OSH Rules 2026: Journey Allowance & Audio-Visual Worker Compliance Framework

Inter-State Migrant Workers and Audio-Visual Workers : Key Compliance Requirements for Employers

Summary: The article examines the stated requirements under the Occupational Safety, Health and Working Conditions (Central) Rules, 2026 for inter-State migrant workers and audio-visual workers. It discusses journey allowance after the stated 180-day employment threshold, a toll-free helpline, government studies and electronic reporting concerning inter-State migrant workers. For audio-visual workers, it discusses written agreements registered in Form XXIV, remuneration and instalments, additional payment for preparatory and extended work, breaks, refreshments, transport, food, travel and accommodation, accident insurance, suspension or cessation of production, early termination and dispute resolution under the Industrial Relations Code, 2020. The article concludes with practical compliance measures concerning workforce data, eligibility tracking, journey allowance, contractor compliance, employee communication, formal agreements, remuneration, working arrangements, travel, insurance and termination.

The Occupational Safety, Health and Working Conditions (Central) Rules, 2026 (“OSH Rules”) introduce specific compliance requirements for two categories of workers that often operate in dynamic and geographically dispersed employment environments—inter-State migrant workers and audio-visual workers.

Chapter XI of the OSH Rules deals with these categories separately. Part II addresses inter-State migrant workers, while Part III contains specific provisions concerning audio-visual workers.

The provisions reflect an important policy direction: labour compliance is increasingly moving beyond traditional factory-based employment relationships to address mobility, welfare, documentation, safety and contractual certainty.

For employers, contractors, production houses and other stakeholders, these provisions merit closer attention.

Part II – Inter-State Migrant Workers

1. Journey Allowance: A Defined Employer Obligation

One of the most significant provisions under Part II is the requirement relating to journey allowance.

Rule 102 provides that an employer must pay a lump-sum amount towards the fare for the to-and-fro journey between the place of employment and the worker’s place of residence in the home State.

The entitlement arises where the inter-State migrant worker has worked for not less than 180 days in the preceding twelve months in the concerned establishment.

The journey allowance is to be provided once in twelve months.

The prescribed travel mode includes:

• train not below II Class sleeper;
• bus; or
• another mode of passenger transport.

This is a significant compliance consideration for organizations employing migrant workers over extended periods.

Practical implication

Employers should not treat journey allowance as an informal employee-welfare benefit.

It should be incorporated into the organization’s:

HR policy → Eligibility tracking → Payroll/Finance process → Compliance records

A system should ideally identify when a migrant worker completes the required 180-day period.

2. Change of Employer Does Not Automatically Eliminate the Entitlement

An important situation addressed by Rule 102 is where an inter-State migrant worker changes employers during the relevant period.

Where the worker has not availed the journey allowance from the previous employer, the present employer may become responsible for payment where the worker has completed 180 days in the preceding twelve months, including the period spent with the previous employer.

The worker is required to provide a certificate in this regard.

This provision has an important HR implication.

Employee mobility can affect statutory entitlement calculations.

Accordingly, employers engaging experienced migrant workers should consider capturing:

• previous employer details;
• period of employment;
• journey allowance availed/not availed; and
• employee declaration/certificate.

This becomes particularly relevant in sectors characterized by high workforce mobility.

3. Toll-Free Helpline for Inter-State Migrant Workers

Rule 103 provides for a toll-free helpline for inter-State migrant workers.

The helpline is to be provided through a general or special order by the Director General, Labour Welfare Organization, Ministry of Labour and Employment, to address queries and safety concerns of inter-State migrant workers.

This reflects a broader shift towards ensuring that migrant workers have access to information and support mechanisms beyond the workplace.

For employers, this reinforces the importance of communicating statutory rights and available grievance/support mechanisms in a language understood by the workforce.

4. Government-Led Studies on Safety, Health and Welfare

Rule 104 enables the Central Government to identify studies relating to the safety, health and welfare of inter-State migrant workers.

Where necessary, the Central Government may consult State Governments or expert organizations involved in these areas.

The provision indicates that migrant-worker governance is not viewed solely through the lens of employment or wages.

It also encompasses:

Safety + Health + Welfare + Mobility + Access to Information

5. Data and Reporting on Inter-State Migrant Workers

The Rules also require employers to furnish details and statistics relating to inter-State migrant workers and their occupational safety and health electronically through a web portal designated by the Central Government.

This creates an important compliance expectation around workforce data management.

Organizations should therefore maintain accurate employee-level information concerning migrant workers, including the data required for statutory reporting.

This is especially relevant for organizations with:

• multiple establishments;
• project-based manpower;
• large contractor workforces;
• seasonal operations; or
• workers recruited from different States.

Part III – Audio-Visual Workers

The OSH Rules also recognize the specific nature of employment in the audio-visual sector.

Unlike conventional employment arrangements, audio-visual production frequently involves:

• project-based engagements;
• fixed production timelines;
• studio and location-based work;
• irregular working hours;
• travel;
• outdoor assignments; and
• contractual engagements linked to completion of a production.

The Rules therefore introduce a specific contractual framework.

6. Written Agreement with the Producer

Rule 105 provides that the agreement between an audio-visual worker and the producer is required to be registered in Form XXIV.

The prescribed Form XXIV provides considerable detail regarding the contractual relationship.

The agreement covers the duration of the engagement, nature of services, remuneration, working arrangements, travel, food, accommodation, insurance and termination.

The duration of the agreement is linked to completion of the audio-visual production and cannot exceed the prescribed consecutive-month period stated in the form.

This formalization is important for an industry where informal or project-based engagements have historically been common.

