Are attendance registers different for contract workers?

The Contract Labour (Regulation and Abolition) Act, 1970 applies where an establishment engages contract labour above the prescribed threshold, and it prescribes a distinct set of registers and forms — muster roll, wages register, register of workmen employed by the contractor, and related returns. These sit alongside, not instead of, the registers the principal employer keeps for its own employees.

Primary responsibility for maintaining them rests with the contractor, but the principal employer is not a bystander. The Act requires the principal employer to ensure wages are paid and, where the contractor fails, to pay and recover — which in practice means an oversight obligation over the contractor's records. An inspection at your premises will not accept 'that is the vendor's paperwork' as an answer.

For IT services firms and agencies this arises constantly through subcontracted developers, staffing partners and site-based facility staff. The common failure is not refusing to keep records — it is keeping them in an unreconcilable way, where the contractor's muster roll and the client's access logs describe different realities and neither matches the invoice.

The Occupational Safety, Health and Working Conditions Code, 2020 consolidates contract labour provisions, and the direction is toward consolidated registers and electronic maintenance. That helps, but only for employers who can produce the contractor-side record on demand.