Bridging the Divide: A Comparative Analysis of India’s New Labour Codes and US Employment Laws

Abstract

This article provides a comprehensive comparative analysis of India’s newly implemented Labour Codes against the established US labour law framework. Drawing from over a decade of global practitioner experience, the study deconstructs complex legal statutes such as the Code on Wages, the Industrial Relations Code and the Code on Social Security. The analysis highlights critical divergences in gratuity eligibility, wage structures and gig worker protections. Written in plain English to ensure accessibility for non-legal professionals, this research utilises comparative tables and practical examples to equip human resources (HR) leaders with the clarity needed to navigate the evolving cross-border employment landscape.

Keywords

US labour law gig economy social security fixed-term employment gratuity

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References

FLSA. (1938). Fair Labor Standards Act of 1938, 29 U.S.C. § 203 .

FMLA. (1993). Family and Medical Leave Act of 1993, 29 U.S.C. §§ 2601–2654.

Gazette of India. (2019). The Code on Wages .

Gazette of India. (2020a). The code on Industrial Relations Code .

Gazette of India. (2020b). The Code on Social Security .