What PSARA Actually Regulates
The Private Security Agencies (Regulation) Act 2005 is the licensing law for anyone who provides security guards or supervisors to others for a fee. It does not set wages or working hours; those come from the Minimum Wages Act, the Code on Wages, the Shops and Establishments Acts and the Contract Labour framework. What PSARA does is make holding a licence conditional on complying with all of those, and it gives the state Controlling Authority the power to inspect, suspend and cancel.
Every state has its own PSARA rules made under the central Act, and the Private Security Agencies Central Model Rules 2020 are the template most states have adopted or adapted. The licence is issued per state, and within a state it may be issued for one district, several districts or the whole state. An agency operating in Haryana and Delhi needs two licences from two Controlling Authorities, each with its own renewal date.
Compliance is therefore a stack: licence conditions on top, guard eligibility and training in the middle, and labour-law and statutory compliance underneath. The checklist in this article works down through the stack. The PSARA glossary entry has the short definitions if you need to brief a client.
- PSARA licenses the agency; labour laws set wages and hours; the licence depends on both
- One licence per state; district, multi-district or state-wide scope
- Central Model Rules 2020 are the template most state rules follow
- Controlling Authority (usually a senior police or home department officer) inspects and renews
- Non-compliance with wage or PF law is a ground for licence action, not only a labour claim
Licence: Application, Validity, Renewal and Display
A PSARA licence is valid for five years and is renewable on application before expiry, with a window and a fee that vary by state. The application requires details and police verification of the proprietor, partners or directors, proof of a registered office, a training arrangement with a recognised institute, and an undertaking to comply with the Act. Directors with certain criminal antecedents or links to disqualified organisations cannot hold a licence.
Once issued, the licence must be displayed conspicuously at the registered office and at each branch office covered by it. Guards deployed at client sites should carry an agency ID card that references the licence number. Clients are increasingly asking for a copy of the licence in the tender stage and at each renewal; keep a current scanned copy ready.
Renewal is where record-keeping pays off. The Controlling Authority may ask for the guard register, training records, verification files, wage records and evidence of PF and ESI compliance for the licence period. An agency that files these month by month renews in weeks; one that reconstructs them renews late and risks a lapse during which it cannot lawfully deploy anyone. The guide to starting a security agency covers the first application in detail.
- Licence valid 5 years; apply for renewal well before expiry per your state's window
- Display the licence at the registered office and every branch
- Guard ID cards should carry the agency name and licence number
- Keep a current copy for client tenders and audits
- File compliance records monthly so renewal is a compilation, not a reconstruction
The Section 15 Register
Section 15 of PSARA requires every licensed agency to maintain a register in the prescribed form. It must contain the names, addresses, photographs and salaries of every private security guard and supervisor under the agency's control, the names and addresses of the persons who manage the agency, the names and addresses of the clients the agency serves, and any other particulars the state rules prescribe. The register must be available for inspection by the Controlling Authority or a person authorised by it.
In practice this means the guard master, the management list and the client list have to exist as a single coherent record, and the salary column has to match what the payslip and the wage register show. An inspector who finds a guard on a client site who is not in the register, or whose register salary is lower than the minimum wage, has found two violations at once.
Most agencies maintain the register in Excel or a bound book. Either is acceptable if it is current and complete. A digital employee database that stores photographs, addresses, wage details, deployment site and verification documents against each guard produces the section 15 register as an export, and updates it every time a guard joins, moves site or leaves. The attendance register rules article explains how the attendance record ties into this.
- Guards and supervisors: name, address, photograph, salary
- Management: names and addresses of proprietor, partners or directors
- Clients: names and addresses of every establishment served
- Any additional particulars required by the state rules
- Open to inspection at any time; keep it current, not month-end current
Guard Eligibility, Verification and Training
PSARA sets the eligibility conditions for guards: Indian citizenship (or citizenship of a country with reciprocal arrangements), a minimum and maximum age, satisfactory character and antecedents, the prescribed training, and physical fitness standards set by the rules. The agency must verify antecedents before deployment, which in practice means police verification through the local station or the state's online character verification portal, plus reference and previous employer checks. The background and police verification article walks through the process.
Training under the Central Model Rules 2020 is 100 hours of classroom instruction and 60 hours of field training for a fresh guard, delivered through a recognised training institute or the agency's own approved facility. Ex-servicemen and former police personnel qualify for a shorter condensed course. Supervisors need additional training. Certificates should be kept on the guard's file with the institute's registration details.
The common failure is deploying a guard the day he is recruited, with verification 'in process' and training 'scheduled'. Both are licence conditions, not paperwork. Agencies with a real reliever pool can absorb the lag between recruitment and clearance; agencies without one are always tempted to skip it.
