ESIC recovery: C-18 notices on wages above ₹20 lakh need Joint Director’s prior approval; recovery offices to move to district Branch Offices
Two ESIC Headquarters memoranda change how dues are assessed and recovered. From the memorandum of 7 August 2026, a C-18 notice involving wages or omitted wages above ₹20 lakh needs prior approval of the Joint Director (Revenue). By an Office Memorandum of 3 September 2026, revenue recovery offices are to be decentralised from Regional and Sub-Regional Offices to Branch Offices, preferably one in a district.
Key facts
- In force
- Memorandum dated 7 August 2026; Office Memorandum dated 3 September 2026 (phased implementation)
- Who it affects
- Employers covered under ESI who receive C-18 notices or recovery certificates; Insured Persons filing claims at Branch Offices; ESIC field offices
- What it is
- New facility
- Section
- Labour
- Published
- 3 September 2026
In 30 seconds
- Memorandum dated 7 August 2026: where a Joint Director is posted in addition to the Regional Director / Joint Director (I/c), that Joint Director handles Revenue and Recovery and is the appellate authority under section 126 of the Code on Social Security, 2020.
- A C-18 notice involving wages or omitted wages exceeding ₹20 lakh needs prior approval (assessment) of the Joint Director (Revenue) before issue.
- Multiple Recovery Officers are to be deployed in Regional and Sub-Regional Offices wherever possible.
- Office Memorandum dated 3 September 2026: recovery offices move to Branch Offices, preferably only one in a district.
- The officer posted there is designated “Recovery Officer-cum-Branch Manager” and also looks after faster decisions on Insured Persons’ claims.
- Roll-out is phased; a Recovery Officer should be able to execute 2–3 thousand certificates in a year.
हिंदी में सार
ESIC मुख्यालय के दो आदेश: 7 अगस्त 2026 के ज्ञापन के अनुसार ₹20 लाख से अधिक मज़दूरी/छूटी हुई मज़दूरी वाले C-18 नोटिस जारी करने से पहले संयुक्त निदेशक (राजस्व) की पूर्व मंज़ूरी ज़रूरी है, और वही संयुक्त निदेशक सामाजिक सुरक्षा संहिता की धारा 126 के तहत अपीलीय प्राधिकारी होंगे। 3 सितंबर 2026 के कार्यालय ज्ञापन से राजस्व वसूली कार्यालय क्षेत्रीय/उप-क्षेत्रीय कार्यालयों से शाखा कार्यालयों में — यथासंभव हर ज़िले में एक — चरणबद्ध तरीके से भेजे जाएँगे।
Two orders, one direction
ESIC Headquarters has issued two internal orders on revenue and recovery within a month. Both issue with the approval of the Director General.
7 August 2026: a second check on large C-18 notices
The memorandum (F. No. P-11/12/clarification on CoSS,2020/2025) says three things:
- In Regional and Sub-Regional Offices where a Joint Director is posted in addition to the Regional Director / Joint Director (I/c), that Joint Director is responsible for Revenue and Recovery, and is the appellate authority under section 126 of the Code on Social Security, 2020.
- Where a C-18 notice is proposed involving wages or omitted wages exceeding ₹20 lakh, prior approval (assessment) of the Joint Director (Revenue) is required before the notice is issued.
- Multiple Recovery Officers are to be deployed in Regional and Sub-Regional Offices wherever possible, for effective execution of recovery proceedings.
3 September 2026: recovery goes to the district
The Office Memorandum (No. Q-11/12/Restructuring/2026-RRC) records that the Director General has approved decentralisation of Revenue Recovery Offices from Regional / Sub-Regional Offices to Branch Offices, so that recovery is effected and certificates issued by Authorised Officers are concluded in a time-bound manner.
| Point | What the Office Memorandum says |
|---|---|
| Which Branch Office | Regional Directors and SRO in-charges identify Branch Offices where recovery dues and certificates are higher in number — preferably only one in a district |
| Who heads it | A “Recovery Officer-cum-Branch Manager”, who also manages the Branch Office and ensures better delivery of services, especially faster decisions on claims filed by Insured Persons |
| Social Security Officer | The officer posted in the area for Inspector-cum-Facilitator functions also works as Recovery Inspector and/or Deputy Manager of the Branch Office |
| Staff | Branch Office staff also work for the Revenue Recovery Office; additional staff if required |
| Coordination | The Recovery Officer at the Regional or Sub-Regional Office is the Coordinating Officer for the district Recovery Officers |
| Sub-Regional Office areas | Regional Directors consult SRO in-charges before posting Assistant Directors as Recovery Officers at the location decided by the SRO in-charge |
| Pace | Phased implementation, such that a Recovery Officer should be able to execute 2–3 thousand certificates in a year |
The Office Memorandum issues in consultation with the Financial Commissioner and Personnel & Administration. Neither document names the Branch Offices or gives a date by which the shift will be complete.
What employers should note
If a C-18 notice is proposed against your establishment for wages or omitted wages above ₹20 lakh, it should carry the Joint Director (Revenue)’s prior approval. Recovery certificates may, as the roll-out proceeds, be executed by a Recovery Officer sitting in a Branch Office in your district instead of the Regional or Sub-Regional Office.
Questions and answers
When does a C-18 notice need the Joint Director’s approval?
In all cases where the C-18 notice proposed involves wages or omitted wages exceeding ₹20 lakh, prior approval (assessment) of the Joint Director (Revenue) is required before the notice is issued.
Who is the appellate authority under section 126?
In Regional and Sub-Regional Offices where a Joint Director is posted in addition to the Regional Director / Joint Director (I/c), that Joint Director is the appellate authority under section 126 of the Code on Social Security, 2020.
Where will ESIC recovery offices now sit?
In Branch Offices identified by Regional Directors and SRO in-charges — those with a higher number of recovery dues and certificates, preferably only one in a district.
Has the shift already happened?
The Office Memorandum of 3 September 2026 says implementation is to be made in a phased manner for smooth transition. It gives no completion date.
Published 3 September 2026. Updated 6 October 2026. This report is for general information and is not professional advice. Read the source document before acting on it.