What a French fine on Infosys reveals about different ways India and Europe think about work

But the fine matters more than its size. France polices something India does not: not the number of hours an employee works, but whether anyone can actually prove what those hours were. Under French law, employers must accurately track working time, including compliance with the country’s 35-hour statutory week, overtime ceilings, and mandatory rest. The obligation is not simply to keep a register, but to demonstrate, if asked, that the record is trustworthy.

That distinction sits at the heart of a question India has spent the past two years arguing about, mostly without resolving: why do some countries treat working hours as something the law must protect, while in India, working long hours is still, in large parts of the corporate world, treated as a virtue?

A familiar argument, revived

The debate has an obvious recent trigger. Infosys founder N R Narayana Murthy has spent much of the past two years arguing that Indian professionals should work 70-hour weeks, a figure he has since revised upward to 72, explicitly invoking China’s ‘9-9-6’ culture of 9 am to 9 pm, six days a week.

In a podcast back in 2023, he mentioned, “India’s work productivity is one of the lowest in the world. Unless we improve our work productivity, we will not be able to compete with those countries that have made tremendous progress.” China’s own Supreme Court declared the 9-9-6 schedule illegal in 2021, a detail that rarely features in the version of the argument repeated in India.

Murthy is not alone in holding this view. His comments matter here only because they represent, in their most public form, an idea that shapes Indian workplaces long after the debate has moved on: that hours worked are a reasonable proxy for value created. Whether that idea survives contact with evidence is a separate question, one that research, and the people living inside these systems, can help answer.

What the evidence shows

Two strands of research help frame what is otherwise an argument conducted mostly in anecdote and opinion.

The first is the WHO/ILO Joint Estimates of the Work-related Burden of Disease and Injury, published in Environment International in 2021 by Frank Pega and a Technical Advisory Group. Drawing on data from nearly 2,400 surveys across 194 countries, the study estimated that in 2016, 488 million people worldwide were working 55 hours a week or more – the threshold at which WHO and ILO’s expert reviewers judged there was sufficient evidence of elevated risk of ischaemic heart disease and stroke, compared with people working a standard 35-40 hour week.

The paper attributed roughly 7,45,000 deaths globally to that exposure in a single year. It is worth being precise about what this shows and does not: this is population-level, exposure-based epidemiology built from observational data rather than controlled experiments, and the authors frame it as an association carrying “sufficient evidence” rather than a proven mechanism. But the scale and consistency of the finding across so many countries is difficult to dismiss as noise.

The second study is closer to home. In 2024, Guruprasad Vinod and Srikant Ambatipudi, writing in the Annals of Occupational and Environmental Medicine, surveyed 282 bank employees in Kollam district, Kerala, using standardised instruments to measure burnout and stress. They found that 82.2 per cent of respondents showed moderate to high burnout, and just over a quarter reported clinically significant stress. Longer average daily working hours were independently associated with higher odds of both, even after adjusting for other factors.

Read together, the two studies point in the same direction without proving identical things: one shows a plausible biological cost to sustained overwork at a global scale, the other a measurable psychological one, inside an ordinary Indian workplace. Neither claims hours alone explain burnout or illness – culture, job control and financial insecurity all mediate the relationship. But both make it harder to treat ‘working longer’ as a cost-free choice.

Working hours around the world: See how India’s statutory framework stacks up against France, the United Kingdom and the United States. (Source: Khubi A. Agrawal, Advocate – Labour, Employment & Corporate Laws)

What the law actually requires

 If the research describes the cost of long hours, the law describes who is meant to prevent it.

Gyanendra Kumar Mishra, a partner at Dentons Link Legal, points out that India already limits most employees to nine hours a day and 48 hours a week, with mandated overtime pay and a weekly rest day, under the Factories Act, 1948, various State Shops and Establishments Acts, and the still-not-fully-implemented Occupational Safety, Health and Working Conditions Code, 2020. “However, timekeeping requirements are relatively flexible. By contrast, France (35-hour workweek), Germany (generally 8 hours per day, extendable subject to statutory conditions) and the UK (48-hour weekly average, subject to individual opt-out) impose far stricter obligations to monitor actual working time and demonstrate compliance through reliable records,” he tells indianexpress.com.

Khubi A Agrawal, an advocate specialising in labour and employment law, frames a comparative table that makes the gap concrete. France requires overtime pay of 25 per cent above the ordinary rate for the 36th to 43rd hour and 50 per cent thereafter, capped at 220 overtime hours a year, alongside mandatory 11-hour daily and 24-hour weekly rest. India’s OSH Code, in force since November 2025, doubles ordinary wages for eligible overtime but sets no central statutory minimum rest between shifts. The UK caps hours at 48 a week, averaged over 17 weeks, with an individual opt-out; the US has no federal cap on hours at all, only a requirement to pay 1.5 times the ordinary rate beyond 40 hours for eligible workers.

“The challenge is less about the law and more about enforcement and workplace culture. IT, consulting, and professional services businesses often serve global clients across multiple time zones, creating expectations of extended availability. In addition, senior managerial employees may fall outside certain working-hour protections, inspections are less frequent in white-collar sectors than in factories, and many organisations rely on output rather than actual hours worked. Consequently, statutory limits do not always translate into workplace practice,” shares Mishra.

