Updated 16 October 2026
If your PF gap audit is not done, run it this week on current employees only, file the first batch of declarations on the EPFO Employer Portal, and add the rest before 31 October. Multiple declarations are allowed.
A one-time window with a hard 31 October 2026 deadline
The EPF enrolment amnesty of 2026 closes on 31 October. Many Indian companies with 20 or more staff have PF gaps they may not know about: contractors who became employees, consultants who worked full-time, trainees kept off-roll for years. Each one is a damages risk.
EPFO’s order dated 8 July 2026 changes the math. The Employees’ Enrolment Campaign, 2026, which runs from 1 July to 31 October 2026, lets you fix past gaps on these terms:
- ₹100 lump-sum damages per defaulting establishment. Not per employee, not per month.
- The employee’s share is waived where it was never deducted from wages.
- The employer’s share is still due, with interest (under Section 7Q of the old EPF Act or Section 127 of the Code on Social Security, 2020, as applicable) and administrative charges.
For CHROs and CFOs of 100+ employee companies, this is the cheapest way in years to settle never-enrolled staff. With about two weeks left, the question is no longer whether to act but how fast.
What the EPF enrolment amnesty actually does
The campaign is run under the Code on Social Security, 2020 and the Employees’ Provident Funds Scheme, 2026 (notified 29 June 2026). Three things matter most:
1. It waives the employee’s share of past PF if you never deducted it. Only the employer’s share, with interest and admin charges, is due.
2. It caps damages at ₹100 per establishment. Damages for late payment usually run at a percentage of the arrears for every year of delay. On a large staff base that is tens of lakhs. The campaign replaces it with a single ₹100.
3. It is open even if you are already under inquiry. EPFO’s order says establishments facing an inquiry (Section 7A of the old Act or Section 125 of the Code) can still use the campaign, with damages for the inquiry period limited to ₹100.
Who qualifies for the amnesty
You can declare an employee who:
- Joined between 1 April 2009 and 31 March 2026
- Is alive and still working with you on the date of declaration
- Was eligible for PF and was never enrolled
You cannot declare:
- Staff who have already left. EPFO’s order adds that no suo motu action will be started for employees who exited before your declaration, but take advice on your own position.
- People outside the 2009 to 2026 joining window.
The campaign is about never-enrolled staff. If you deducted PF from salaries but did not deposit it, or under-reported wages for enrolled staff, those are separate defaults: get advice rather than relying on this campaign.
Why the EPF enrolment amnesty matters more for 100+ employee companies
First, data matching is getting sharper. PF filings can be compared with GST, TDS and company filings. Contractor payments that look like salary bills stand out. The “wait and see” approach is getting riskier.
Second, the savings are large. Take a mid-sized company that kept 40 staff off PF over several years. Under normal enforcement:
- Employer share: about ₹2.3 crore in principal (illustrative)
- Damages for late payment: another ₹90 lakh to ₹1.8 crore
- Interest at 12% a year: about ₹1 crore
Under EEC 2026, same population:
- Employer share: still about ₹2.3 crore (principal is always due)
- Interest: still about ₹1 crore (the campaign does not waive it)
- Damages: ₹100
The saving is the damages line, which for most 100+ employee companies runs from tens of lakhs to well over a crore. The principal and the interest do not go away. These are illustrative figures; run your own numbers with your adviser.
The 15-day playbook for filing before 31 October
Days 1 to 4: PF gap audit on current staff. Pull payroll registers, contractor and consultant lists and vendor invoices from 1 April 2009, and cross-check against your PF ECR data. Focus on trainees who moved to full-time, contractors who became employees, consultants who were effectively full-time, and off-roll staff from growth phases.
Days 4 to 6: filter for eligibility. For each person, check: still working with you, joined in the 2009 to 2026 window, eligible for PF at joining, never enrolled. Note the reason for every exclusion.
Days 6 to 8: calculate and approve. Work out the past employer share, interest and admin charges for each person, plus ₹100 damages. Get CFO or board sign-off for the payment.
Days 8 to 13: file in batches. Each declared employee needs a UAN generated through Face Authentication (UMANG app). File declarations on the EPFO Employer Portal and pay through the ECR-linked challan (TRRN). Multiple declarations are allowed, so file the clear cases first.
Days 13 to 15: onboard and communicate. Enrol declared staff in your monthly PF returns going forward, explain the take-home impact, and answer UAN and pension questions.
After 31 October: fix upstream. Update onboarding so no new hire slips through.
Five mistakes that will cost you the amnesty
1. Waiting for the last week. Portal issues are common near deadlines, and UAN generation needs each employee’s face authentication.
2. Only cleaning up the “obvious” cases. The value is in scope. Anyone eligible you leave out stays a full-damages risk after 31 October.
3. Missing the “still working” rule. A person who has already left cannot be declared. Never backdate records.
4. Using the old wages definition. The new EPF Scheme, 2026 follows the Code’s wider definition of wages. Check that contributions are worked out on the right base.
5. Assuming your payroll vendor will handle it. Most vendors are not tracking the campaign proactively. The CFO or CHRO owns this.
What to do this week on the EPF enrolment amnesty
- Assign one owner, usually the Head of Compliance or CHRO, with 31 October as the hard deadline.
- Run the PF gap audit on current staff, 2009 to 2026.
- Have external counsel or a payroll compliance expert review the list.
- Get CFO or board sign-off for the employer share, interest and charges.
- File the first batch of declarations this week.
Declared employees may also be eligible for PM-VBRY benefits, subject to that scheme’s terms. After 31 October, any gap you have not fixed is back under normal damages and interest rules.
TMS runs the full EPF enrolment amnesty audit, calculation, filing and cleanup for corporates with 100 to 2,000 employees. If your team does not have the bandwidth to finish by 31 October, this is what outsourced payroll partners are built for.
FAQ
Q: Is the ₹100 damages per employee or per company? It is a lump sum per defaulting establishment, not per employee.
Q: We are already facing an EPFO inquiry. Can we still use the campaign? Yes. EPFO’s order allows establishments under inquiry to participate, with damages for the inquiry period limited to ₹100.
Q: What if we deducted employee PF but never deposited it? The waiver of the employee’s share applies only where it was never deducted. Deducted-but-not-deposited PF is a separate, serious default; take advice.
Q: Can we file in phases? Yes. Multiple declarations are allowed, and filing in phases cuts last-week portal risk.
Q: Does the amnesty waive interest on the past contributions? No. Interest at 12% a year stays payable on the employer’s share for the back period, along with administrative charges. What the campaign waives is the employee’s share where it was never deducted, and the percentage-based damages, which drop to a flat ₹100. On a long back period, interest is often the largest number, so budget for it.
Sources: Press Information Bureau, Release ID 2300475 (17 August 2026); EPFO order on the Employees’ Enrolment Campaign, 2026, dated 8 July 2026. Last reviewed: 16 October 2026. General guidance, not legal advice.
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