Three compliance resets, one narrow window
Three separate workforce compliance changes landed within six weeks of each other at the close of 2025: India brought its four consolidated labour codes into force and then published draft rules for them, two US states added new pay disclosure obligations effective January 1, and a federal court upheld the $100,000 fee on new H-1B petitions. None of these is a minor procedural update. Each requires a near-term operational response from payroll, HCM and talent acquisition teams, not just from legal departments.
India's labour codes move from law to enforcement
The Government of India brought all four labour codes into force on November 21, 2025: the Code on Wages, the Code on Social Security, the Industrial Relations Code, and the Occupational Safety, Health and Working Conditions Code. Together they consolidate 29 existing central labour laws (EY India, 2025).
The Code on Wages carries the change payroll teams are watching most closely. It standardizes the definition of wages so that basic pay and dearness allowance must equal at least 50% of an employee's total cost to company. Employers who have historically kept basic pay low, often in the 30% to 40% range, to reduce statutory contributions now have to restructure salary components so the wage definition holds (EY India, 2025).
The codes are in force, but implementation is not complete. Payroll.org reported on December 17, 2025 that the detailed Central and State rules needed to operationalize the codes, covering wage calculation, benefit structuring, worker registration and safety standards, were still pending, leaving global payroll teams to prepare without a finished rulebook (Payroll.org, 2025).
That gap started closing at the end of December. On December 30, 2025, the central government issued draft Central Rules for all four codes and opened them for public consultation, with a 30-day comment window for the Industrial Relations Code rules and 45 days for the other three (EY India, 2025; All India Radio News, 2026). Employers operating in India now have a specific, near-term deadline to review the draft language and flag issues before it hardens into final rule.
Two more states join the pay transparency patchwork
In the United States, two state laws took effect January 1, 2026 that change what employers have to tell workers about pay, and neither is a simple range-posting mandate.
California's SB 642, signed by Governor Newsom on October 8, 2025, tightens the state's existing pay transparency and equal pay laws. It redefines "pay scale" as a good faith estimate of what an employer reasonably expects to pay a candidate upon hire, closing the practice of posting a wide placeholder range. It also extends the statute of limitations for equal pay claims to three years with a six-year lookback period for relief, and broadens the definition of "wages" for equal pay purposes to include bonuses, stock, and other forms of compensation beyond base salary (California Employment Law Report, 2025; CDF Labor Law, 2025).
Oregon's SB 906, signed by Governor Kotek on May 28, 2025, takes a different approach. Rather than regulating job postings, it requires employers to give every new hire a written explanation of their pay rate, pay period, benefit deductions and payroll codes at the time of hire, and to refresh that explanation annually for existing employees. Noncompliance carries a civil penalty of up to $500 per violation (Littler Mendelson, 2025).
Both laws apply only within their respective states. Neither should be read as a national standard, and employers operating across multiple states are working from two different compliance obligations that happen to start on the same date.
A federal court keeps the H-1B fee in place
The $100,000 fee on new H-1B petitions, imposed by presidential proclamation effective September 21, 2025, is still standing after its first serious legal test. The US Chamber of Commerce sued the Department of Homeland Security over the fee on October 16, 2025 in the US District Court for the District of Columbia. On December 23, 2025, Judge Beryl Howell ruled for the administration, finding the fee within the executive's authority to restrict entry of noncitizens and rejecting the argument that it violated the Administrative Procedure Act (The Hill, 2025; Fragomen, 2025).
The fee applies to new cap-subject H-1B petitions filed on or after the effective date. It does not apply to petitions filed before that date, to change-of-status or extension filings for people already in the US, or to cap-exempt employers such as universities. For talent acquisition teams sponsoring candidates who need a new cap-subject H-1B, the fee is now a budget line to plan around rather than a litigation risk that might disappear (Forbes, 2025).
The Chamber of Commerce case is not the only one pending. A separate challenge was filed in the Northern District of California in October 2025, and a coalition of 20 states filed a third suit in the District of Massachusetts in December 2025. Both remain unresolved (Forbes, 2025).
What to watch next
India's comment window on the draft Central Rules runs into late January and mid-February 2026, when employers and industry bodies will submit objections that could reshape the final language before it takes effect. In the US, the first job postings and new-hire paperwork under California's SB 642 and Oregon's SB 906 will start surfacing enforcement questions once employees and applicants have live postings to compare against the law's text. And the two pending H-1B fee lawsuits, in California and Massachusetts, will test whether the December ruling in Washington holds as the sole word on the fee's legality before the next H-1B cap season opens.