In May, the Ministry of Rural Development placed the draft rules under the Viksit Bharat – Guarantee for Rozgar and Aajeevika Mission (Gramin), or VB-G RAM G, in the public domain for comments, giving citizens and state governments around a month to submit feedback. The rules will determine how India’s new rural employment guarantee framework takes shape, and have significant consequences for workers.The government has presented VB-G RAM G as an expansion of the rural employment guarantee, mainly because the Act increases guaranteed work from 100 to 125 days. That increase is important. But the real question is whether the new framework preserves the demand-driven and rights-based character of MGNREGA, or risks turning the right to work into a fiscally managed and digitally mediated programme.Our reading is that the Act introduces several design features that could weaken a worker’s enforceable right to demand work. The draft implementation rules were expected to address these shortcomings, and provide strong safeguards. Instead, they leave several critical questions unanswered.Fund allocationThe most important issue is normative allocation. Under MGNREGA, the principle was that funds should flow to accommodate demand. If workers demanded work, the state was legally required to provide work, and the financing architecture had to respond. Under VB-G RAM G, the Union government will determine state-wise normative allocation every year and expenditure beyond that allocation will have to be borne by the state.This does not automatically mean that demand will be denied. But it changes the incentive structure. If additional demand means additional state liability, states and local officials may have reason to under-register demand, delay opening works, or avoid triggering unemployment allowance. The guarantee may remain formally intact while access to work is narrowed through budgeting and administration.The “Objective Parameters for Normative Allocation Rules” make this concern sharper. They say allocation will follow the 16th Finance Commission’s horizontal devolution formula, with additional performance indicators such as timely wage payment, social audit compliance and completion of works. But the rules do not clearly lay out the formula, weights, data sources, calculation method or process through which states and the public can scrutinise the allocation. A new allocation framework should have made the process more transparent and rule-bound. Instead, the draft rules leave too much discretion with the Union government.Also read: A Short History of MNREGA: 20 Years in Ten ChartsA fiscal devolution formula is also a poor fit for an employment guarantee law. Demand for work depends on distress, unemployment, drought, migration, landlessness, crop failure, local labour markets and administrative reach. Official data also cannot capture demand that was never registered.Sixth-day switch-off clauseThe Act also introduces a sixty-day no-work restriction during notified peak agricultural seasons. States are required to notify sixty days in a year, covering sowing and harvesting seasons, during which works under the Act cannot be undertaken. The Act permits different notifications for districts, blocks or Gram Panchayats, based on agro-climatic zones, local agricultural patterns or other relevant factors.Surprisingly, however, the draft rules are silent on how this window will be decided. What criteria will states use? At what level will the decision be taken? Will it be based on rainfall, cropping patterns, labour demand, migration patterns, or Gram Sabha inputs? Can workers or Gram Sabhas object if the notified period does not match local realities?These questions matter because the sixty-day window can directly affect access to the 125-day guarantee. Without clear parameters and a transparent consultation process, it may become a top-down administrative restriction rather than a locally informed employment calendar. The logic of the restriction itself also requires scrutiny. It assumes that workers seeking public employment are absorbed in private agriculture during sowing and harvesting seasons. That may not be true for landless workers, marginal farmers, women workers, Adivasi households and others who depend on public employment because private labour markets are unreliable.Transitional rulesThe Transitional Rules create another serious risk. Existing MGNREGA job cards are protected only if they have been renewed and verified through e-KYC. This can make e-KYC a condition for continuity of the right to work.Recent MGNREGA experience should make the government cautious. Large-scale deletion of job cards and workers from the MGNREGA database has already been acknowledged in official government communications, and the Union government has had to issue procedures for deletion and restoration. Under VB-G RAM G, transition cannot be left to digital verification alone. Existing MGNREGA job cards should remain valid until physical and local verification is completed. No worker should be excluded because e-KYC is pending, failed or inaccessible.Payment and grievance rulesThe Payment and Grievance Rules are also disappointing because digital technologies are no longer merely administrative tools under VB-G RAM G; they are built into the statutory architecture. The Act refers to biometric authentication, geospatial systems, mobile and dashboard-based monitoring, and technology-enabled transparency. One would therefore expect the rules to create clear mechanisms to resolve technical failures and fix accountability when such failures deny workers their rights.Instead, the Payment Rules make Direct Benefit Transfer, the Aadhaar Payment Bridge System (APBS) and MIS-based processing central to wage and unemployment allowance payments without adequately addressing what happens when payments are rejected, misdirected to unknown Aadhaar-linked accounts, blocked due to NPCI mapping issues or inaccessible because banking infrastructure is weak. Workers should have the right to receive wages in a bank or post office account of their choice. APBS should not become mandatory where it creates opacity or exclusion. Failed, rejected or misdirected payments should lead to automatic correction and compensation.Also read: No CAG Performance Audit of MGNREGA for 10 Years Poses Serious QuestionsThe Grievance Rules contain some positive provisions. They allow oral complaints, say complaints cannot be refused because of form, language, or mode, and require receipts and registration numbers. But the system remains heavily dependent on digital registration. There must also be physical complaint registers, paper receipts, local-language support, village-level grievance camps and Gram Sabha review of pending and closed complaints.Panchayat classificationAnother provision introduced under the VB-G RAM G is the categorisation of Gram Panchayats, on the basis of which certain types of works can be provisioned. The proposed classification framework uses indicators such as average employment provided per household and distance from district headquarters. Both are weak indicators for assessing need. Average employment provided is not the same as demand for work. Low employment may reflect the failure of the administration to register demand, issue job cards, open works or reach small habitations.Distance from district headquarters is also an inadequate measure of remoteness. Five kilometres in a hilly or forested area is not the same as five kilometres in the plains. Terrain, road quality, travel time, seasonal access, distance from block offices, distance from banks and the number of habitations within a panchayat may matter much more.There is also a larger governance concern. The Act and rules mention Gram Sabhas, but do not sufficiently strengthen their role in planning, verifying records, reviewing grievances, or checking whether demand is actually being registered. In Scheduled Areas, this gap is even more serious because Gram Sabhas have special legal and constitutional significance.ConclusionThe draft rules should have reassured workers that the new framework will preserve the demand-driven character of the employment guarantee. Instead, they were formulated with no worker inputs, and leave major questions unanswered on allocation, the 60-day no-work window, transition from MGNREGA job cards, payment failures and grievance redressal.The rules must be revised to state that normative allocation cannot cap the right to work, provide supplementary funding when demand exceeds allocation, clarify how the 60-day restriction will be determined and challenged, ensure job card continuity irrespective of e-KYC delays, give workers choice in payments, mandate correction of failed payments, and create accessible offline grievance systems, at a minimum.The promise of 125 days will matter only if workers can actually demand and receive work. Without such safeguards, VB-G RAM G risks replacing a rights-based guarantee with a digitally managed and fiscally capped scheme. That would not be an expansion of MGNREGA. It would be its dilution.Chakradhar Buddha is affiliated with LibTech India, a centre in CORD. Laavanya Tamang is Senior Researcher at the Foundation for Responsive Governance.