Most attendance policies in Indian companies were written by copying one. That is not a criticism of the people who wrote them. It is simply how the document usually comes to exist: somebody needs a policy by Friday, finds one, changes the company name and the office timings, and it goes into the handbook.
The copied policy usually works, in the sense that nobody challenges it, for as long as nobody challenges it. What it does not survive is the first employee who reads it carefully during a dispute. At that point three things tend to surface. The policy prescribes a financial penalty that the employer is not entitled to impose in that form. It says something about working hours that contradicts the state Act the establishment is registered under. And it describes a process that the attendance system does not actually implement, which means the record you would produce in support of the decision does not match what the policy says should have happened.
This piece sets out what an attendance policy has to decide, what the law constrains, and where policies fail. Section 7 is a sample you can adapt, written to be edited rather than pasted. It is deliberately shorter than most policies you will have seen, because length in a policy is usually a symptom of unresolved decisions, not a sign of thoroughness.
The intended reader is whoever will have to enforce this: an HR manager writing the policy, a founder formalising something that has been informal, or an HR head rewriting a document that has stopped matching how the company works.
Nothing here is legal advice. Attendance is governed partly by central law and partly by the Shops and Establishments Act of the state your establishment is registered under, and those differ. The four Labour Codes came into force on 21 November 2025, which changed several of the underlying provisions. Have the final document reviewed by someone who can read it against your own state registration and any settlement or standing orders that apply to you.
What an Attendance Policy Is For
An attendance policy is not a statement of values. It is the document you will hold up when you take an action that costs an employee money or their job, and its only real test is whether it survives being read back to you by somebody who disagrees with it.
That test has three parts.
It has to be specific enough to produce the same answer twice. If two managers can read the same clause and treat the same behaviour differently, the policy has not decided anything, it has delegated the decision while appearing to make it. Most attendance disputes are really disputes about inconsistency, not about the rule.
It has to be lawful. A policy that prescribes something the employer may not do is worse than no policy, because it is evidence of intent. Section 2 covers the constraints most policies breach.
It has to be implementable in whatever records attendance. A clause that says late arrivals beyond three in a month attract a half-day deduction is unenforceable if the system does not count late arrivals in a way that anybody can reproduce. This is the failure mode nobody anticipates and it is the most common one. Section 9 is about closing that gap.
Everything else in a policy is either a consequence of those three or is decoration.
What the Law Actually Requires
There is no single Indian statute called the attendance law. The obligations come from four places, and a policy that ignores any of them will eventually contradict it.
Working hours and weekly rest come from the state Shops and Establishments Act for commercial establishments, and from the Occupational Safety, Health and Working Conditions Code, 2020 for factories and the establishments it covers, which subsumed the Factories Act, 1948. Daily and weekly hour limits, the spread-over of a working day, rest intervals and the weekly off are set there, and they vary by state. A policy that states office timings without checking them against the applicable Act is asserting something it has not verified.
Record keeping comes from the same place. Registers of attendance, wages and overtime have to be maintained and produced on demand. The Codes consolidated the prescribed forms without removing the obligation, and the muster roll remains the document an inspector asks for. Our piece on attendance compliance under the Labour Codes sets out what has to be kept and for how long.
Leave entitlement comes from statute and interacts with attendance constantly, because most of what a policy calls absence is really an unapproved leave question. Statutory leave accrues on a basis fixed by law, not by policy, and a policy cannot reduce it. The detail is in our piece on leave policy requirements under Indian labour law.
Deductions come from the Payment of Wages Act framework, now carried into the Code on Wages, 2019, and this is where copied policies most often go wrong. Two different things get confused.
A deduction for absence from duty is permitted. If an employee is absent for a period and has no leave to cover it, wages for that period may be deducted, proportionate to the absence. That is not a penalty, it is simply not paying for time not worked.
