OSH/WHS Law Tracker — Week 32, 2026 (3–9 August): Form-V Appointment-Letter Deadline Lands 7 August; Andhra Pradesh Notifies Its Final OSH Rules the Same Day by G.O.Rt.No. 146 and Becomes the Fourth State Complete Across All Four Labour Codes; ESIC July Deposit Collides With Independence Day

This week (2026-08-03 to 2026-08-09) India's first hard deadline under the Occupational Safety, Health and Working Conditions (Central) Rules, 2026 landed: Form-V appointment letters fell due on 7 August 2026 for every establishment where the Central Government is the appropriate government — a three-month clock from the G.S.R. 345(E) notification of 8 May 2026, cascading to contractor workers with principal-employer exposure. On the same day, Andhra Pradesh notified its final OSH Rules by G.O.Rt.No. 146, becoming the fourth state complete across all four Labour Codes after Gujarat, Bihar and Arunachal Pradesh. Ahead: the ESIC July deposit falls on 15 August, a Saturday and Independence Day, shifting to Monday 17 August 2026. This is an execution week — the practitioner priority is evidence of Form-V issuance, not the letters themselves.

Top Developments This Week

1. The Form-V Deadline Landed — What an Inspector-cum-Facilitator Will Actually Ask to See

The obligation. Rule 6 of the Occupational Safety, Health and Working Conditions (Central) Rules, 2026 (notified G.S.R. 345(E), 8 May 2026, under Section 134 of the OSH Code, 2020) required appointment letters in the prescribed Form-V format by 7 August 2026 — three months from notification. The format is not a courtesy letter. It requires: employment type (regular, fixed-term or contractual), universal account number or insurance number where available, the labour identification number of the establishment, the employee's skill category, the broad nature of duties, and, for a woman employee, the maternity benefits available.

Scope, precisely. The Central Rules bind establishments for which the Central Government is the appropriate government — typically central public sector undertakings, railways, mines, major ports, banking and insurance. Private-sector employers whose appropriate government is a State are governed by that State's OSH rules once notified, and the Central Form-V format does not automatically apply to them. Getting this boundary wrong in either direction is the most common error we are seeing: state-sphere factories issuing Central Form-V unnecessarily, and Central-sphere contractors assuming their state has not notified yet so nothing applies.

What the file needs to contain now that the date has passed. Not the letters — those are the input. The evidence:

1. A date-stamped issuance register recording when each letter was issued, to whom, and against which employment category.
2. Contractor compliance certificates confirming issuance to contract workers, because the OSH Code makes the principal employer vicariously exposed for contractor-worker gaps.
3. Written escalation correspondence to any contractor that did not respond, dated before 7 August. This is the single most useful document in an Inspector-cum-Facilitator interaction — it converts a gap from negligence into documented pursuit.
4. A record of the exercise in the next Safety Committee minutes (Section 22, OSH Code), so it appears in the establishment record and not only in the HR file.

If you missed it. Issue immediately with the actual date. Do not backdate: a backdated appointment letter converts a compliance lapse into a records offence and forfeits the due-diligence position. Under the OSH Code the general penalty sits at Section 94, offences by companies at Section 109 — which carries an explicit conjunctive defence for directors and officers who prove the offence occurred without their knowledge and that they exercised all due diligence — and compounding at Section 114. The compounding route is available; the backdating route destroys it.

Links. Ministry of Labour & Employment — Gazette Notifications: https://labour.gov.in/gazette-notification | Shram Suvidha: https://shramsuvidha.gov.in/home

2. Andhra Pradesh Finalises Its OSH Rules — What Changes for a Multi-State Occupier

The notification. The Government of Andhra Pradesh, through the Labour, Factories, Boilers and Insurance Medical Services Department, issued G.O.Rt.No. 146 dated 7 August 2026 notifying the final Occupational Safety, Health and Working Conditions (Andhra Pradesh) Rules, 2026 under the OSH Code, 2020. The final rules followed the draft published 6 April 2026 and consideration of objections received. One compliance tracker records the G.O. date as 6 August 2026 rather than 7 August — verify against the AP Gazette copy before citing a date in advice.

What it repeals. The AP Rules revoke the state rules previously made under the Beedi and Cigar Workers (Conditions of Employment) Act, 1966, the Building and Other Construction Workers (RE and CS) Act, 1996, the Contract Labour (Regulation and Abolition) Act, 1970 and the Dock Workers (Safety, Health and Welfare) Act, 1986. Read against the OSH Code chapter map, that is Chapter XVIII (beedi and cigar), Chapter XI (BOCW and contract labour) and Chapter IX (docks) taking over four separate state rule-sets at once.

