

Proper record-keeping is a cornerstone of CLRA compliance. Both the contractor and the principal employer are required to maintain specific registers and records. Non-maintenance of these records is a punishable offence and also makes it difficult to defend against claims in labour disputes.

Registers the Contractor Must Maintain

Form Number	Register Name	Key Details Recorded
Form XII	Register of Workers (Muster Roll)	Worker name, father’s name, age, address, date of employment, nature of work, wage rate
Form XIII	Register of Wages	Wages earned, deductions, net amount paid, date of payment, worker’s signature/thumb impression
Form XIV	Deductions Register	Nature of deduction, amount, authority for deduction, worker acknowledgement
Form XV	Overtime Register	Overtime hours worked, overtime rate, amount paid, date of payment
Form XVI	Register of Fines	Nature of offence, amount of fine, date imposed, how fine amount utilised
Form XVII	Register of Advances	Advance amount, purpose, instalments for recovery, balance outstanding

Employment Cards

Every contractor must issue an employment card to each contract worker within 3 days of employment. The employment card must contain the worker’s name, photograph, nature of employment, wage rate, and the name and address of both the contractor and the principal employer.

Principal Employer’s Records

• Form XII-A: Register of contractors, containing details of each contractor engaged, their license number, contract period, number of workers, and nature of work.
• Form XXV: Annual return that must be submitted to the Registering Officer by February 15 each year. This return covers the preceding calendar year and includes details of all contractors engaged, contract workers employed, and wages paid.

Record Retention Period All registers and records under the CLRA Act must be preserved for a minimum period of 3 years from the date of the last entry. During this period, these records must be available for inspection by the Labour Inspector at any time during working hours.

10. Penalties for Non-Compliance

The CLRA Act imposes significant penalties for various types of non-compliance. These penalties can include fines, imprisonment, or both. The new Labour Codes have further increased the quantum of penalties, especially for repeat offenders.

Penalty Structure Under CLRA Act

Violation	Section	Penalty
Principal employer operating without registration	Sec 23	Fine up to Rs 25,000
Contractor operating without license	Sec 23	Fine up to Rs 25,000
Contravention of any CLRA provision	Sec 24	Up to 3 months imprisonment + fine up to Rs 1,000
Repeat offence (second or subsequent conviction)	Sec 25	Up to 6 months imprisonment + fine up to Rs 2,000
Obstruction of Labour Inspector	Sec 26	Up to 3 months imprisonment + fine up to Rs 500
Non-compliance under Labour Codes (first offence)	Labour Codes	Fine up to Rs 2 lakh
Non-compliance under Labour Codes (repeat offence)	Labour Codes	Fine up to Rs 4.8 lakh

Warning: Personal Liability Under Sections 24 and 25 of the CLRA Act, the person responsible for the management of the establishment (such as the managing director, partner, or proprietor) can be held personally liable for violations. This means penalties including imprisonment can be imposed on individuals, not just the company. Ignorance of the law or delegation of responsibility to subordinates is not a valid defence.

11. Labour Codes 2025: What Changed for Contract Labour

The new Labour Codes (consolidating 29 existing labour laws into 4 codes) bring significant changes to the regulation of contract labour. While the exact implementation timeline varies by state, businesses should prepare for these changes now.

Key Changes Under the New Labour Codes

1. Threshold Increased from 20 to 50 Workers: The applicability threshold for both principal employers and contractors has been raised from 20 to 50 workers. Establishments with fewer than 50 contract workers will be exempt from the formal registration and licensing requirements.
2. Contract Labour in Core Activities Prohibited: The Labour Codes explicitly prohibit the use of contract labour for ‘core activities’ of the establishment. Only ‘non-core’ activities can be outsourced to contract workers. This is a major change that will impact many industries.
3. Core vs Non-Core Activities Defined: ‘Core activity’ is defined as any activity for which the establishment is set up, including regular services such as security or housekeeping that are ordinarily part of the establishment’s routine work. ‘Non-core’ activities are those that are not essential to the primary business objective.
4. Single Registration for Multiple Locations: Principal employers can now obtain a single registration that covers multiple establishments within the same state. This significantly reduces the administrative burden for companies operating at multiple locations.
5. Digital Compliance and E-Filing: All registrations, license applications, returns, and compliance filings must be done digitally through the government’s online portal. Physical filing will be phased out, making compliance faster and more transparent.
6. Wage Payment Timeline: Wages must be paid within 7 days of the end of the wage period (typically by the 7th of the following month). This is stricter than the previous provisions under some state rules.
7. Enhanced Penalties: The maximum penalty for non-compliance has been significantly increased, with repeat offenders facing fines up to Rs 4.8 lakh. The focus has shifted from imprisonment to monetary penalties for most violations.