A fine is a different instrument and it is tightly constrained. Under the Payment of Wages Act framework, a fine may only be imposed for acts and omissions that have been specified and approved in advance, the employee has to be given an opportunity to show cause, a register of fines has to be maintained, and the total fine imposed in any wage period may not exceed three per cent of the wages payable for that period. Fines also cannot be recovered in instalments beyond a limited window.
The distinction matters enough to set out side by side, because almost every policy that gets into trouble has merged these two.
| Deduction for absence from duty | Fine | |
|---|---|---|
| What it is | Wages not paid for a period not worked | A penalty imposed for an act or omission |
| When it applies | The employee was absent and had no leave to cover it | The employee worked, but did something the employer treats as a breach |
| Prior approval of the act or omission | Not applicable | Required, and the acts and omissions must be specified in advance |
| Opportunity to show cause | Not applicable | Required |
| Register | The attendance and wage registers | A separate register of fines |
| Ceiling | Proportionate to the period of absence | Total fines in a wage period capped at three per cent of wages payable for that period |
| Typical policy clause that gets this wrong | Rarely | "Three late marks equal a half-day deduction" |
Read those two paragraphs against your current policy. A clause that says three late arrivals equal a half-day deduction is imposing a penalty, not withholding pay for time not worked, because the employee did work most of that day. Whether it can stand depends on whether it is structured as a fine and meets every one of those conditions, and in most copied policies it does not. This is the single most common unlawful clause in Indian attendance policies and almost nobody notices, because the amounts are small and employees rarely contest them.
The safer construction, and the one used in the sample in section 7, is to treat repeated lateness as a performance and conduct matter handled through a warning process rather than through money. That is both more defensible and, in practice, more effective.
The Six Decisions the Policy Has to Make
Everything else follows from these. Make them explicitly, write down the answer, and the policy writes itself. The six are what counts as present, when the working day starts and ends, what lateness is and what follows from it, who approves a correction and by when, what happens to a day that is neither worked nor covered by leave, and who is exempt. A decision left implicit does not go away. It gets made later by whoever is processing payroll that month.
| The decision | What the policy has to state | What happens when it is left open |
|---|---|---|
| What counts as present | The mechanism for each kind of work: a punch, a system login, a manager's confirmation or output | One rule is written and exceptions are granted informally |
| When the working day starts and ends | Whether the start time is fixed or flexible, and if flexible, the window, core period or daily hours requirement | Most of the disputes |
| What lateness is and what follows from it | The threshold in minutes, and separately the consequence when it recurs | The threshold and the consequence are merged into a single clause |
| Who approves a correction, and within what window | A named approver, a deadline and a record | Corrections arrive during payroll processing and the payroll owner becomes the approver |
| A day neither worked nor covered by approved leave | The definition of absence without leave, its consequence and its escalation | The consequence and the escalation are improvised case by case |
| Who is exempt, and on what basis | The exempt roles, named in the policy rather than understood | A contesting employee points at the colleague the rule was not applied to |
What counts as present. Not a philosophical question, a mechanical one. Is presence established by a punch, by a system login, by a manager's confirmation, or by output? For a shift worker on a factory floor it is a punch. For a field sales executive it is a location capture at a customer site. For a designer working from home it is neither, and pretending otherwise produces a policy nobody follows. A company with more than one kind of work needs more than one answer, and the policy should say so instead of writing one rule and granting exceptions informally.
When the working day starts and ends, and how much of that is fixed. A policy that states a start time without saying whether it is fixed or flexible has not decided. If there is flexibility, define it: a window, a core period, or a daily hours requirement. Vagueness here produces most of the disputes.
What lateness is and what follows from it. This has two parts and they are usually merged wrongly. The threshold, meaning after how many minutes an arrival is late, and the consequence, meaning what happens when it recurs. Section 4 covers the arithmetic.
Who approves a correction, and within what window. Missed punches are routine, not exceptional. Attendance regularisation needs a named approver, a deadline, and a record. Without a deadline, corrections arrive during payroll processing and the payroll owner becomes the de facto approver of everybody's attendance.
What happens to a day that is neither worked nor covered by approved leave. This is the definition of absence without leave, and it needs a clear consequence and a clear escalation. Section 5 covers it.
