Navigating Ind AS 19 in the Era of the New Wage Code

[2026] 182 taxmann.com 608 (Article)

1. Introduction

The notification and impending implementation of the New Labour Codes, particularly the Code on Wages, 2019, marks a structural shift in India’s employee compensation framework. While the operational and HR implications are widely discussed, the financial reporting consequences under Ind AS 19 Employee Benefits are equally significant and, in many cases, immediate.

Recent quarterly financial statements of several large corporates have already reflected substantial exceptional items arising from employee benefit remeasurements. These adjustments are not policy choices but accounting consequences triggered by a change in the employer’s constructive and legal obligations.

2. Interplay Between Labour Codes and Ind AS 19

Ind AS 19 requires entities to recognize:

• A liability for defined benefit obligations (DBO)
• An expense when employee benefits are earned or when obligations are amended

The New Wage Code alters the definition of “wages”, which directly affects the base on which statutory benefits, such as:

• Gratuity
• Leave encashment
• Bonus-linked benefits are computed.

Once the Code becomes notified or when its implementation becomes virtually certain, the employer’s obligation under Ind AS 19 changes, triggering remeasurement.

3. Beyond HR: Why Labour Code Changes Are a Financial Reporting Issue

Under Ind AS 19, entities are required to recognise increased obligations even before any actual salary restructuring or cash outflow occurs, whenever past service benefits are enhanced or the benefit formula is amended to the employee’s advantage. Consequently, the implementation of the New Wage Code constitutes a financial reporting event in its own right, rather than merely a prospective payroll adjustment.

4. The 50% Wage Rule and Actuarial Mechanics

The 50% Rule – Core Trigger

Under the New Wage Code, exclusions such as HRA, allowances, and perquisites cannot exceed 50% of total remuneration. Consequently, the Basic + DA component must be at least 50% of CTC.

Since gratuity and leave encashment are calculated on Basic (or Basic + DA), this rule significantly increases the benefit base.

5. Impact on Defined Benefit Plans

Defined benefit obligations under Ind AS 19 are sensitive to:

• Salary levels
• Salary escalation rates
• Years of service

An increase in Basic wages leads to:

• Higher projected benefit obligations
• Immediate increase in Present Value of Defined Benefit Obligation (PVDBO).

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