EPFO Compliance Checklist 2026
For Exempted PF Trust Managers — 100+ compliance checkpoints covering EPFO SOP 2023, Labour Codes 2025, Investment Norms & Annual Audit Prep.
AI-Assisted Content — For Reference Only
This checklist has been structured and organised with the assistance of AI tools. While every effort has been made to ensure accuracy against EPFO SOP 2023 and applicable regulations, this content is not legal or compliance advice. Regulatory requirements change frequently. Always consult a qualified legal or compliance advisor before taking action.
How to Use This Checklist
Designed for Provident Fund Trust Managers, HR Heads, Finance Controllers and Trustees of EPFO-exempted PF establishments. Use it quarterly for self-audit and annually before your statutory audit submission.
Regulatory requirement. Non-compliance may attract EPFO penalty or trust cancellation.
Strongly recommended. Protects the trust during audit inspections.
Required on a quarterly or annual cycle. Note the due date.
AI-generated reference — verify all items with your legal/compliance advisor before use.
Section 1 — Trust Registration & Governance
- MandatoryValid exemption order — under Section 17 of the EPF & MP Act, 1952 or Section 143 of the Code on Social Security, 2020
No formal order but IT recognition? AMNESTY, 2026 closes 28 December 2026
- MandatoryContinuation of exemption applied for under the EPF Scheme, 2026
Due within 2 years of the Social Security (Central) Rules, 2026 — clock runs from 8 May 2026
- MandatoryRenewal diarised — fresh exemption orders run for 3 years
Extension applied for on the portal at least 6 months before expiry
- MandatoryTrust deed registered & updated with current trustee details
Re-registration required within 30 days of trustee change
- MandatoryMinimum trustee composition: equal employer + employee representatives
- MandatoryTrust rules amended to align with the EPF Scheme, 2026 and the Code on Social Security wage definition
The 1952 Scheme was replaced on 29 June 2026 — rules citing it need review
- MandatoryTrust Rules circulated to members, translated into the language of the majority of employees
EPF Scheme, 2026 requirement
- Board of Trustees meeting minutes maintained (min. 2 per year) and recorded in Form-III
- MandatoryForm-IV written undertaking filed with the Regional PF Commissioner
Undertaking to abide by the conditions for grant of exemption
- Trustee KYC and DSC updated for e-filing
Required for signing electronic returns
- Trust PAN, TAN obtained and active
- MandatorySeparate bank account exclusively for trust operations
Section 2 — Member Account Management
- MandatoryPF account opened for all eligible employees within 30 days of joining
- MandatoryUAN seeding with Aadhaar, PAN and bank account completed
Mandatory per EPFO circular; required for digital claim processing
- MandatoryNomination forms (Form 2) collected & updated for all members
- MandatoryEmployee ledger updated monthly with contributions & interest
- Transfer-in applications (Form 13) processed within 20 days
Penalty risk on delays beyond EPFO SOP timelines
- KYC documents collected and uploaded on unified portal
- MandatoryStatements of account issued to members within 2 months of financial-year close
EPF Scheme, 2026 — replaces the older once-a-year practice
- MandatoryDeceased member settlement initiated within 30 days
Failure attracts trustee liability
Section 3 — Contribution Compliance
- MandatoryEmployer contribution: min. 12% of basic + DA deposited monthly
Must match or exceed EPFO's declared rate
- MandatoryEmployee contribution: 12% deducted and deposited by 15th of next month
Late deposit attracts 12% p.a. penal interest
- MandatoryPension contribution (8.67% of wages) remitted to EPFO separately
Even exempted trusts must remit pension to EPFO
- MandatoryEDLI (Employee Deposit Linked Insurance) contribution remitted to EPFO
₹75/member/month or as applicable
- MandatoryECR (Electronic Challan cum Return) filed on EPFO unified portal monthly
- Contribution on allowances reviewed post Supreme Court judgments
Includes HRA, special allowance — legal review recommended
- Arrear contributions (on increment, revision) deposited with interest
- Contract workers / third-party payroll PF contributions tracked
Section 4 — Investment Management (EPFO Norms)
- MandatoryMin. 85% of corpus invested in government-approved debt instruments
Mandatory EPFO investment pattern — primary audit trigger
- MandatoryMax. 15% in equities (only NIFTY/SENSEX index ETFs permitted)
Crossing limit is a major compliance violation
- Investment register maintained with maturity dates & interest tracking
- Investment committee approval obtained before each transaction
- MandatoryNo investment in related-party instruments or employer securities
Strictly prohibited under EPFO investment norms
- Maturity proceeds reinvested within 7 working days
Idle funds for extended periods attract scrutiny
- SLR (Statutory Liquidity Ratio) instruments verified quarterly
- Investment policy document reviewed & approved by trustees annually
Section 5 — Annual Returns & Statutory Filings
- MandatoryForm-II return filed digitally under the EPF Scheme, 2026