Who is exempt, and on what basis. Most companies exempt somebody, usually senior staff or field roles, and most policies do not say so. Undeclared exemptions are the fastest way to make a policy unenforceable against everybody else, because the first thing a contesting employee will point at is the colleague the rule was not applied to.
Grace, Late Marks and Half Days: The Arithmetic
Almost every Indian attendance policy contains a grace period, a late-mark count and a conversion of late marks into something, and almost none of them state the arithmetic precisely enough to be reproduced. Here is what has to be pinned down.
The grace period is a number of minutes after the start time within which an arrival is not treated as late. Say whether it is per day, whether it is available every day or a fixed number of times per month, and what happens when it is exceeded: whether the whole delay counts or only the delay beyond the grace. Those two produce different numbers and policies rarely say which applies.
The late mark is a count. Say what resets it. A calendar month, a payroll month and a rolling thirty days are three different things and produce three different results for the same behaviour. Say it in the policy rather than leaving it to the system's default, because the system's default is the answer you will end up defending.
The conversion is the part that needs care. If accumulated late marks convert into a loss of pay, read section 2 again: that is a penalty for a day mostly worked, not a deduction for time not worked, and it needs to be structured as a fine to stand, with everything a fine requires. If instead the accumulated late marks convert into a formal warning, and repeated warnings feed into the disciplinary process, the mechanism is defensible, understood by everybody, and it does not put you inside the fines regime.
Half days are a separate decision and should be stated as a rule about hours, not a rule about halves. Define the minimum hours that constitute a full day and the minimum that constitute a half day, and say what happens below the lower threshold. A shift worker's half day and an office worker's half day are usually different numbers, which is another reason the policy may need more than one schedule.
Early departure deserves one line and usually gets none. Whichever way you treat late arrival, treat early departure consistently, or you have written a policy that penalises morning traffic and ignores afternoon errands.
Absence Without Leave, and What Follows
Absenteeism is the part of the policy that will be tested hardest, because the outcomes at the far end of it are termination and abandonment of employment.
Start with the definition. A day not worked and not covered by approved leave is absence without leave. That is simple, and the complexity is entirely in the exceptions: sickness reported by phone, a family emergency, a leave application submitted after the fact. The policy should say which of those can be regularised, by whom, and within what window. If sick leave can be applied retrospectively on return, say so and say whether a medical certificate is required beyond a stated number of days. If it cannot, say that instead, and expect to enforce it.
Then the consequence, which has two components that should not be merged. Pay for the absent day, which is a deduction for time not worked and is straightforward. And the conduct consequence for the pattern, which is a warning process with escalating steps. That escalation is the substance of an absenteeism policy and it belongs in this document rather than in a separate one.
Then the abandonment provision, which is the clause most policies get wrong by writing it too aggressively. A clause that says continuous unauthorised absence beyond a stated number of days will be treated as voluntary abandonment of employment is common and is not, on its own, sufficient. Treating an employee as having abandoned employment is in substance a termination, and doing it without notice, without a written communication to the employee's recorded address, and without an opportunity to respond, is the version that fails when contested. Write the clause with the notice step in it. The number of days is a business decision; the notice step is not optional.
One more thing that policies routinely omit: what happens to the statutory leave balance and the final settlement when an absence period ends in exit. Employees ask, HR improvises, and the improvisation is inconsistent. Say it once in the policy.
Attendance for Remote, Hybrid and Field Staff
A policy written for one office and applied to three kinds of work is the most common structural failure we see, and it is getting more common, not less.
For remote and hybrid staff, the honest position is that presence is no longer the measure and pretending it is produces theatre: employees who move a mouse, managers who ignore the data, and a record nobody trusts. What is worth capturing is availability during agreed hours and the days on which the employee is expected in an office, if any. Write the hybrid expectation as a number of days and a way of designating them, and make the designation visible in the system rather than agreed in a chat. Our piece on attendance for distributed teams covers what capture is worth doing at all.