Impact on Businesses: What You Should Do Now 1. Audit your current contract labour arrangements to identify workers engaged in ‘core activities’ 2. Plan the transition of core-activity contract workers to direct employment or find alternative compliance structures 3. Update your digital systems for e-filing of registrations, licenses, and returns 4. Review and renegotiate contractor agreements to reflect the new legal requirements 5. Train your HR team on the new compliance framework

12. Common Compliance Failures & How to Avoid Them

Based on inspection reports and labour tribunal cases, the following are the most frequently observed compliance failures. Understanding these common pitfalls can help both principal employers and contractors stay on the right side of the law.

Failure 1: Not Verifying Contractor’s License Validity

Many principal employers engage contractors without checking whether the contractor holds a valid, current license under the CLRA Act. Some contractors operate on expired licenses, and the principal employer bears joint liability for this oversight.

How to Avoid: Maintain a tracker of all contractors’ license expiry dates. Request a copy of the license (Form III) before engagement and set up reminders for renewal dates. Do not release payments to contractors with expired licenses.

Failure 2: Not Issuing Form V to Contractors

Principal employers sometimes fail to issue Form V (Certificate of Principal Employer) to their contractors. Without this form, the contractor cannot legally obtain or renew their license.

How to Avoid: Make Form V issuance a standard part of your contractor onboarding process. Issue it before the contractor begins deploying workers at your establishment.

Failure 3: Wages Paid in Cash Without Records

Cash payments without proper documentation (wage slips, muster rolls, payment registers) are a recipe for disputes and penalties. Inspectors frequently flag this during site visits.

How to Avoid: Mandate bank transfers for all wage payments. If cash payment is unavoidable, ensure it is made in the presence of an authorised representative and properly documented in the wage register (Form XIII).

Failure 4: Missing Welfare Facilities at Worksite

Inspectors commonly find worksites lacking basic welfare facilities such as clean drinking water, separate latrines for men and women, or first aid boxes. These are non-negotiable requirements regardless of the number of workers.

How to Avoid: Conduct monthly welfare audits at all worksites. Include welfare facility compliance as a key performance indicator in contractor agreements.

Failure 5: Not Filing Annual Return (Form XXV)

The annual return in Form XXV must be filed by February 15 each year. Many principal employers forget or delay this filing, leading to penalties and increased scrutiny from labour authorities.

How to Avoid: Set up automated reminders in your compliance calendar. Collect the required data from contractors throughout the year rather than scrambling at the last minute.

Failure 6: Using Contract Labour for Core Activities

Engaging contract workers for permanent, core activities of the establishment (such as production line work in a factory or patient care in a hospital) can lead to abolition orders and the deemed absorption of contract workers as regular employees.

How to Avoid: Clearly define and document which activities are ‘core’ and which are ‘non-core’ in your establishment. Restrict contract labour to genuinely non-core functions such as housekeeping, security, and facility maintenance.

Failure 7: No Employment Cards Issued to Workers

Contractors frequently fail to issue employment cards to their workers. This makes it difficult to identify and track contract workers, and is a specific violation under the CLRA rules.

How to Avoid: Include employment card issuance as a contractual obligation. Verify during site inspections that every contract worker carries a valid employment card with photograph and essential details.

13. Simplify Contract Labour Compliance with SalaryBox

Managing contract labour compliance involves tracking multiple registrations, licenses, payment deadlines, welfare obligations, and filing requirements across numerous contractors and worksites. Manual tracking through spreadsheets and paper registers is error-prone and time-consuming.

How SalaryBox Helps with Contract Labour Management Automated Attendance & Payroll: Track contract worker attendance digitally and process payroll accurately with minimum wage compliance built in. No more manual muster rolls. Bank Transfer Payments: Pay contract workers directly through bank transfers with auto-generated wage slips. Maintain a complete digital trail for every payment. Compliance Dashboard: Track PF, ESI, and TDS deductions for contract workers. Generate compliant pay slips and maintain digital records that satisfy inspector requirements. Contractor Management: Maintain separate payroll batches for different contractors. Track license expiry dates, worker counts, and payment schedules in one place. Digital Records: Replace paper-based Form XII, XIII, XIV, and XV registers with digital records that are searchable, exportable, and always ready for inspection.

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14. Frequently Asked Questions (FAQ)

Below are answers to the most common questions about contract labour compliance, the CLRA Act, and the impact of the Labour Codes 2025.

Q: What is contract labour in India?

A: Contract labour refers to workers who are employed by a contractor to perform work at an establishment belonging to the principal employer. These workers do not have a direct employment relationship with the establishment where they work. Instead, they are hired through an intermediary (the contractor) who is responsible for their wages, attendance, and working conditions. India has over 50 million contract workers across manufacturing, construction, IT services, security, housekeeping, and other sectors.