Why this is the week's second-most-important item. Andhra Pradesh becomes the fourth state to complete rules under all four Labour Codes, after Gujarat, Bihar and Arunachal Pradesh. That is the signal, not the state. Until mid-2026 the multi-state compliance matrix changed roughly annually; it is now changing month to month — Rajasthan on 30 June, Andhra Pradesh on 7 August — and every change re-bases registration, licensing, returns, Safety Committee thresholds and inspection procedure for establishments in that state.

Practitioner action. (1) For AP sites, stop advising on the repealed state rules immediately and re-run the registration and licensing position under the new Rules — AP's Code on Social Security (Andhra Pradesh) Rules, 2026 cross-reference Form-I under the OSH (AP) Rules, 2026, so the forms interlock across codes. (2) Re-check contractor licensing: dock, BOCW and contract-labour licences previously issued under the repealed rules need a transition position, and the licence-migration question is the one most likely to be raised at the first inspection. (3) Add a standing State Gazette watch rather than a periodic one for Karnataka, Maharashtra, Tamil Nadu, Telangana and Kerala — at the current cadence, a quarterly check is already too slow.

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Links. Andhra Pradesh Labour Department: https://labour.ap.gov.in/ | Ministry of Labour & Employment — Gazette Notifications: https://labour.gov.in/gazette-notification

3. Why the ESIC July Deposit Is the Quiet Trap in the August Calendar

The collision. The ESIC contribution on July 2026 wages is due 15 August 2026 under Regulation 31 of the Employees State Insurance (General) Regulations, 1950 — the fifteenth of the month following the wage month. In 2026 the fifteenth falls on a Saturday and is also Independence Day, a gazetted holiday. The deposit therefore shifts to the next working day, Monday 17 August 2026, together with the July provident-fund deposit.

Why not to rely on that. The shift rule is real but the failure mode is operational, not legal: bank cut-offs, portal availability and challan generation over a three-day closure are what actually cause a missed deposit. Pay by Friday 14 August 2026. The rates are Employer 3.25 per cent + Employee 0.75 per cent of gross wages up to the ₹21,000 per month coverage ceiling (₹25,000 for employees with disabilities), on the Code on Social Security, 2020 wage base — Basic plus DA, with the 50 per cent allowance cap on CTC.

The cost of getting it wrong is triple-counted. Simple interest at 12 per cent per annum under Regulation 31A; damages of 5 to 25 per cent of the arrear under Section 85B of the ESI Act, 1948 where delay runs beyond two months; and, separately, permanent disallowance of the employee share under Section 36(1)(va) of the Income-tax Act, 1961 following Checkmate Services (2022). The third is the one finance teams forget: a three-day delay on the employee share is not recoverable in a later year.

Adjacent August dates worth holding in one view. TDS deposit and GSTR-1 on 7 August, IFF on 13 August, ESI and PF on 17 August (shifted), GSTR-3B on 20 August, PMT-06 on 25 August. And on the OSH track: the 40-plus annual health check-up on 7 September 2026 and the Shram Suvidha establishment-record update on 7 November 2026.

Links. ESIC — employer page: https://www.esic.gov.in/employer-page | ESIC: https://www.esic.gov.in/

Regulatory Action Log

• Boilers — draft IBR 2026 still un-notified. With the Monsoon Session in its closing sittings, G.S.R. 31(E) remains a draft. IBR 1950 continues as the operative delegated regulation under the Boilers Act, 2025 (Act 12 of 2025), in force 1 May 2025 by S.O. 1943(E) of 30 April 2025, applying to all boilers and boiler components including government-owned plant. Complete the IBR 1950 versus draft IBR 2026 gap analysis now — registration, inspection cadence, digital-monitoring provisions. Note the parallel machinery: the Boiler Accident Inquiry Rules, 2025 (notified 10 September 2025) require an appointed committee to examine a damaged boiler and report to the Central Government within 45 days.

• Electrical — CEA Chapter XA milestones are overdue on their face. The CEA (Measures relating to Safety and Electric Supply) Amendment Regulations, 2026 (gazetted 30 March 2026, F. No. CEA-PS-16/1/2021-CEI Division) required CEA to publish the applicable BESS standards list, and the Directorate General of Fire Services to issue fire-official training guidelines, within three months of commencement. Neither is traceable from a Tier 1 source at W32 close. The substantive obligations — two-fault-tolerant design and a third-party fire-safety audit within three months of commissioning, reported to the Electrical Inspector — bind from 1 April 2027 regardless.

• Supreme Court ERF affidavit — week two of four. The Union and CPCB accounting for the Environment Relief Fund under Section 7A, Public Liability Insurance Act, 1991 is due around 20 August. Practitioner deliverables inside the window remain unchanged: Section 4(2A) paid-up-capital floor on the sum insured, Rule 11 contribution parity with the premium, insurer remittance confirmation, and reconciliation of the site inventory against the S.O. 227(E) (24 March 1992) threshold quantities and the MSIHC Rules 1989 Schedule 2 and 3 declarations.