For field staff, location matters and the policy has to say so plainly. If attendance is established by a location capture at a customer or site, the policy should state that location is captured at the point of marking attendance, state what is captured and what is not, and say what the data is used for. Live location tracking through the day is a different thing from a location stamp at check-in, and conflating them in a single policy clause is both a privacy problem and an adoption problem. Both can be legitimate, and plenty of field operations genuinely need route data for visit verification or for a distance-based conveyance claim. What the policy has to do is say which of the two applies to which population, and say it separately. Where we deploy field tracking, live tracking is off by default and enabled per team rather than across the company, which is the configuration we would recommend whoever you buy from.
For shift workers the issue is different again: shifts rotate, a night shift crosses midnight, and the policy has to say which day a shift belongs to for attendance purposes. Get this wrong and the same night's work is counted twice or not at all at month end, and the overtime attached to it goes the same way.
The practical answer is a single policy with a schedule per population, rather than one rule with informal exceptions. It is longer to write and considerably shorter to argue about.
A Sample Attendance Policy You Can Adapt
What follows is a working draft, not a finished document. Every square bracket is a decision you have to make, and section 3 is where the decisions are explained. Have the result reviewed against your state's Shops and Establishments Act, and against any standing orders or settlement that applies to you, before it goes into a handbook.
Purpose and scope
This policy sets out the attendance expectations that apply to all employees of [Company], at all locations, and the process by which attendance is recorded, corrected and reviewed. Where a schedule at the end of this policy states a different rule for a specific category of employee, that schedule prevails for that category. Where this policy conflicts with a statutory provision applicable to an establishment, the statutory provision prevails.
Working hours
The standard working day is [8] hours, exclusive of a meal interval of [30] minutes, worked between [09:30] and [18:00], [five/six] days a week. The weekly off is [Sunday]. Working hours, rest intervals and weekly rest are subject to the limits under the applicable state Shops and Establishments Act or, for establishments to which it applies, the Occupational Safety, Health and Working Conditions Code, 2020, and this policy does not permit anything those provisions do not.
Recording attendance
Attendance is recorded through [the biometric device at the entrance / the mobile application / the employee self-service portal] and no other record is authoritative. Employees are responsible for marking attendance at the start and end of each working day. A day for which no attendance is recorded and no approved leave exists is treated as absence without leave under clause 8.
Late arrival
An arrival after [09:30] is late. A grace period of [15] minutes applies [on each working day / on [3] occasions in a calendar month], and an arrival within the grace period is not recorded as late. Where the grace period is exceeded, the arrival is recorded as late irrespective of the grace period.
Consequences of repeated lateness
Late arrivals are counted over a [calendar month]. [3] late arrivals in that period result in a documented conversation with the reporting manager. [5] result in a written warning, which is placed on the employee's record. Continued lateness after a written warning is dealt with under the disciplinary process, which may include consequences up to and including termination. Lateness does not attract a deduction from wages under this policy.
Half days and short days
A day on which an employee works fewer than [4] hours is recorded as absent. A day on which an employee works at least [4] hours but fewer than [7] hours is recorded as a half day and a half day of leave is applied against the employee's balance, or, where no balance exists, wages for a half day are not payable. Early departure before [18:00] without prior approval is treated under clause 5 in the same way as late arrival.
Correcting the record
Where attendance has not been recorded correctly, the employee may submit a regularisation request to their reporting manager within [7] days of the date concerned, stating the reason. The reporting manager may approve or reject it, and the decision is recorded. Requests submitted after [7] days, or after the payroll cut-off for the month concerned, whichever is earlier, will not be considered and the day stands as recorded.
Absence without leave
A day not worked and not covered by approved leave is absence without leave. Wages are not payable for such a day. Where an employee is unable to attend for reasons of illness or emergency, they must inform their reporting manager on the day, by [telephone or written message], and apply for the appropriate leave on return. Leave applied for on return may be approved at the reporting manager's discretion. Sickness absence exceeding [2] consecutive days requires a medical certificate.