What it looks like from inside

Nikita Raj Raikwar, 32, a freelance content marketing manager, was officially expected to work from 6 pm to 3 am to cover a Canadian shift, but says she routinely worked from 2 pm to 4 am to remain available across Indian, West African and US Eastern time zones at once. “It’s 3.30 in the morning, and I’m asked to work on something urgent,” she recalls, describing being told to deliver by “EOD” (end of day) without acknowledgement that her own day had ended hours earlier. She initially believed the extra hours would make her indispensable.

“Even after slogging over 12 hours daily, founders were wondering what I did,” she says, adding that she was made to maintain three separate trackers for the same work. She has since restructured her days around short, deliberate sprints and is unambiguous about the argument that started this piece: “I think the Murthy 70-hour work week is a flawed concept and one that can lead to insane burnout. Trust me, I know.”

Tanusha, 22, who spent two years in consulting before moving industries, describes a workplace where the official end time of 5.30 or 7 pm was fiction. “You left when the work, or the room, allowed it,” she says, estimating her real week at 45 to 50 hours or more. What stayed with her was the language used to justify it: leadership called it “hustling”, which in practice meant “sacrificing personal time for work” and “being yes people to senior leadership.” Leaving on time, even with her work finished, “read as a lack of dedication rather than efficiency” – a perception that carried directly into appraisal conversations. She also names a cost rarely discussed in these debates: “lower back pain, locked shoulders, poor posture, weight gain.”

Ajay Tomar, 25, whose official week already runs to 54 hours across six days, put the underlying incentive most bluntly: “There was more pressure to look busy than to deliver results. At that time, I understood why it’s called a performance review and not work feedback.”

Priyanka Dalal Arya, who has spent three years working in the UK after 14 years across two countries, provides a counterpoint. Her seven-hour day, she says, is exactly what it appears on paper to be. “I have never received a call or even a message after working hours or on weekends,” she says, noting an email sent over a weekend “can be considered rude.”

Staying visibly late in her current workplace is read not as commitment but as inefficiency. She credits part of this culture to unionisation among junior and mid-level staff in the UK, and argues India needs something similar: “I have seen endless examples of employees being exempted from even their basic rights because leadership knows that going to court for legal rights will take a lot of time and resources.”

How do India’s working-hour rules compare with France, the UK and US? (Source: Canva)

Why guilt persists even without pressure

Pratishtha Trivedi Mirza, a senior clinical psychologist at Amaha, argues that chronic overwork produces “a particular kind of depletion that rest alone doesn’t repair,” keeping the nervous system in sustained activation and gradually eroding concentration, decision-making and emotional regulation, the very faculties, she notes, that make someone good at their job. The guilt so many employees describe about logging off on time, she says, is rarely about the work itself: it is about what availability is believed to signal about commitment and worth, a message absorbed from culture even when no manager has said it aloud. “The person has already internalised the expectation and is enforcing it on themselves,” she says – which is precisely why policy alone rarely fixes it.

Gurleen Baruah, an organisational psychologist at That Culture Thing, frames the same phenomenon through what she calls the gap between an organisation’s written and lived culture. “Every organisation has two cultures: the written culture and the lived culture. On paper, the workday may end at 6 pm, but if employees see promotions, recognition, and appreciation going to those who stay late or are always available, that becomes the real rule.”

She cites Cal Newport’s Deep Work to make a related point, noting, “Knowledge work depends on uninterrupted, high-quality focus rather than simply spending more time at work. In many cases, working longer becomes counterproductive because the quality of thinking declines. It’s not just about how long we work, but how well we can think while working.” Baruah also points out that constant availability can tip into what she calls workaholism, sometimes less a matter of loving work than of using it to avoid difficult emotions elsewhere.

The view from HR

If psychologists explain why the guilt persists, HR leaders are left managing the culture that produces it. Dr Balasubramanian Sethuraman, an HR professional, notes, “Working hours often reflect culture more than capability. In India, commitment is frequently measured by visibility… In Europe, they optimise for sustainability.” His diagnosis of what actually changes a culture is not a policy document but leadership behaviour: “If a CEO sends emails at midnight and expects responses, no wellness initiative will fix that culture.”

He is equally sceptical that hours and output move together: “Hours and productivity have a surprisingly weak relationship. Beyond a point, every additional hour delivers diminishing returns.” His preferred remedy is organisational rather than individual; treating overtime as a business metric to be investigated, not a badge of loyalty to be rewarded, and, as he states, aiming “not to reduce work, but to reduce avoidable work.”

What to do

“Clear boundaries create a level playing field,” says Baruah, adding that when employees know they won’t be judged by how late they stay or how quickly they reply after work, the focus shifts from performative busyness to meaningful outcomes.

“Work becomes about delivering on clear goals, KRAs, and OKRs rather than constantly proving commitment through visibility. And from a psychological lens too, boundaries allow people to recover, reconnect with other parts of their lives, and return to work with fresh energy and ideas. Organisations benefit too. Employees who have time to rest and think often make better decisions, collaborate more effectively, and produce higher-quality work,” concludes the expert.