• BOCW — Q2 cess reconciliation against monsoon site risk. Confirm the state-board receipt acknowledgment for the June-quarter remittance under the BOCW Welfare Cess Act, 1996. The Prakash Atlanta (JV) v NHAI dormant-statute defence (2026 INSC 76, 20 January 2026) applies only to periods before the state Welfare Board was constituted under Section 18 of the BOCW Act, 1996 — it is not a defence to current cess, and reading it as one is a live advisory risk.

• Addressing convention now settled. Correspondence, notice replies and safety-audit filings should address the Directorate General Occupational Safety and Health (DGOSH), renamed from DGFASLI by S.O. 2534(E) under Section 87(1) of the OSH Code with effect from gazette publication on 15 May 2026. For dock work at major ports, the penalty and compounding authority designated by S.O. 2486(E) of 13 May 2026 is the Deputy Director (Safety), Dock Safety Division, Mumbai.

State Variations

Andhra Pradesh. Moved into the final-rules column on 7 August 2026 (G.O.Rt.No. 146). Re-run registration, licensing and returns under the new Rules; the repealed beedi and cigar, BOCW, contract-labour and dock-worker state rules are no longer the advisory basis. Confirm the Form-I cross-reference with the Code on Social Security (Andhra Pradesh) Rules, 2026, and take a transition position on licences issued under the repealed rules.

Rajasthan. In force since S.O. 23 of 30 June 2026. Registration, licensing, renewals and statutory submissions filed electronically through the State portal, with deemed-approval mechanics where departmental timelines lapse — so the portal acknowledgement is the practitioner's primary evidence, not the department's response.

Gujarat. Complete across all four Labour Codes. Gujarat DISH monsoon inspection window active; inspector field-visit reports are uploaded to the DISHA portal within two days of visit, so a defect is on record before the occupier's reply is drafted. Chemical-manufacturing occupiers should run the PLI cover and ERF contribution reconciliation site-by-site during the Supreme Court affidavit window.

Maharashtra. Draft stage. The draft Maharashtra OSH (Factories and Other Ports) Rules, 2026 and draft Maharashtra OSH (Labour) Rules, 2026 were published 6 May 2026. Until final notification, DISH enforces the Factories Act 1948 + Maharashtra Factories Rules 1963, plus the MSIHC Rules 1989, the Chemical Accidents (EPPR) Rules 1996 and the Maharashtra Factories (Control of Industrial Major Accident Hazards) Rules, 2003 — which has no Central analogue and is routinely missed in multi-state matrices. Tarapur and Ambernath corridors: PLI/ERF file first, boiler certification second.

Tamil Nadu. Draft stage. DISH-TN and the State Boiler inspectorate continue the Gummidipoondi (SIPCOT, Tiruvallur) boiler-blast inquiry of 14 July. Separately, Virudhunagar's fireworks cluster is in its pre-Deepavali production ramp — Explosives Act 1884 + Explosives Rules 2008 licensing (Forms LE-1 to LE-6) through PESO, plus Section 87 of the Factories Act, 1948 on dangerous operations.

Karnataka. Still draft. The Draft Karnataka OSHWC Rules 2026 were published 23 January 2026 under notification LD 245 LET 2021; no final State Gazette notification is confirmable from a Tier 1 source. Continue advising on the Karnataka Factories Act 1 of 2003 and Karnataka Factories Rules 1969. Draft Rule 21(1)(b) would raise the non-hazardous-factory Safety Committee threshold from 200 to 500 workers — plan for the asymmetry before commencement.

Delhi-NCR. Monsoon active; no Delhi-specific OSH gazette notification in W32. Post-rain structural-integrity checks and scaffolding-tie inspection remain the operative site duty across Bawana, Narela and Okhla.

Practitioner Watch-List

1. Convert Form-V from issuance to evidence. Date-stamped register, contractor compliance certificates, pre-deadline escalation correspondence, and a Safety Committee minute. If issuance slipped, issue with the actual date and preserve the Section 109 due-diligence position — never backdate.

2. Re-base every Andhra Pradesh advisory. G.O.Rt.No. 146 repealed four state rule-sets in one instrument. Verify the G.O. date against the AP Gazette copy (6 versus 7 August discrepancy) before citing it.

3. Pay the ESIC and PF July challans by Friday 14 August. The legal shift to 17 August is real; the operational risk over a three-day closure is not worth taking.

4. Move state-rules monitoring from quarterly to standing. Two states finalised inside six weeks. A quarterly gazette check now under-serves any multi-state occupier.

