File factory returns in Tamil Nadu
Who this applies to
- You already hold, or are applying for, a factory licence. Renewing that licence is a different filing.
- The combined annual return in Tamil Nadu has been Form 22, under rule 100 of the Tamil Nadu Factories Rules, due by 31 January for the preceding calendar year.
- We have found no final Tamil Nadu rule or DISH circular naming the form and route for the return after 21 November 2025.
What the return is
Tamil Nadu has required a combined annual return in Form 22 under rule 100 of the Tamil Nadu Factories Rules, filed by 31 January for the preceding calendar year. DISH also built Form 22 into its self-certification scheme, and that scheme kept the return. Self-certification never removed it.
The Occupational Safety, Health and Working Conditions Code, 2020, in force since 21 November 2025, keeps the duty: an employer must file returns with the Inspector-cum-Facilitator, electronically or otherwise, in the manner and for the periods the appropriate Government prescribes (OSH Code, s.33(d)). For a private factory in Tamil Nadu that is the State. We have found no Tamil Nadu rule under the Code prescribing the return, and until there is one, the old rule continues so far as it is not contrary to the Code (s.143(3)). What we have not found is a DISH circular confirming the form and the portal route it now expects. So the sensible course is to file the return through the route DISH accepts and write down that you relied on it. The wider transition is covered in our OSH Code guide.
Renewing the licence does not file this return, and the return does not renew the licence. Keep the two dates separate.
What it costs to get wrong
A missing return is a separate breach from an expired licence. Under the Code, failing to file a return required by the Code or the rules under it carries a penalty of not less than ₹50,000 and up to ₹1 lakh (OSH Code, s.96(1)). Whether that applies to a return required only by the saved rule 100 depends on reading section 143(3), which treats saved rules as made under the Code; we think it does, but no decision on the point has been found.
The practical cost arrives sooner. A renewal or an inspection stalls when the annual figures, the accident notices and the licensed particulars do not agree.
The process
Reconcile the year you are reporting
Check the headcount, including contract workers where the form asks for them, and check the process, power, buildings and machinery against the approvals. Reconcile accidents and dangerous occurrences with the notices already sent. Do not report the licensed maximum as if it were the actual employment figure.
Check the records the return sits on
Occupational health examinations, competent-person certificates for lifting machinery and pressure plant, leave and working-time records and welfare arrangements should all be current before you file. Hazardous-chemical and waste figures should match the MSIHC and TNPCB returns for the same period.
File through the route DISH accepts
Submit the return the portal currently offers and keep the acknowledgement. Portal acceptance is good evidence of what you submitted, but not proof that the underlying form has been finally settled. If the portal and the Code-era position appear to diverge, ask DISH in writing.
What else continues
The return is one duty among several. You still need to keep the licence and the approved plans current, maintain the prescribed registers and notices (OSH Code, s.33(a) and (b)), and report accidents, dangerous occurrences and occupational disease on the current channel. A hazardous-process factory also keeps its health and safety policy, emergency plan and drills up to date. None of those is discharged by Form 22.
Common failure points
- Treating licence renewal as the annual return. They are separate filings with separate dates.
- Leaving out contract workers where the form asks for them.
- Reporting one accident figure on the return and another on the notices.
- Assuming the self-certification scheme removed the return. It did not.
- Assuming a portal receipt settles the legal form for every later year. It records what you filed that year.
Unsure whether Form 22 is the return DISH still wants?
Send us last year's acknowledgement and your licence. We will separate the annual return from renewal, and tell you what to confirm with DISH before you file.