✅ Comprehensive Audit Checklist under the Code on Wages, 2019 (State-wise Compliant)

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📅 For Monthly, Quarterly or Annual HR/Compliance Audits


🧾 1. Wage Structure & Salary Components

Audit Item Checkpoint Compliance Tip
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

📄 2. Registers & Forms (As per Code on Wages Rules)

Audit Item Form State Variations
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

📥 3. Payment of Wages Compliance

Audit Item Frequency Remarks
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
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

🧑‍⚖️ 5. Bonus & Statutory Benefits

Audit Item Law Status
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

🛠️ 6. Inspector-Cum-Facilitator Interaction

Audit Item Preparation Remarks
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

📢 7. Display & Notices

Audit Item Required Notice Location
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

💻 8. State-Specific Additional Requirements

State Extra Compliance Area
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

🧮 9. HR Policy & Internal Compliance

Audit Item Review Needed
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?

🟢 Final Compliance Scorecard Template

Area Score (Out of 5) Remarks
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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