5. Open the BESS design file if any site is adding grid-scale storage. Chapter XA binds 1 April 2027; the commissioning-linked fire-safety audit is the obligation most likely to be discovered after the fact.

FAQ

Q1: What exactly was due on 7 August 2026, and who had to comply?

Form-V appointment letters under the OSH (Central) Rules, 2026 (G.S.R. 345(E), 8 May 2026) — a three-month clock from notification, binding establishments for which the Central Government is the appropriate government. The format requires employment type (regular, fixed-term or contractual), UAN or insurance number, the establishment's labour identification number, skill category, broad nature of duties, and maternity benefits for women employees. The duty cascades to contractor workers, with the principal employer vicariously exposed. State-sphere establishments follow their own State OSH rules once notified.

Q2: What did Andhra Pradesh notify on 7 August 2026 and why does it matter beyond the state?

G.O.Rt.No. 146 dated 7 August 2026 notified the final Occupational Safety, Health and Working Conditions (Andhra Pradesh) Rules, 2026, repealing AP rules under the Beedi and Cigar Workers Act 1966, the BOCW Act 1996, the Contract Labour Act 1970 and the Dock Workers Act 1986. AP becomes the fourth state complete across all four Labour Codes, after Gujarat, Bihar and Arunachal Pradesh. The wider significance is cadence: the multi-state compliance matrix now changes month to month, not annually. One tracker records the date as 6 August — check the gazette copy.

Q3: When is the ESIC contribution for July 2026 wages actually due?

Statutorily 15 August 2026 under Regulation 31 of the ESI (General) Regulations, 1950; because that is a Saturday and Independence Day, the deposit shifts to Monday 17 August 2026 along with the July PF deposit. Pay by Friday 14 August rather than rely on the shift. Rates: Employer 3.25 per cent plus Employee 0.75 per cent up to the ₹21,000 monthly ceiling. Late deposit attracts 12 per cent per annum interest under Regulation 31A, 5–25 per cent damages under Section 85B ESI Act 1948, and permanent disallowance of the employee share under Section 36(1)(va) Income-tax Act 1961.

Q4: What happens to an establishment that missed the Form-V deadline?

Issue immediately with the actual date; do not backdate. Maintain a date-stamped issuance register, retain pre-deadline escalation correspondence to non-responding contractors, and record the remediation in the next Safety Committee minutes. Under the OSH Code, the general penalty is Section 94, offences by companies Section 109 (with a conjunctive due-diligence defence for directors and officers), and compounding Section 114. Backdating forfeits the due-diligence position that the compounding route depends on.

Q5: Did the draft Indian Boiler Regulations 2026 get notified during the Monsoon Session?

No. As at 9 August 2026 the draft published by G.S.R. 31(E) remains un-notified and IBR 1950 continues as the operative delegated regulation under the Boilers Act, 2025 (Act 12 of 2025), in force 1 May 2025 by S.O. 1943(E). Complete the IBR 1950 versus draft IBR 2026 gap analysis on registration, inspection cadence and digital-monitoring provisions. Note also the Boiler Accident Inquiry Rules, 2025 (10 September 2025) and their 45-day committee reporting cycle.

Compliance Deadlines — W32 and Beyond

Primary Sources This Week

• Ministry of Labour & Employment — Gazette Notifications: https://labour.gov.in/gazette-notification
• Andhra Pradesh Labour Department: https://labour.ap.gov.in/
• Shram Suvidha Portal: https://shramsuvidha.gov.in/home
• ESIC — employer page: https://www.esic.gov.in/employer-page
• Employees State Insurance Corporation: https://www.esic.gov.in/
• DPIIT — Boilers / Central Boilers Board: https://www.dpiit.gov.in/boilers
• India Code — Boilers Act, 2025 (Act 12 of 2025): https://www.indiacode.nic.in/handle/123456789/21395?view_type=browse
• Central Electricity Authority: https://cea.nic.in/
• Directorate General Occupational Safety and Health (DGOSH, formerly DGFASLI): https://dgfasli.gov.in/view-notification
• Supreme Court of India — latest orders: https://www.sci.gov.in/latest-orders/
• Petroleum and Explosives Safety Organisation (PESO): https://www.peso.gov.in/en
• Rajasthan Labour Department: https://labour.rajasthan.gov.in/
• Karnataka Labour Commissionerate (Karmika Spandana): https://karmikaspandana.karnataka.gov.in/english
• Maharashtra DISH — notifications: https://mahakamgar.maharashtra.gov.in/dish-notifications.htm
• DISH Tamil Nadu: https://dish.tn.gov.in/
• DISH Gujarat: https://dish.gujarat.gov.in/
• Parliament of India: https://sansad.in/
• e-Gazette of India: https://egazette.gov.in/

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