Q: Who is a principal employer under the CLRA Act?

A: A principal employer is the owner or occupier of the establishment where contract labour is employed. In a factory, it is the owner or occupier as defined under the Factories Act. In a mine, it is the owner or agent as defined under the Mines Act. In other establishments, it is any person responsible for the supervision and control of the establishment. In government departments, the head of the department is the principal employer. The principal employer has statutory obligations including obtaining registration, issuing Form V to contractors, ensuring welfare facilities, and paying wages if the contractor defaults.

Q: How do I obtain CLRA registration as a principal employer?

A: To obtain registration, submit an application in Form I (in triplicate) to the Registering Officer (typically the Deputy Labour Commissioner) of your area. Include details such as establishment name and address, nature of industry, maximum number of contract workers, details of all contractors, and nature of work performed by contract labour. Pay the prescribed registration fee. Upon approval, you will receive the Registration Certificate in Form II, which must be displayed at the establishment.

Q: What is the difference between Form I and Form IV under the CLRA Act?

A: Form I is the application for registration submitted by the principal employer to the Registering Officer. It covers the entire establishment and details how many contract workers will be employed. Form IV is the application for a license submitted by the contractor to the Licensing Officer. The contractor needs a separate Form IV for each principal employer. Additionally, Form IV requires Form V (Certificate from the Principal Employer) as a mandatory attachment, a security deposit of Rs 30 per worker, and the prescribed license fee.

Q: What happens if the contractor fails to pay wages to contract workers?

A: Under Section 21 of the CLRA Act, if the contractor fails to pay wages to contract workers within the prescribed time, the principal employer is legally obligated to pay the wages directly to the workers. The principal employer can then recover the amount from the contractor’s pending bills, security deposit, or through legal proceedings. This provision ensures that contract workers are never left without wages due to a contractor’s default. Under the Labour Codes 2025, wages must be paid within 7 days of the end of the wage period.

Q: Can contract labour be used for core activities of an establishment?

A: Under the existing CLRA Act, there is no explicit prohibition, but the appropriate government can abolish contract labour in any process or operation through a notification after considering factors like the nature of work and worker conditions. Under the new Labour Codes 2025, contract labour in core activities is explicitly prohibited. ‘Core activity’ includes any activity for which the establishment is set up, as well as regular services like security and housekeeping that are part of routine operations. Only non-core and ancillary activities can be outsourced to contract workers.

Q: What are the penalties for CLRA non-compliance?

A: The penalties under the CLRA Act include: (1) Fine up to Rs 25,000 for operating without registration or license (Section 23), (2) Imprisonment up to 3 months plus fine up to Rs 1,000 for contravention of any provision (Section 24), (3) Imprisonment up to 6 months plus fine up to Rs 2,000 for repeat offences (Section 25), (4) Imprisonment up to 3 months plus fine up to Rs 500 for obstructing a Labour Inspector (Section 26). Under the Labour Codes 2025, penalties are significantly higher with fines up to Rs 2 lakh for first offence and Rs 4.8 lakh for repeat offenders.

Q: How have the Labour Codes 2025 changed contract labour rules?

A: The key changes include: (1) Threshold increased from 20 to 50 workers for applicability, (2) Contract labour in core activities is explicitly prohibited, (3) Single registration allowed for multiple locations within the same state, (4) Digital compliance and e-filing mandated, (5) Wages must be paid within 7 days of wage period end, (6) Enhanced penalties up to Rs 4.8 lakh for repeat offenders, (7) Clear definition of ‘core activity’ vs ‘non-core activity’ provided for the first time.

Q: Is a separate contractor license needed for each principal employer?

A: Yes, under the CLRA Act, a contractor must obtain a separate license for each principal employer they supply workers to. Each license requires a separate Form IV application, a separate Form V (Certificate from the respective Principal Employer), a separate security deposit, and a separate license fee. For example, if a security agency provides guards to five different companies, it needs five separate licenses. Each license specifies the particular principal employer, the nature of work, and the maximum number of workers.

Q: What welfare facilities must be provided for contract workers?

A: Mandatory welfare facilities include: (1) Drinking water at every worksite, (2) Latrines and urinals with separate facilities for men and women at every worksite, (3) First aid boxes at accessible locations, (4) Canteen when 100 or more workers are employed at a site, (5) Rest rooms when work starts before 6 AM or ends after 7 PM, (6) Creche when 50 or more women workers are employed (under Labour Codes). The contractor is primarily responsible, but if they fail, the principal employer must provide these facilities and recover the cost.