Muster roll and attendance register rules in India: what a small employer must keep

A muster roll is one of the oldest records in Indian labour law: one row per employee, showing who was at work on each day of the month. It is still required in 2026; what has changed is the rulebook behind it. The four Labour Codes came into force on 21 November 2025, the central rules under the Code on Wages followed on 8 May 2026, and the states are now writing their own.

What a muster roll is, and who has to keep one

In practice "muster roll" and "attendance register" mean the same thing: the employer’s month-by-month record of each person’s attendance. The duty now sits in Section 50(1) of the Code on Wages, 2019, which requires every employer of an establishment the Code covers to maintain a register of the persons employed, the muster roll, wages and other prescribed details. The only carve-out in that section is for someone employing no more than five people for agriculture or domestic purposes, and "domestic" expressly excludes a business. A consultancy, agency or clinic with even a handful of staff is not exempt.

(MGNREGA muster rolls, where worksite attendance goes through the government’s NMMS app with geo-tagged photographs, belong to a public scheme, not an employer, and are not covered here.)

Which rules require it, old and new

For decades the format came from central rules made under the old Acts. The Minimum Wages (Central) Rules, 1950 prescribed a daily muster roll in Form V (rule 26(5)). In February 2017 the Ease of Compliance to Maintain Registers under various Labour Laws Rules, 2017 (G.S.R. 154(E)) folded the registers required under nine central laws into five combined forms, A to E, with Form D as the attendance register. For many employers they applied only once their state adopted them.

On 8 May 2026 the Centre notified its rules under the Code on Wages (G.S.R. 343(E)), in force from the date of publication. They supersede the Minimum Wages (Central) Rules, 1950 and the 2017 combined registers for the minimum-wages, payment-of-wages and equal-remuneration laws. Rule 51 now prescribes three registers: Form I, the employee register; Form IV, the register of wages, overtime, advances, fines and deductions; and Form IX, the attendance register-cum-muster roll.

The catch for a private firm is that these central rules apply directly only where the Central Government is the "appropriate government": railways, mines, oilfields, banking companies and establishments run by or under the Centre. For an ordinary office the state is the appropriate government, and its existing rules continue until it notifies its own rules under the Code on Wages. States are moving at different speeds; Uttar Pradesh, for example, notified its Code on Wages rules on 12 August 2026.

Your state’s Shops & Establishments Act still applies on top. Maharashtra and Haryana have stopped requiring a separate S&E registration for establishments registered under the OSH Code, but in both states the rest of the Act, including hours, leave and the maintenance of records, continues wherever it is not inconsistent with the Code. Maharashtra’s 2018 rules, for instance, require a combined muster-roll-cum-wages register in Form Q and a leave book in Form O.

What the register must record

Going by the central Form IX, an attendance register-cum-muster roll carries, for each employee: an employee code, name and designation; the shift and the place of work or department; a day-by-day attendance record for the month; the total number of days worked; the total overtime hours worked; and brief details of any tour or assignment outside the workplace. Overtime pay, advances and deductions belong in the wage register (Form IV), not the muster roll.

Leave usually has its own record, such as Maharashtra’s leave book. Your state’s form may name its columns differently, but expect to show who worked, on which shift, on which days, and how much overtime.

Can you keep it digitally?

Yes, in every set of rules we checked. Rule 51(1) of the 2026 central rules lets an employer maintain registers "electronically or in physical form" in the appended formats. The 2017 combined-register rules allowed electronic registers too, and Maharashtra’s S&E rules let entries be authenticated digitally or manually.

Two conditions come with that. Electronic is a medium, not a format: the register still has to carry the particulars your state’s form asks for. And you must be able to produce it, or give access to it, when an Inspector-cum-Facilitator asks. A shared spreadsheet that anyone can overwrite is hard to defend on either count.

How long to keep it, and the penalty

The 2026 central rules require registers to be preserved for five years after the date of the last entry (rule 51(4)). State rules set their own periods, so check yours.

Under Section 54(2) of the Code on Wages, not maintaining records, or maintaining them improperly, is punishable with a fine of up to Rs 10,000. Section 54(3) builds in a first chance: the Inspector-cum-Facilitator must first give a written direction with time to comply, and no prosecution follows if you do, unless it is a repeat of the same violation within five years.

What a 20-person firm should actually do

• Work out whose rules you are under. Almost certainly your state’s. Check whether it has notified Code on Wages rules and which forms they prescribe; if not, its existing rules continue.
• Keep the core set together. An employee register, the attendance register or muster roll, the wage register and a leave record, in your state’s formats.
• Record attendance daily. Not from memory at month-end. Note overtime when it is worked; Maharashtra’s rules require exactly that.
• Go digital, but be able to print. You should be able to produce the register in the prescribed format the day an inspector asks.
• Keep five years of history. That is the central-rules period, counted from the last entry; follow your state’s period where it differs.
• Finish the rest of Section 50. Display the required notice (an abstract of the Code, wage rates, wage period and pay day, and the inspector’s details) and give every employee a wage slip on or before payday.
• Correct mistakes openly. Record the correction and who approved it, rather than quietly editing the day.

At twenty people it is also worth checking where you stand on PF and ESI.

Where HireMaze fits. HireMaze keeps the daily record a register is built from. Your team checks in from their phones against their shifts, with no biometric device or shared register; leave balances update themselves; a forgotten punch becomes a regularisation request; and roles mean each manager sees their own team. At month-end there is a month view of who worked and an export for whoever runs payroll. That export is the raw daily record, not Form IX or any other prescribed format. HireMaze does not file anything with a government portal, run payroll or make a firm compliant; it gives you clean data to keep your register in your state’s format.

Frequently asked questions

Is a digital attendance register legal in India?

Yes, under the rules we checked. The 2026 central rules under the Code on Wages allow registers to be kept electronically or in physical form. The register must still carry the particulars your state’s form prescribes, and you must be able to produce it when an inspector asks.

What is the muster roll format under the Labour Codes?

In the central rules notified on 8 May 2026 it is Form IX, the attendance register-cum-muster roll. Most private firms come under their state’s rules, so use the form your state prescribes; until a state notifies its own Code on Wages rules, its existing rules continue.

Is Form V still the muster roll?

Form V was the muster roll under the Minimum Wages (Central) Rules, 1950, which the 2026 central rules have superseded. In the 2026 central rules, Form V is the wage slip and the muster roll is Form IX. A state that has not yet notified new rules may still use its older forms.

How long must an attendance register be kept?

The 2026 central rules require registers to be preserved for five years after the date of the last entry. State rules can set their own period, so check the rules that apply to your establishment.

Does a firm with fewer than ten employees need a muster roll?

Yes. Section 50 of the Code on Wages sets no headcount threshold for a business; the only carve-out is for employing up to five people for agriculture or domestic purposes. Your state’s Shops and Establishments rules may add requirements of their own.