GRAP Alert for Gurugram Employers: Running Your Private Office at 50% Attendance (5–20 November 2026)

Nov 4, 2026

From 5 November to 20 November 2026 (both days inclusive), every private office in District Gurugram must run with no more than 50% of its staff attending physically. The rest must work from home.

The Office of the Deputy Commissioner, Gurugram issued this direction by Order No. 5392/MB dated 03.11.2026. It implements CAQM Order No. 120017/27/GRAP/2021/CAQM-1991(A) dated 30.10.2026, issued under Section 12 of the Commission for Air Quality Management in NCR and Adjoining Areas Act, 2021. The CAQM has specifically named Gurugram among the districts where offices must cut physical attendance, citing a recurring pattern of 'Severe' and 'Severe+' AQI in early to mid-November.

The order takes effect tomorrow. This note explains what private employers must do, who is exempt, who will inspect, and gives a roster format you can adopt today.

What the order requires of private establishments

Para (ii) of the order places four obligations on private offices in Gurugram:

1. 50% cap on physical attendance. Not more than 50% of the staff strength may attend the office physically on any day.
2. Work from home for the rest. The remaining staff must work from home. These are working days, not holidays.
3. Regulate working hours and attendance. Private establishments must adjust their working hours and attendance to meet the cap.
4. Keep the roster ready for inspection. The attendance roster must be available whenever an inspecting officer asks for it.

The order applies within the revenue limits of District Gurugram, urban and rural alike. Employers in other Haryana districts should check whether their own Deputy Commissioner has issued a similar order under the same CAQM direction.

Who is covered and who is exempt

The cap covers all private offices in the district: IT and ITeS companies, consultancies, banks and financial services, corporate and regional offices, back offices and shared service centres, and professional firms.

Para (ii)(c) exempts industrial establishments and essential services where the 50% arrangement is not feasible. Read this carefully:

• The exemption turns on feasibility, not on the label. A factory's administrative or corporate office that can work remotely is arguably still an office and should follow the cap.
• Shop-floor, production, maintenance, security, utilities and similar roles that cannot be done from home fall within the exemption.
• The order does not list 'essential services'. Hospitals, emergency services, utilities and similar operations are the safe reading; anything else should be justified on record.

If you rely on the exemption, record why in a short internal note signed by the head of the establishment. That note is your first answer to an inspecting officer.

Separately, para (i) restricts dust-generating demolition and outdoor construction across the district. Private developers and contractors should treat that as a distinct compliance obligation.

Who will enforce it, and what non-compliance can cost

The Deputy Labour Commissioner, Gurugram and the General Manager, District Industries Centre (DIC), Gurugram are responsible for the 50% cap in private offices. Field monitoring rests with the Sub Divisional Officers (Civil) and the Regional Officers of the Haryana State Pollution Control Board, who will inspect daily. The Commissioner of Police, Gurugram has been asked to assist.

Every enforcing officer must file a daily action taken report by 5:00 PM listing sites inspected, violations found and action taken. Expect inspections to be frequent and documented.

Any person or establishment violating the order is liable to action under Section 14 of the CAQM Act, 2021 and other applicable laws. Beyond the statutory penalty, an inspection finding can lead to further notices and scrutiny of the establishment, so a clean roster matters.

Compliance checklist for private employers

Complete these before the office opens on 5 November:

?Fix your staff strength. Count everyone on the rolls of the Gurugram office, including contract and outsourced staff deployed there. The order does not define 'staff strength', so the wider count is the safer one.
? Calculate the daily cap. 50% of staff strength, rounded down. For 75 staff, the cap is 37 per day.
? Classify roles. Mark each role as office-based (cap applies) or exempt (cannot be done remotely), and record reasons for every exempt role.
? Issue an internal circular. Signed by the head of the establishment, citing DC Gurugram Order No. 5392/MB dated 03.11.2026, the period, the roster system and WFH expectations.
? Prepare and circulate the roster. Use the format below. Share it with employees at least a day in advance.
? Regulate working hours. Stagger reporting times if needed to keep the floor within the cap at any point in the day.
? Record actual attendance daily. Use biometric or access-card logs and reconcile them with the roster each evening.
? Keep records at the front desk. The circular, roster, daily attendance and exemption note should be with the admin or HR lead, in print or on a device, for any inspection.
? Brief the reception and security team. They should know whom to call and what to show when an officer visits.
? Address WFH basics. Laptops, VPN access, data security, reporting lines and working hours for employees working from home.
? Talk to your landlord or co-working operator. Shared premises may face common inspections; align on who holds which records.
? Keep salary and leave unaffected. WFH days count as normal working days. No leave should be deducted for rostered WFH.

Suggested Attendance Roster Format

The simplest compliant model splits office-based staff into two groups that attend on alternate working days. The format below has five parts; print them on the establishment's letterhead and keep them together.

Part A: Establishment details

Part B: Group allocation

Part C: Day-wise schedule

The sample assumes a Monday to Friday week; adjust for Saturdays and any holidays declared by the establishment.

If you claim no exemption, keep each group at or below half the staff strength. If some staff are exempt and still attend, they should be counted in the daily number unless your exemption note clearly explains why they fall outside the cap.

Part D: Exempt staff register

Part E: Daily attendance record and certification

Certified that physical attendance at this office during 05.11.2026 to 20.11.2026 has been regulated in compliance with Order No. 5392/MB dated 03.11.2026 of the Deputy Commissioner, Gurugram.

Signature, name and designation of the head of the establishment, with date and seal.

Alternatives to the alternate-day model: department-wise rotation (useful where whole teams must sit together), or fixed half-week blocks (Group A Monday to Wednesday morning, Group B Wednesday afternoon to Friday) with staggered hours. Whatever the model, the daily headcount must stay within the cap and the roster must show it.

Common questions from employers

Our registered office is in Delhi but we have a team in Gurugram. Does this apply? Yes, to the Gurugram premises. The order turns on where the office is situated, not where the company is registered.

We are in a co-working space. Who is responsible? Each establishment is responsible for its own staff. Keep your own roster; do not rely on the operator's records.

Can we ask employees to take leave instead of working from home? The order directs that the remaining staff 'shall work from home'. Forcing leave in place of WFH would go against its spirit and invite employee grievances.

Does the 50% include contract and outsourced staff? The order does not say. Counting them in staff strength and in daily attendance is the safer course, since inspectors will see everyone present on the floor.

Our client wants our deployed staff at their Gurugram site. The client's premises are subject to the cap. Coordinate with the client so your staff are reflected in its roster.

Can the order be extended? Yes. It runs till 20.11.2026 'unless withdrawn or modified earlier', and GRAP measures are often revised with AQI. Keep the roster system ready to extend.

Closing note

The order is short, but inspections will be daily and the roster is the first document an officer will ask for. A signed circular, a clear roster, daily attendance records and a reasoned exemption note will answer most questions at the door.

This note is for general information and does not constitute legal advice. It is based on Order No. 5392/MB dated 03.11.2026 of the Deputy Commissioner, Gurugram. Employers should check for any later modification or withdrawal of the order.

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