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Updated April 2026

# 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. Always consult a qualified advisor.

[Download PDF](/EPFO_PF_Trust_Compliance_Checklist_2026.pdf)[View Compliance Software →](/compliance)

1,276

Exempted PF Trusts in India

85%

Min. govt. securities investment mandate

₹5 Lakh+

Avg. penalty per compliance default

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.

Mandatory

Regulatory requirement. Non-compliance may attract EPFO penalty or trust cancellation.

Best Practice

Strongly recommended. Protects the trust during audit inspections.

Periodic

Required on a quarterly or annual cycle. Note the due date.

Update — EPF Scheme, 2026

This checklist has been updated for the EPF Scheme, 2026, which replaced the EPF Scheme, 1952 on 29 June 2026. Items carrying an EPF Scheme, 2026 note are new or materially changed — the continuation application, Form-II, Form-III and Form-IV, digital trust accounts, two-month member statements, and the ceiling on declared interest.

[See what the EPF Scheme, 2026 changes for exempted trusts→](/epf-scheme-2026)

AI-generated reference — verify all items with your legal/compliance advisor before use.

1

## 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

2

## 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

3

## 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

4

## 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

5

## 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

6

## 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

7

## 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

8

## 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

**Audit-Ready (90–100% complete)** — File your annual return with confidence

**Needs Attention (70–89% complete)** — Close gaps before your next EPFO inspection

**High Risk (Below 70% complete)** — Engage compliance consultant immediately

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.

AI-Assisted Checklist — Always verify requirements with a qualified compliance professional

[Book a Free Demo →](https://calendly.com/andolasoft/30min)[Download PDF Checklist](/EPFO_PF_Trust_Compliance_Checklist_2026.pdf)

Deadline AMNESTY 2026 closes on 28 December 2026.

A one-time EPFO window for trusts that hold Income Tax recognition but no formal exemption order. [Check whether yours qualifies →](/amnesty-2026)

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## EPF Scheme 2026

-   [EPF Scheme 2026](/epf-scheme-2026)
-   [AMNESTY 2026 28 Dec](/amnesty-2026)
-   [Exemption Continuation](/exemption-continuation)
-   [Compliance](/compliance)
-   [EPFO Checklist 2026](/compliance/checklist)

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