Replaces the Form 3A / 6A framing most trusts still plan their year around
- MandatoryTrust accounts maintained digitally
EPF Scheme, 2026 — spreadsheets and paper ledgers are no longer a defensible record
- MandatoryAudited Balance Sheet of PF Trust submitted to EPFO within 6 months of FY end
- MandatoryReceipts & Payments Account prepared and approved by trustees
- MandatoryIncome & Expenditure Statement prepared (separate from employer's books)
- Bank Reconciliation Statement (BRS) completed monthly
One of the most common EPFO audit findings
- Income Tax Return filed for the trust separately (if applicable)
Trust income from non-exempt investments may be taxable
- Form 10C and 10D (pension withdrawals) processed with EPFO
- MandatoryAnnual interest credited to all member accounts before 31st March
Board declares the rate annually under para 13(9), in tandem with income actually earned
- MandatoryDeclared rate checked against the ceiling of benchmark + 2 percentage points
EPF Scheme, 2026. EPF rate for FY 2025-26 was held at 8.25%
- MandatoryLosses from fraud, defalcation or a wrong investment decision made good by the employer
Principal + interest, within 2 months of the loss or by FY end, whichever is earlier
- Legacy Section 14B damages reviewed against VISHWAS, 2026
One-time settlement at reduced rates — closes 28 December 2026
Section 6 — Loans, Withdrawals & Settlements
- Loan eligibility criteria defined in trust rules and consistently applied
- Refundable & non-refundable loan registers maintained separately
- MandatoryLoan sanction within 30 days of application (SOP 2023 timeline)
Delay beyond SOP triggers escalation to EPFO
- MandatoryForm 19/10C settlement processed within 20 working days
EPFO SOP October 2023 — binding on exempted trusts
- Partial withdrawal (marriage, education, illness) eligibility verified before sanction
- Transfer-out (Form 13) completed within 20 days for resigned members
- MandatoryDeath claim & EDLI payment initiated within 30 days
Family nominee must not face delay — trustee liability risk
- Outstanding loans reviewed quarterly; defaulting members flagged
Section 7 — EPFO Inspection Readiness (SOP 2023)
- MandatoryAll registers/records available for EPFO inspection within 48 hours
EPFO SOP 2023 — trusts subject to periodic & surprise checks
- MandatoryCompliance officer designated and details submitted to EPFO
- MandatoryPrevious inspection observations closed with documented proof
- Trust deed, rules, trustee resolution book ready for inspector
- Investment portfolio summary with purchase docs readily accessible
- Member complaints register maintained and reviewed quarterly
- Digital access control: role-based access to trust records enabled
- Data backup policy in place; disaster recovery tested annually
On-premise deployments: backup must be off-site or cloud-mirrored
Section 8 — Labour Code & New-Age Compliance
- Code on Social Security 2020 impact assessed for trust structure
May alter contribution definitions when fully notified
- MandatoryWage definition under new Labour Codes reviewed (50% rule for allowances)
Impacts PF contribution base significantly
- International worker (IW) PF compliance tracked separately (if applicable)
Different rules for expatriate and Totalization Agreement countries
- Gratuity trust compliance reviewed alongside PF trust (joint audit risk)
- Superannuation fund, if any, investment norms separately verified
- Employee awareness sessions on PF self-service portal conducted
Reduces member complaints to EPFO
- MandatoryAnnual trustee training on EPFO regulatory updates completed
Trustees bear personal liability under EPF Act
- Cyber security audit of PF software & data systems done annually
Compliance Scorecard — Self Assessment
After completing the checklist, use this scorecard to rate your trust's compliance health.
| Section | Total Items | Mandatory | Status (✓/✗) | Action Owner | Due Date |
|---|---|---|---|---|---|
| 1. Registration & Governance | 8 | 4 | |||
| 2. Member Account Management | 8 | 5 | |||
| 3. Contribution Compliance | 8 | 6 | |||
| 4. Investment Management | 8 | 5 | |||
| 5. Annual Returns & Filings | 8 | 5 | |||
| 6. Loans, Withdrawals & Settlements | 8 | 4 | |||
| 7. EPFO Inspection Readiness | 8 | 3 | |||
| 8. Labour Code & New-Age Compliance | 8 | 2 | |||
| TOTAL | 64 | 34 | |||
Compliance Rating Guide
AI-Assisted Content — For Reference Only
This checklist has been structured and organised with the assistance of AI tools. While every effort has been made to ensure accuracy against EPFO SOP 2023 and applicable regulations, this content is not legal or compliance advice. Regulatory requirements change frequently. Always consult a qualified legal or compliance advisor before taking action.
Reference: EPFO SOP October 2023 | Updated: April 2026 | Confidential — For PF Trust Managers & HR/Finance Teams Only
This checklist is AI-assisted and for guidance only. Consult your legal/compliance advisor for specific advice.
Struggling with any of these 64 checkpoints?
myPF Software automates 90% of this checklist — contributions, investments, statutory reports, member ledgers, BRS, and EPFO-ready audit trails.