Continuous unauthorised absence
Where an employee is absent without leave and without intimation for [5] consecutive working days, [Company] will send a written communication to the employee at the address recorded in their file, requiring them to report for duty and to explain the absence within [7] days of the date of that communication. Where the employee neither reports nor responds within that period, [Company] may proceed on the basis that the employee has abandoned employment, and will confirm that position in writing. Nothing in this clause removes the employee's right to be heard.
Holidays, leave and compensatory off
Public and festival holidays applicable to each location are published at the start of each calendar year. Leave entitlement, accrual and application are governed by the leave policy. Where an employee works on a weekly off or a declared holiday at the company's request, [compensatory off is granted and must be availed within [90] days / overtime is payable in accordance with the applicable statutory provision].
Records
Attendance records are maintained in [system] and retained for the period required under the applicable statutory provisions. Employees may view their own attendance record at any time through [the employee self-service portal].
Schedules by category
Schedule A applies to employees working on shift. For these employees, a shift beginning on one calendar day and ending on the next is recorded against the calendar day on which it began, for attendance, for overtime and for the wage period. Shift timings, the applicable grace period and the shift allowance are as notified for each shift.
Schedule B applies to employees working in the field. For these employees, attendance is recorded through the mobile application and a location is captured at the moment attendance is marked and at the moment it is closed. [Location is not recorded at any other time. / In addition, location is recorded at intervals of [x] minutes between those two points for the purpose of [visit verification and conveyance computed on distance travelled].] Location data is used solely for the purposes stated in this clause and is retained for [x] months.
Schedule C applies to employees working remotely or on a hybrid basis. For these employees, attendance is recorded through [the employee self-service portal] and availability is expected during [11:00 to 17:00]. Employees on a hybrid arrangement are expected at their designated office on [2] days each week, designated in [system] in advance.
That is the whole policy. If yours is four times longer, look at what the extra length is doing, because in most handbooks it is restating the law inaccurately or describing a process the system does not implement.
Where Policies Fail in Practice
Five failure modes, in the order we see them. The policy contradicts the state Act the establishment is registered under. The penalty clause is unlawful, because it converts late marks into a pay deduction without meeting the conditions a fine has to meet. The policy is enforced selectively against people it never named as exempt. The system does not implement what the document says. And the policy was never communicated in a way that can be evidenced against a version.
The policy contradicts the state Act. Written for a head office in one state, applied to a branch in another with different daily hour limits or a different weekly rest provision. The fix is the schedule structure in section 7, with the location-specific numbers stated rather than assumed.
The penalty clause is unlawful. Covered in section 2. A late-mark-to-pay-deduction conversion that is not structured as a fine, does not meet the conditions for one, and has never been tested because the amounts are small.
The policy is enforced selectively. One department applies it, another does not, and the exemption was never written down. This is the failure that loses disputes, because the inconsistency is easy to demonstrate and hard to justify after the fact.
The system does not implement the policy. The document says late marks reset monthly and the system counts them on a rolling basis. The document says regularisation closes after seven days and the system accepts it until payroll runs. Nobody notices until the two are compared in a dispute, at which point the system's record is the evidence and the policy is just a document.
The policy was never communicated in a way that can be evidenced. Circulated by email in 2021, updated twice since, and nobody can show which version an employee was working under. An acknowledgement recorded against a version, in the system, solves this cheaply and almost nobody does it.
Making the Policy Enforceable in the System
A policy and the system that records attendance have to agree, clause by clause, or the policy is decorative. Four checks close the gap: configure the counters to match the words, route approvals to the person the policy names, close the regularisation window automatically rather than by memory, and make each employee's own record visible to them. The first takes about an hour and prevents most of section 8.
Configure the counters to match the words. Grace period, its frequency, the late-mark reset basis, the half-day hour thresholds and the regularisation window are all numbers in a document and settings in a system. Sit with both open and reconcile them line by line. This takes an hour and prevents most of section 8.
