India: Indian Government Introduces the Private Placement Agency (Regulation) Bill, 2025

Authors: Avik Biswas, Ivana Chatterjee, and Kevin Kennedy

On 14 August 2025, the Central Government introduced the Private Placement Agency (Regulation) Bill, 2025 to bring private placement agencies under mandatory registration and oversight. The Bill establishes state and central authorities, requires private placement agencies to report placements on the Integrated Career Services portal, seeks to protect jobseekers and ensure transparency in domestic and overseas placements, and prescribes penalties for fraud and non-compliances, amongst other things.

The rapid expansion of private placement agencies in India has created both opportunities and vulnerabilities in the labour market. These agencies have long served as intermediaries linking jobseekers with employers, domestically and abroad. However, due to the absence of a comprehensive regulatory framework, such private placement agencies have also been associated with fraudulent practices, excessive charges, and a lack of accountability. It is against this backdrop that the Central Government has introduced the Private Placement Agency (Regulation) Bill, 2025 (“Bill”), seeking to impose order, transparency, and uniform oversight across the sector. The Bill is currently in the draft stage, and the Central Government has invited comments and suggestions from relevant stakeholders.

 

The Bill defines a ‘private placement agency’ as any individual, group, or legal entity engaged in recruitment or placement activities for Indian jobseekers, whether for employment within the country or abroad. However, the term ‘Indian jobseekers’ has not been defined in the Bill. The definition expressly excludes government bodies, underscoring that the legislation targets private intermediaries operating in this sector. Importantly, the scope covers agencies working on behalf of both private and public employers, reflecting the recognition that recruitment is increasingly outsourced even by public sector entities.

 

The key provisions of the Bill have been summarised below:

• The Bill mandates registration for all private placement agencies, allowing a six-month compliance period from the date of its enactment. The registration is valid for a period of five years.
• Private placement agencies operating within a single state will fall under the jurisdiction of State Placement Support Authorities, while those working across multiple states will be regulated by a Central Placement Support Authority. These bodies are vested with powers of registration, inspection, and oversight, as well as the authority to suspend or cancel registrations where violations occur. They are also mandated to address grievances, though the precise procedures for redressal will only be clarified once detailed rules are issued. The Bill further brings overseas recruiters into its fold by linking them with the Ministry of External Affairs’ emigration oversight, that brings about additional compliance requirements.
• The Bill requires registered private placement agencies to ensure that all jobseekers and employers availing its services are registered on the government’s Integrated Career Service Portal. However, the Bill is silent on the specific compliance obligations in this regard.
• The Bill requires private placement agencies to maintain digital records of candidates and employers by uploading placement details such as career service identification numbers, the nature of placement and the date of commencement of employment onto the Integrated Career Service Portal. For placement outside India, the proposed date of departure must also be uploaded prior to the initiation of the emigration clearance process.
• The Bill requires agencies to take reasonable steps to safeguard the welfare of placed job seekers, particularly those in vulnerable segments such as blue-collar and unorganised employment, and to align their operations with government-supported platforms for career counselling, skill development, and employment facilitation.
• The Bill sets out a wide spectrum of offences for non-compliances such as operating without registration, engaging in fraudulent or exploitative practices, failing to disclose placement details, or obstructing inspections. The penalties escalate in proportion to the seriousness of the violation, ranging from monetary fines and temporary suspension of registration up to imprisonment of up to three months. Importantly, the framework extends liability to officers in charge of a company, who may only avoid sanction by demonstrating that they exercised due diligence.

Key Action Points for Human Resources and In-house Counsel

Organisations that may qualify as private placement agencies should closely monitor the progress of the Private Placement Agency (Regulation) Bill, 2025, to anticipate potential compliance obligations that could arise once it is enacted and the accompanying rules are notified. Organisations relying on private placement agencies currently do not have any compliance obligations under the proposed framework. However, they may need to verify registration status once the framework is in force, revise contracts to include applicable warranties and indemnities, and ensure systems are in place to provide accurate data for reporting through the Integrated Career Service Portal. Attention should also be paid to prospective obligations concerning data protection and overseas placements. Early readiness will allow employers to adapt smoothly and demonstrate diligence when the Bill is enacted.