Insights · Occupational health compliance

The OSH Code's mandatory annual health check: an employer's setup guide

Medvis Healthcare Group · 31 July 2026 · 6 min read

India’s Occupational Safety, Health and Working Conditions Code has done something no earlier labour law did: it made an annual health check for workers above 40 a legal obligation for the employer — funded by the employer, across industries. Most compliance teams have heard about it. Far fewer have set up for it. This guide covers what changed, who is covered, what “compliant” actually means, and a practical checklist to get from zero to inspection-ready.

What changed — and when

The OSH Code, 2020 consolidated thirteen older labour laws, including the Factories Act 1948’s health provisions. It came into force on 21 November 2025, and its compliance obligations became binding on 8 May 2026. Among its employer duties is a free, employer-funded annual health examination for every worker above 40 years of age — no longer limited to hazardous processes or notified factories.

Under the older, largely voluntary regime, health-check utilization in corporate India hovered around a third of eligible employees. The OSH Code converts that discretionary benefit into a statutory duty — with the records to prove it.

Who is covered

• All industries, not just factories. The Code’s health-check duty reaches establishments well beyond the traditional Factories Act perimeter.
• Every worker above 40 — on your rolls or engaged through contractors working at your establishment (contract-labour coverage follows the Code’s establishment-based logic; take specific advice for your structure).
• Hazard-exposed roles keep their existing, stricter cadences.Periodic medical examinations under the Factories Act framework and DGMS-aligned schedules for mines continue — the annual check is a floor, not a replacement.

“Compliant” means records, not bookings

The common mistake is to treat this as a procurement task: book a camp, collect a vendor invoice, done. An inspector’s question is different: show me the register. Who was screened, on which date, what was found, which doctor signed the record, and when is each worker due next? If those answers live in filing cabinets and spreadsheets across departments, you have bookings — not compliance.

A compliant program produces, as a by-product of running it: a per-worker health record, a doctor-signed outcome for every examination, a statutory register that is always current, and a recall list of who is due in the next cycle.

The employer’s setup checklist

1. Roster the covered workforce. Extract every worker above 40 (plus hazard-exposed roles of any age), with date of birth, role, department and site. This roster is the backbone — every later record hangs off it.
2. Choose the delivery model. On-site camp (most practical for plants and large sites), a tie-up with a local diagnostics provider, or a hybrid. Ask any provider two questions: can a doctor sign every record, and in what form do we receive the data — PDFs, or structured records we can keep as registers?
3. Define the examination panel. A physician examination plus a baseline panel appropriate to age and role; add role-specific tests (audiometry, spirometry, vision) where exposure demands them.
4. Make doctor sign-off non-negotiable. Every fitness outcome must carry a qualified doctor’s signature. Software can draft and organize; only a clinician decides.
5. Generate the register as you go — not as a year-end reconstruction. Each examination should update the register the day it happens.
6. Set the recall cycle. “Annual” only works if someone is tracking due dates. Build the next-due date into the record at the moment of examination.
7. Close the loop on findings. An abnormal result that nobody acts on is a liability, not a record. Route findings to a doctor’s review and document the advice given.

Where paper programs fail

The same failure modes repeat across plants: camp results arrive as a carton of PDFs weeks later; certificates go missing when a medical officer transfers; nobody can produce a due-list, so workers are missed in the next cycle; and when a notice arrives, assembling evidence takes days. None of these are medical failures — they are record-keeping failures, and they are exactly what an inspector sees.

How Medvis maps to this

Medvis was built for precisely this chain. The workforce roster is uploaded once; camps are scheduled against it; samples are barcoded on-site; results flow from analyzers into our laboratory information system with automated quality control; a doctor reviews and signs every record; and fitness certificates and statutory registers generate themselves — with recall dates set at the moment of examination. The full statutory workflow is described on our occupational health page.

We are honest about where we are: Medvis is a Hyderabad-based platform working with early partners, not a decade-old incumbent. What we offer is a system built for the OSH Code era — records-first, doctor-signed, inspection-ready by design.

This guide is general information for Indian employers, not legal advice. Statutory interpretation varies by state rules and establishment type — confirm specifics with your legal counsel. Medvis provides decision-support software; every fitness decision on our platform is signed by a qualified doctor.