Make the approval path the one in the policy. If the policy says the reporting manager approves regularisation, the system should route it to the reporting manager and nobody else, and should record who approved what and when. An approval that happened over a message and was keyed in by HR is not the record the policy describes.
Close the window automatically. A regularisation deadline that depends on somebody remembering to stop accepting requests will not hold. The system should stop accepting them. Attendance software that enforces a cut-off removes an argument that otherwise recurs every month.
Make the employee's own record visible to them. Employee self-service turns attendance from something done to people into something they can check. It also means a disputed day gets raised in week one rather than at the end of the year, which usually keeps it a correction instead of a grievance. Leave balances belong in the same place for the same reason.
One further step worth taking: record acknowledgement of the policy against its version. When the policy changes, re-acknowledge. It is a small amount of work and it is the difference between "the policy says" and "the employee accepted this version on this date". Our HR policy template and employee handbook template are built to be versioned the same way, and the full set is at our HR templates library.
Questions People Ask
What should an attendance policy include?
Six decisions and their consequences, and very little else. What counts as present for each kind of work you have, when the working day starts and ends and how much of that is fixed, what lateness is and what follows from it, who approves a correction and within what window, what happens to a day that is neither worked nor covered by leave, and who is exempt and on what basis. Everything a good policy contains is either one of those or follows from one. If your document is much longer than the sample in section 7, the extra length is usually restating statute inaccurately or describing a process your attendance system does not actually implement, and both are liabilities, not thoroughness.
Can a company deduct salary for late coming in India?
This is the question with the most confidently wrong answers in circulation. Two different things get conflated. Not paying for time not worked is a deduction for absence and is permitted. Taking money for a day that was mostly worked, because the employee arrived late, is a penalty, and under the Payment of Wages Act framework carried into the Code on Wages, 2019 a fine may only be imposed for acts and omissions specified and approved in advance, requires an opportunity to show cause and a register of fines, and the total fined in a wage period may not exceed three per cent of the wages payable for that period. Most late-mark deduction clauses in Indian handbooks meet none of those conditions. Handling repeated lateness through a documented warning process instead is both lawful and, in our experience, more effective at changing the behaviour.
How many late marks equal a half day?
There is no statutory answer, which surprises people. The three-late-marks-equal-a-half-day convention is a custom that spread by copying, not a rule with a source. Whatever number you choose, the thing that matters is the clause underneath it: if accumulated late marks convert into a loss of pay, you are in the fines regime described above and the clause has to satisfy it. If they convert into a documented conversation and then a written warning, you are in the disciplinary process, which is where this behaviour belongs anyway. The sample in section 7 uses three and five for the two warning steps and does not convert lateness into money at all.
Is an attendance policy legally required in India?
The policy itself is not a statutory document. The obligations underneath it are: registers of attendance, wages and overtime have to be maintained and produced on demand, working hours and weekly rest are constrained by the state Shops and Establishments Act or, for covered establishments, the Occupational Safety, Health and Working Conditions Code, 2020, and statutory leave accrues on a basis fixed by law. A written policy is how you make sure your practice matches those obligations and how you evidence consistency when a decision is challenged. Companies without one are not in breach for that reason alone; they simply have nothing to point at when a dispute starts.
How should the policy handle work from home and hybrid?
Write it as a schedule rather than as an exception. The honest position for remote work is that presence is not the measure, so capturing it as though it were produces a record nobody trusts and managers ignore. What is worth stating is availability during agreed hours and, for hybrid, the number of days expected at an office and how those days are designated. Designate them in the system rather than in a chat, because a hybrid expectation that exists only in conversation cannot be enforced consistently and will be applied differently by different managers, which is the failure in section 8 that actually loses disputes.
Can we treat continuous absence as resignation?
Not simply by declaring it. Treating an employee as having abandoned employment is in substance a termination, and a clause that converts absence into resignation automatically after a stated number of days is the version that fails when contested. What holds up is the same clause with a notice step: a written communication to the employee's recorded address requiring them to report and explain within a stated period, and only then a written confirmation of the company's position if there is no response. The number of days before you write is a business decision. The written communication and the opportunity to respond are not optional, and the sample clause in section 7 is drafted that way.