7. Remuneration Structure Must Be Clearly Documented

Form XXIV contemplates payment of an agreed amount to the audio-visual worker, including an advance at the time of signing and payment of the balance in specified instalments.

The contractual documentation therefore becomes the foundation for determining:

• agreed remuneration;
• payment milestones;
• outstanding amounts; and
• additional remuneration.

For producers, maintaining clear payment records will be essential to demonstrate compliance.

8. Additional Payment for Extended or Preparatory Work

The prescribed agreement specifically addresses situations where an audio-visual worker is required to attend the studio, location or workplace before the scheduled shift for preparatory work.

In such circumstances, the producer is required to pay additional wages at the prescribed contractual rate.

Similarly, where the worker is required to continue working beyond the working day, the agreement provides for:

• additional payment;
• a one-hour break;
• refreshments; and
• transport facilities.

This is particularly significant for production environments where working hours may vary depending on shooting schedules.

The key compliance lesson is straightforward:

Production schedules should not operate independently of labour compliance.

9. Transport, Food and Travel Support

The prescribed agreement requires the producer to provide transport and food, or pay travelling allowances for reporting to duty and food allowance while on duty, as customary or as fixed by bilateral arrangements between the producer and representatives of audio-visual workers.

Where the worker is required to work at an outdoor location, the producer is also required to bear travelling, accommodation, food and other customary expenses.

This creates a practical compliance requirement for production budgets.

Labour costs for audio-visual production should therefore consider not only the headline remuneration but also applicable:

Travel + Accommodation + Food + Transport + Extended-hours costs

10. Accident Insurance: A Specific Protection

One of the most significant provisions in Form XXIV is the requirement for the producer to get the audio-visual worker insured against injury or damage, including death caused by an accident arising out of or in the course of employment or during the assignment.

This provision is particularly relevant considering the nature of location-based production work.

Outdoor shoots, travel, equipment movement and variable working environments can create occupational risks that may not arise in conventional office employment.

Accordingly, producers should ensure that insurance arrangements are in place before deployment rather than treating insurance as a post-incident requirement.

11. What Happens When Production Is Suspended?

The prescribed agreement also addresses circumstances where production cannot proceed because of events such as:

• fire;
• riot;
• natural calamity;
• orders of a public authority; or
• other reasons beyond the producer’s control.

Where production is temporarily suspended, the producer may suspend the agreement after providing written notice and settling dues up to the date of notice.

Where production ceases completely, the agreement may be terminated with written notice and payment of amounts due.

This is particularly relevant in the context of project-based engagements.

The contract should therefore clearly establish the financial consequences of:

Suspension → Resumption → Cancellation → Termination

12. Early Termination by the Producer

The Rules provide significant protection where a producer seeks to terminate the agreement before its expiry for reasons other than misconduct or unwillingness of the worker to perform the agreed services.

In such a case, the producer is entitled to terminate the agreement only after paying the balance of the stipulated amount.

Only after such payment can the producer engage another audio-visual worker in place of the original worker.

This provision could have a direct financial impact on production planning.

A producer terminating an engagement prematurely should therefore examine the contractual and statutory consequences before replacing the worker.

13. Dispute Resolution

Rule 106 provides that the procedure for referring disputes involving audio-visual workers to a Conciliation Officer or Tribunal will follow the procedure prescribed under the Industrial Relations Code, 2020 and the rules made thereunder.

What Employers and Producers Should Do Now

The provisions under Part II and Part III warrant a practical compliance review.

For Employers Engaging Inter-State Migrant Workers

Organizations should consider implementing:

1. Migrant Worker Register/Data

Maintain accurate information regarding:

• home State;
• employment location;
• date of joining;
• period of employment;
• contractor, where applicable;
• journey allowance eligibility; and
• journey allowance payment.

2. 180-Day Tracking Mechanism

Create an automated alert when a migrant worker approaches completion of 180 days in the preceding twelve-month period.

3. Journey Allowance Process

Define:

Eligibility → Employee declaration → Approval → Payment → Record

4. Contractor Compliance

Where migrant workers are deployed through contractors, the principal employer should ensure that relevant worker information is available for statutory reporting and compliance verification.

5. Employee Communication

Communicate rights and available support mechanisms in languages that migrant workers can understand.

For Producers and Audio-Visual Companies

A robust compliance framework should include:

Written Agreement → Registered Form XXIV → Remuneration Schedule → Working Hours → Overtime/Extended Work → Transport → Food → Travel → Accommodation → Insurance → Termination → Dispute Resolution

The production budget should also factor in statutory and contractual worker-related costs from the beginning.

A Broader Compliance Message

The significance of these provisions goes beyond the specific obligations mentioned in the Rules.

For inter-State migrant workers, the framework recognizes that employment mobility creates additional welfare and administrative requirements.

For audio-visual workers, the framework recognizes that project-based and location-based work requires greater contractual clarity and worker protection.

Conclusion

The OSH Rules, 2026 bring greater structure to two categories of workers whose employment arrangements can be significantly different from conventional workplace models.

For inter-State migrant workers, the focus is on mobility, journey allowance, safety, health, welfare and access to information.

For audio-visual workers, the focus is on formal agreements, remuneration, extended working arrangements, travel and accommodation, accident insurance and protection against premature termination.

For employers and producers, the message is clear:

Labour compliance should begin before deployment—not after a dispute, inspection or claim arises.

The organizations that integrate these requirements into their HR systems, contracts, payroll processes and workforce data will be better positioned to demonstrate compliance under the new OSH framework.

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Disclaimer: This article is intended for general information and academic discussion and should not be construed as legal advice. Applicability of specific provisions should be examined with reference to the Occupational Safety, Health and Working Conditions Code, 2020, the OSH Rules, applicable State rules/notifications and the facts of each establishment.