✅ Comprehensive Audit Checklist under the Code on Wages, 2019 (State-wise Compliant)
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For Monthly, Quarterly or Annual HR/Compliance Audits
๐งพ 1. Wage Structure & Salary Components
Audit Item | Checkpoint | Compliance Tip |
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1.1 | Is at least 50% of total remuneration included in "Wages" as defined under Section 2(y)? | Adjust Basic + DA accordingly |
1.2 | Are allowances (HRA, conveyance, bonus, incentives) not exceeding 50% of CTC? | Recalculate CTC if necessary |
1.3 | Is VDA (Variable Dearness Allowance) being revised as per state-specific frequency (e.g., half-yearly in MH & TN)? | Use CPI-IW index updates |
1.4 | Are part-time workers paid 15% premium over normal hourly rates (as required in Maharashtra)? | Apply premium where applicable |
1.5 | Have wages been revised after state’s latest minimum wage notification? | Keep updated with local wage board updates |
๐ 2. Registers & Forms (As per Code on Wages Rules)
Audit Item | Form | State Variations |
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2.1 | Register of Wages | Form I |
2.2 | Register of Overtime | Form II |
2.3 | Register of Deductions | Form III |
2.4 | Register of Fines | Form IV |
2.5 | Register of Advances | Form V |
2.6 | Wage Slip | Form VI |
2.7 | Evidence Register (Complaints) | Form VII |
2.8 | Appeal Register | Form VIII |
2.9 | Annual Return Submission | Form IX |
๐ฅ 3. Payment of Wages Compliance
Audit Item | Frequency | Remarks |
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3.1 | Are wages paid within 7th or 10th of the following month as per Act? | Monthly payroll cutoff check |
3.2 | Is salary credited directly into employee bank accounts? | Digital transfer mandatory |
3.3 | Are no unauthorized deductions made? | Check if deductions are per Sec 18 |
3.4 | Are loan/advance repayments as per agreed installments? | Document approval & recovery record |
⚖️ 4. Equal Remuneration
Audit Item | Gender Parity Check | Compliance Action |
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4.1 | Is equal pay given for same/similar work to male/female/third gender workers? | Review designation-wise salary |
4.2 | Are promotions and pay hikes non-discriminatory? | Ensure HR policy reflects parity |
4.3 | Do job descriptions mention non-discriminatory nature? | Include in appointment letters |
๐ง⚖️ 5. Bonus & Statutory Benefits
Audit Item | Law | Status |
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5.1 | Is bonus paid under Payment of Bonus Act till Central Rules notified? | 8.33% minimum, 20% max |
5.2 | Is gratuity paid under Payment of Gratuity Act till Wage Code enforced? | >5 years of service |
5.3 | Is Leave Encashment paid as per state law/Standing Orders? | Maintain leave register |
๐ ️ 6. Inspector-Cum-Facilitator Interaction
Audit Item | Preparation | Remarks |
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6.1 | Are all records digitally available for inspection? | Use HRMS or labour compliance software |
6.2 | Are intimations of deductions submitted within 10 days (in MH)? | Track via HR calendar |
6.3 | Is the establishment registered under Code on Wages Portal (once live)? | Mandatory for all employers |
6.4 | Are copies of notifications and VDA revisions available for reference? | Maintain hard & soft copies |
๐ข 7. Display & Notices
Audit Item | Required Notice | Location |
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7.1 | Minimum wages applicable | At main gate or employee notice board |
7.2 | Abstract of Code on Wages (in local language) | As per Rule 22 |
7.3 | Grievance Redressal Officer details | Mention name/contact clearly |
๐ป 8. State-Specific Additional Requirements
State | Extra Compliance Area |
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Maharashtra | Online filing of deduction notices, extra premium for part-time |
Tamil Nadu | Strong enforcement of working hours and VDA compliance |
Gujarat | SEZ compliance flexibility; MSME-friendly inspection |
Kerala | Legacy minimum wage levels; early VDA adaptation and union oversight |
๐งฎ 9. HR Policy & Internal Compliance
Audit Item | Review Needed |
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9.1 | Are offer letters & salary breakups Code-compliant? |
9.2 | Is internal wage audit done quarterly? |
9.3 | Are HR policies updated with new "wage" definition? |
9.4 | Is a Grievance Redressal Officer appointed (mandatory >20 workers)? |
9.5 | Are internal records reconciled with payroll and finance data? |
๐ข Final Compliance Scorecard Template
Area | Score (Out of 5) | Remarks |
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Wage Structure | ✅✅✅✅ | Aligned with 50% rule |
Registers & Forms | ✅✅✅ | Needs digitization |
Timely Payments | ✅✅✅✅✅ | Excellent |
Bonus & Benefits | ✅✅✅ | Partially delayed |
Display & Abstracts | ✅✅ | Missing in branches |
Inspector Preparation | ✅✅✅✅ | Portal setup pending |
HR Policy Alignment | ✅✅✅✅✅ | Fully compliant |
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