What is the difference between an attendance policy and a leave policy?
The attendance policy governs the days an employee is expected to work and what happens when they do not, or do so late. The leave policy governs entitlement, accrual, application and approval for days the employee is entitled to be away. They meet at exactly one point, which is the day that was not worked: whether it is covered by an approved leave application or is absence without leave. Keep them as two documents and make the join explicit in both, because merging them produces a long document in which the statutory leave provisions get buried inside operational rules and are then edited by people who do not realise they cannot be reduced.
How do we roll out a new attendance policy without a fight?
Publish the change before it takes effect, not with it. Say what is changing and why, give a date it starts, and run the old and new rules in parallel for one cycle so people can see their own numbers under both. Reconcile the document against the system before you publish, using the four checks in section 9, because the fastest way to lose credibility is to announce a rule the system then applies differently. Record acknowledgement against the version. Most of the resistance to attendance policies comes from inconsistency rather than strictness, and a rule that applies to everybody visibly generates far less friction than a lenient rule applied unevenly.
Does attendance software make the policy enforceable on its own?
No, and a vendor who suggests otherwise is describing a smaller problem than you have. Software enforces the mechanics: it counts, it closes the correction window, it routes the approval to the named person and it keeps the record. What it cannot do is make the policy lawful, make it consistent with your state's Act, or stop a manager applying it to one team and not another. What it does do is remove the excuse. Once the counters match the words and the record is visible to the employee, a disagreement becomes a disagreement about the rule, which is a conversation you can have, rather than about the facts, which is one you cannot win.
Where This Leaves You
Do these in order.
Read your current policy against section 2 first, specifically the deduction and fine distinction. If there is a clause that converts lateness into money, that is the one to fix, and it is usually the only clause in the document with real exposure attached.
Then make the six decisions in section 3 explicitly, with whoever will have to enforce them. Write the answers down before you write any prose. Most of the time you will find that two of the six have never actually been decided, and that is why the current document is vague in exactly those places.
Then draft from the sample in section 7, filling the brackets rather than adding sections. Add a schedule per population instead of writing exceptions into the main text.
Then sit with the document and the system open at the same time and reconcile them clause by clause, using the four checks in section 9. Do this before you publish, not after.
Then have it reviewed against your state registration and any standing orders that apply, and record acknowledgement against the version.
If the system side is the gap, our attendance software enforces the counters, the approval path and the correction window rather than trusting people to remember them, leave sits on the same record so the join in section 10 is not a reconciliation, field tracking carries the schedule B population, and the pricing is published rather than quoted.
Related reading: leave policy requirements under Indian labour law, attendance compliance under the Labour Codes, the best attendance management software in India, and the labour law compliance checklist.
Sources
- Code on Wages, 2019, enacted text on India Code. The provisions on deductions from wages, including the conditions attaching to fines, the requirement that acts and omissions be specified and approved in advance, the register of fines, and the cap on the total fine imposed in a wage period.
- Payment of Wages Act, 1936, enacted text on India Code. The framework carried into the Code on Wages, including the three per cent limit on fines in a wage period and the distinction between a fine and a deduction for absence from duty.
- Occupational Safety, Health and Working Conditions Code, 2020, enacted text on India Code. Working hours, weekly rest, spread-over and record keeping for covered establishments, and the consolidation of the Factories Act, 1948.
- Ministry of Labour and Employment, labour.gov.in. Commencement of the four Labour Codes on 21 November 2025.
- State Shops and Establishments Acts. Working hours, rest intervals, weekly off and record keeping for commercial establishments. These differ by state, and the applicable Act is the one for the state in which the establishment is registered.
Nothing above is legal advice, and no clause in the sample policy has been drafted for any particular establishment. Have the final document reviewed against your own state registration and any standing orders or settlement that applies to you.
