Exemption is no longer something you have.
It’s something you renew.
A fresh exemption order now runs for three years. Existing exempted establishments have to apply for continuation. And the application is not a covering letter — it is a pack: Form-II returns, Form-III trustee minutes, a Form-IV undertaking to the Regional PF Commissioner, and evidence that your net worth holds up.
We generate the three forms from your own data, live on the call.
Four dates that now govern your exemption
None of these existed under the EPF Scheme, 1952. All of them are board-level exposure under the EPF Scheme, 2026.
Within 2 years
Existing exempted establishments must apply for continuation of exempted status within two years of the notification of the Social Security (Central) Rules, 2026 — the clock runs from 8 May 2026.
3-year term
A fresh exemption order is initially valid for three years from the publication of the notification. It does not roll over on its own.
6 months ahead
An application for extension must be made on the portal at least six months before the exemption expires — so the work starts well before that.
3-year test
Renewal is granted where the employer continues to satisfy the conditions for exemption and the establishment’s net worth has not remained negative for three or more consecutive years.
The three forms, and what each one really asks for
Most trusts can name the forms. Fewer can produce the underlying record on demand — which is the part that decides how the filing goes.
Form-II
The returnThe exempted trust’s return, filed digitally.
What it rests on
- Member-wise contribution and settlement data for the period
- Interest credited, reconciled to income actually earned
- Investment position against the prescribed allocation limits
Where the difficulty usually is
Generated from the live member ledger rather than assembled from spreadsheets at year end — which is what makes the filing reproducible when the regional office asks a question about it six months later.
Form-III
Trustee meeting minutesMinutes of Board of Trustees meetings, in the prescribed format.
What it rests on
- Dated agenda, attendance and resolutions for each meeting
- Recorded decisions on investments and the interest declaration
- A trail linking each resolution to what was actually done
Where the difficulty usually is
Minutes recorded against the trust record as decisions are taken, so the Form-III position is a by-product of governance instead of a reconstruction exercise. Minutes that cannot be authenticated are treated as if they do not exist.
Form-IV
The undertakingA written undertaking to the Regional PF Commissioner that the trustees will abide by the conditions for grant of exemption.
What it rests on
- Current trustee composition and signatures
- Confirmation against each condition of exemption
- Consistency with what Form-II and Form-III actually show
Where the difficulty usually is
This is the document that makes the conditions personal to the trustees signing it. It should not be signed against a position nobody has verified.
What sits behind the forms
A continuation application is a statement about how the trust has been run. These are the areas where that statement gets tested.
Interest inside the ceiling
Declared interest must track income actually earned, capped at two percentage points above the statutory benchmark, and declared annually by the Board under paragraph 13(9). A historic rate declared on convention rather than income is visible in the record.
Losses made good on time
Losses from fraud, defalcation or a wrong investment decision must be recouped by the employer — principal and interest — within two months of the loss or by the end of the financial year, whichever is earlier.
Trust rules that match the Scheme
Rules and trust deeds drafted against the 1952 Scheme need amendment to align with the 2026 Scheme and the Code on Social Security wage definition. Rules must also be circulated to members, translated into the language of the majority of employees.
Member statements inside two months
Statements of account are due to members within two months of financial-year close. A trust that cannot issue them on that cadence has an operational gap the continuation pack will expose.
Digitally maintained accounts
Trust accounts are expected to be maintained digitally. Spreadsheet ledgers are increasingly difficult to defend as the primary record.
Corporate actions on record
After a merger, demerger, amalgamation or subsidiary formation, exemption status is determined by a competent legal forum rather than revoked automatically — but the event and its treatment need to be documented.
See the three forms produced from your own data
Not a slide deck of screenshots. We take a sample of your member and investment data, run it through the platform, and show you the filing pack that comes out — including the parts it cannot yet evidence, which is usually the more useful half.
- Form-II return, generated from your live member and investment data
- Form-III trustee minutes in the prescribed format, with the resolution trail
- Form-IV undertaking, pre-filled against your current trustee composition
- Interest declaration checked against the benchmark + 2 percentage point ceiling
- Member statement run, evidencing the two-month cadence
- A gap list of anything the pack cannot yet evidence
Continuation and renewal: common questions
- When is our continuation application due?
- Existing exempted establishments are required to apply for continuation of exempted status within two years of the notification of the Social Security (Central) Rules, 2026 — the clock runs from 8 May 2026. Separately, a fresh exemption order is valid for three years, with extension applied for on the portal at least six months before expiry.
- What is Form-II?
- Form-II is the exempted trust’s return under the EPF Scheme, 2026, filed digitally. It replaces the Form 3A / 6A framing most trusts still organise their year around, and rests on the member ledger, the interest computation and the investment position.
- What goes in Form-III?
- Minutes of Board of Trustees meetings in the prescribed format, submitted to the Regional PF Commissioner. Each meeting needs a dated agenda, attendance and recorded resolutions — particularly on investment decisions and the interest declaration. Minutes that cannot be authenticated are treated as non-existent for inspection purposes.
- What does Form-IV commit the trustees to?
- Form-IV is a written undertaking to the Regional PF Commissioner that the trustees will abide by the conditions for grant of exemption. It is what makes those conditions personal to the people signing, which is why the underlying position should be verified before it is signed.
- What happens if net worth has been negative?
- Renewal is granted where the employer continues to satisfy the conditions for exemption and the net worth of the establishment does not remain negative for three or more consecutive years. A single difficult year is not the test; a sustained pattern is.
- We do not have a formal exemption order at all. What then?
- Then continuation is not your first step — there is nothing to continue from. AMNESTY, 2026 is the route for trusts holding Income Tax recognition without a formal exemption order under Section 17 or Section 143, and it closes on 28 December 2026.
- Can we prepare the pack without buying software?
- Yes, and plenty of trusts do it manually. The question is whether you can reproduce it on demand, every three years, with the member statements and digital accounts the 2026 Scheme also expects. That is the case for a system rather than a scramble — but the readiness review itself is free and carries no obligation.
Guidance only, not legal advice. Confirm your trust’s position and filing obligations with your legal and actuarial advisers.
What continuation actually asks of you
The three forms in detail, the trust-deed clauses that have to change first, and the liability clause trustees are signing up to.
Form-II, Form-III and Form-IV: The Three Filings Every Exempted Trust Now Owes
The EPF Scheme, 2026 introduces three statutory artefacts for exempted establishments — a digital Form-II return, Form-III trustee minutes and a Form-IV undertaking to the RPFC. Who signs each one, what evidence attaches, and why Form-III is the one that catches trusts out.
Read the postGovernanceYour Trust Rules Were Written for 1952. Here's the Amendment Checklist.
Most exempted trusts are governed by PF Trust Rules drafted against a Scheme that was repealed in June 2026. This is the clause-level checklist of what has to change — wage definition, interest declaration mechanics, member communication, forms and governance — and who has to be told.
Read the postGovernance"Wrong Investment Decision": The Two-Month Clock Trustees Should Fear
The EPF Scheme, 2026 requires losses from fraud, defalcation or a "wrong investment decision" to be made good — principal and interest — within two months. The phrase is undefined. Here is what trustees should be documenting before the question is ever asked.
Read the postFind out what your pack is missing
The gaps are almost never in the forms themselves. They are in the record underneath — minutes that were never signed, an interest rate nobody reconciled, statements that went out late.