- Citizenship, age band and physical standards per the Act and state rules
- Antecedent and police verification completed before first deployment
- 100 hours classroom + 60 hours field training for fresh guards (Model Rules 2020)
- Condensed course for ex-servicemen and ex-police; extra modules for supervisors
- Training certificates and verification reports on each guard's file
Wage and Statutory Compliance
The licence conditions require compliance with minimum wage law, EPF and ESI. That means every guard is paid at least the notified basic plus VDA for the skill category and zone of the site, PF is deducted and deposited at 12% of basic plus DA up to the ₹25,000 ceiling in force since 17 September 2026, and ESI is deducted and deposited at 0.75% employee and 3.25% employer for guards with wages up to ₹21,000. Monthly ECR and ESIC payments are due by the 15th of the following month.
Beyond the three named in the licence conditions, the agency is also subject to the Payment of Bonus Act (minimum 8.33% for guards with basic plus DA up to ₹21,000 who worked 30 days), the Payment of Gratuity Act (after five years of continuous service), professional tax where the state levies it, and labour welfare fund contributions where applicable. Overtime beyond normal hours must be paid at twice the ordinary rate. The security guard salary calculation article shows how these fit together on a payslip.
A Controlling Authority does not audit payroll in detail, but it does ask for evidence: PF and ESI challans for the licence period, sample payslips, and wage registers. A client's auditor, or a labour inspector under the Contract Labour framework, will go deeper. Preparing the payroll from recorded attendance with the statutory settings configured once removes most of the risk.
- Minimum wage: basic + VDA by category and zone, updated on each revision
- EPF 12% + 12% up to ₹25,000; ECR by the 15th
- ESI 0.75% + 3.25% up to ₹21,000; payment by the 15th
- Bonus, gratuity, PT and LWF as applicable; overtime at 2x
- Keep challans, payslips and wage registers per month for the licence period
Records Inspectors and Clients Ask For
The three records that must reconcile are attendance, deployment and invoices. Attendance shows which guard was on which post on which day; deployment shows which guards were assigned to which client; invoices show what the client was billed. If a client was billed for 10 guards and attendance shows 8, or attendance shows a guard on a site where he was never deployed, the agency has a billing dispute and a compliance gap at the same time.
Inspectors typically ask for the licence, the section 15 register, verification and training files for a sample of guards, wage registers and payslips, PF and ESI challans, and client agreements. Clients ask for a subset of the same plus site attendance and man-hour statements. Keeping these in one place, organised by month and by site, is the difference between a one-day inspection and a two-week one.
Uniforms and ID cards are part of the record too. The Act and rules prescribe that guards wear the agency's uniform, distinct from police and military uniforms, and carry a photo ID issued by the agency. An inspector checking a site will ask a guard to produce the card and will compare it against the register. Digital ID cards issued from the employee database, with the licence number printed, make this a non-event.
- Attendance, deployment and invoice for each site and month must reconcile
- Licence, section 15 register, verification and training files, wage records, challans, client agreements
- Site attendance and man-hour statements for client audits
- Uniform compliance and photo ID cards referencing the licence
- Organise everything by month and site so any sample can be pulled in minutes
Monthly Compliance Calendar and Checklist
Compliance under PSARA is not an annual event. The licence is five-yearly, but the evidence it depends on is generated every month. The list below is the working checklist most well-run agencies follow; adapt the dates to your state's rules and your payroll cycle.
Digital attendance and deployment records change the effort involved. When guards mark attendance with GPS and a selfie at the post, the site attendance, the man-hour statement and the payroll input are the same record. When deployment is recorded per site and post, the section 15 client list and the deployment plan are the same record. Attend Mitra's security guard deployment management software maintains site-wise deployment, guard attendance with GPS and selfie, and site-wise man-hour exports, so most of the checklist below is an export rather than a task.
- By the 7th: wages for the previous month paid; payslips issued showing basic, VDA, OT and deductions
- By the 15th: PF ECR filed and paid; ESIC contribution paid; challans filed by month
- Monthly: section 15 register updated for joiners, leavers and site changes
- Monthly: site attendance reconciled to deployment plan and to client invoice
- Monthly: verification and training status checked for all guards deployed in the month; no unverified guard on post
- April and October (or your state's cycle): minimum wage revision applied; arrears paid; client rates revised
- Quarterly: uniform and ID card audit at a sample of sites
- Annually: bonus paid within 8 months of the accounting year close; gratuity provision reviewed
- Twelve months before expiry: renewal file compiled; police verification of directors refreshed if required