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Central Government Fixes Rs.18,000 per Month as Wage Ceiling for Supervisory Capacity

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  • February 06, 2026
Code on Wages, 2019 • Notification dated 30 January 2026 • Supervisory Wage Ceiling
The Central Government has fixed ₹18,000 per month as the wage ceiling for persons employed in a supervisory capacity under the Code on Wages, 2019. Supervisors earning above this amount will not be treated as “workers” for the purposes of the Code. This affects statutory coverage, eligibility for wage protections, and access to worker-specific legal remedies. Employers should reassess classification of supervisory staff based on this threshold.
What changed
Wage ceiling for supervisors aligned to ₹18,000 for worker classification under the Code on Wages, 2019.
Why it matters
Supervisors up to ₹18,000 may qualify for worker-linked protections such as wage safeguards, overtime and dispute remedies.
Immediate action
Re-check supervisory roles, wage bands and payroll compliance controls; ensure consistent classification across codes.
The rule in one view
Worker classification for supervisory staff under the Code on Wages, 2019
If supervisory wages are ₹18,000 or less
They may fall within the definition of “worker” under the Code on Wages, 2019, subject to their role and applicable tests used in labour jurisprudence.
If supervisory wages exceed ₹18,000
They will be excluded from the worker definition for the purposes of the Code on Wages, 2019, affecting access to worker-centric wage protections and remedies.
The Ministry of Labour and Employment notification issued on 30 January 2026 clarifies the ₹18,000 per month wage ceiling. The revision from earlier levels reflects inflationary trends and the policy intent to ensure lower-wage supervisory staff are not deprived of statutory protections.
Coverage impact
What supervisors up to ₹18,000 may now access as “workers”
Minimum wage protection
Entitlement to minimum wages as notified by the appropriate government.
Timely payment of wages
Coverage for timely wage disbursement and controls on unauthorised deductions.
Overtime and bonus eligibility
Potential eligibility for overtime payments and statutory bonus schemes, subject to applicable conditions.
Grievance and dispute remedies
Access to worker-centric grievance redressal and labour dispute mechanisms.
Social security linkage
Stronger linkage to statutory schemes such as PF and ESI, subject to relevant eligibility criteria under those laws.
This change also improves consistency across labour legislation. The Industrial Relations Code, 2020 had already set a similar supervisory wage limit, and harmonising thresholds helps reduce classification contradictions.
Employer actions
What HR and compliance teams should do next
Reassess supervisory roles
Identify supervisors earning up to ₹18,000 and evaluate classification as workers under the Code on Wages, 2019.
Update payroll systems
Align wage processing, deductions, overtime logic and statutory benefit coverage for those now within the worker definition.
Revise employment documentation
Update employment terms and templates where necessary to reflect the classification and entitlements.
Strengthen compliance audits
Prepare for inspections by maintaining auditable evidence that eligible supervisory staff are not denied statutory benefits.
Court lens: it is not only salary, but the dominant nature of work
Indian courts have repeatedly applied the dominant nature test to determine whether an employee is a workman, focusing on actual duties performed rather than designation alone. A key judicial observation is that job titles can be an eyewash if the person’s real work remains operational in nature.
Karma Global analysis
Key facts in light of the ₹18,000 supervisory threshold
1) “Worker” under the Factories Act, 1948 and “Worker” under the OSH Code, 2020 are not the same.
2) Under the Factories Act, 1948, casual labour connected with the manufacturing process is treated as a worker.
3) An HR executive can be a worker under the Factories Act, 1948, depending on the nature of work performed.
4) Under the OSH Code, 2020, a person employed mainly in managerial or administrative capacity is not a worker.
5) Under the OSH Code, 2020, a person employed in supervisory capacity drawing wages exceeding ₹18,000 is not a worker.
6) Even if someone is not a worker under OSH Code, the Code may still apply to the person as an employee in the establishment, based on relevant definitions.
7) For factory governance, “Occupier” is the key control concept for employer responsibility under OSH Code.
8) OSH Code excludes from “worker” categories: armed forces, police or prison services, managerial or administrative roles, and supervisors drawing wages exceeding ₹18,000.
9) A “Manager” may be a worker under the Factories Act but not a worker under OSH Code.
10) Supervisors are workers under the Factories Act irrespective of wages, whereas under OSH Code, supervisors drawing wages up to ₹18,000 are workers.
Employer vs principal employer under OSH Code
Employer refers to a person employing their own employees and exercising supervision and control. Principal employer applies when contract labour is engaged through a contractor. Every principal employer is an employer, but not every employer is a principal employer.
Occupier concept
A director with limited control over factory affairs will not be an occupier. The occupier is the person with ultimate control over the affairs of the factory.
Talk to Karma Management about payroll, outsourcing, labour laws, staffing, training and governance frameworks tailored for MSMEs. Write to: marketing@karmamgmt.com

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