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⚠️ New Labour Codes: Gratuity Costs Set to Rise from FY25–26

Two major changes under the Social Security Code and Wage Code will significantly impact how organisations account for and fund gratuity:

1️⃣ Fixed-Term Employees Become Gratuity-Eligible Earlier

FTEs will now receive pro-rata gratuity on contract completion, even without completing 5 years.
Effectively, gratuity begins accruing from Year 1.

Impact:
✔ Larger eligible population
✔ Higher Current Service Cost (CSC)
✔ Higher year-end liability (DBO)
✔ Need for separate decrement assumptions for FTEs


2️⃣ Unified “Wage” Definition Increases Gratuity Salary Base

The 50% rule under the Wage Code ensures allowances cannot exceed half of total remuneration.
If they do, the excess becomes part of “wages” — directly increasing the gratuity base.

Impact:
✔ Higher benefit salary
✔ Higher DBO + CSC for allowance-heavy pay structures
✔ Potential one-time gain/loss if companies rebalance pay mid-year

What This Means for Employers 

From FY25–26, expect:
🔺 Higher gratuity provisions
🔺 Higher annual expense
🔺 Earlier cash outflows due to FTE exits

Magnitude depends on:
• Share of fixed-term employees
• Ratio of allowances to basic/DA


Recommended Actions

🔹 Refresh employee census (identify FTEs + contract end dates)
🔹 Review wage structures vs 50% rule
🔹 Re-run actuarial valuation under new rules
🔹 Align Ind AS 19 / AS 15 disclosures 

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