If you’ve been working in HR or compliance over the past few weeks, you’ve probably felt a bit like you’re on a rollercoaster. The latest ESIC circulars have left many of us wondering: Are we supposed to act now, or just watch and wait? Let’s take a step back and look at what’s actually happening.
The First Wave: “Do It Now!”
In early December, ESIC sent out a series of letters that seemed to light a fire under every HR desk. The message was clear: educational institutions must register with ESIC, factories and other establishments should update their records, and everyone needs to ensure all eligible employees are covered under the new Code on Social Security, 2020. There was also a strong push to start using the new wage definition and to make sure payroll and coverage were aligned with the latest guidelines. The SPREE 2025 scheme was highlighted as a window to get things in order by 31st December 2025.
For many of us, this felt like the starting gun. We started reviewing wage structures, checking employee lists, and preparing to make changes to our systems. After all, when the regulator says “act now,” you don’t want to be caught on the wrong side.
The Sudden Pause: “Wait, Not So Fast”
Then, on 18th December, ESIC issued a new circular that changed the tune. This time, the message was that the earlier letters were only meant to create awareness about SPREE. The actual compliance steps—like changing wage definitions and updating records—would only be required once the Central and State Rules under the Labour Codes are formally notified after public consultation.
Suddenly, what had seemed like an urgent directive was reframed as just an informational update. Many HR teams were left scratching their heads. Should we continue with our changes, or should we pause and wait for the official rules?
What Does This Mean for You?
Here’s the honest truth: until the Central and State Rules are notified, there’s no legal requirement to overhaul your payroll, wage definitions, or employee coverage based on these circulars alone. The regulator is asking you to track these developments, not to act on them yet.
This doesn’t mean you should ignore the circulars. Instead, use them as a signal to monitor the situation and prepare for what’s to come. Document your decisions to wait for the official rules, and keep a clear audit trail of your reasoning. If you’re asked later why you didn’t make changes, you’ll have a solid answer.
A Word of Advice
In times like these, it’s easy to feel pressured to act quickly. But the best approach is to stay calm, stay informed, and act only when there’s a clear legal mandate. Regulatory changes can be confusing, but by taking a thoughtful, legally grounded approach, you’ll protect your organisation and your team.
The bottom line is this: until the official rules are notified, there’s no need to rush into changes based on these interim letters. Keep an eye on the developments, document your decisions, and act when the time is right.
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