EPFO's Three Compliance Windows 2026: VISHWAS, Enrolment, PF Trust Amnesty
The new EPF Scheme 2026 opens three time-limited amnesty windows: VISHWAS (₹100 damage settlement), Enrolment Campaign (waived employee share, 31 October 2026 deadline), and PF Trust Amnesty. Employers with pending Section 14B damages, unenrolled eligible workers, or unnotified private trusts must act before December 2026 to avoid full enforcement.
CA Harun Raaj
Chartered Accountant · Harun Raaj & Associates
Legal basis: Employees' Provident Funds Scheme, 2026 (G.S.R. 525(E), 29 June 2026) under Section 15-exporters), Code on Social Security, 2020 — Effective: 29 June 2026 (VISHWAS and PF Trust Amnesty windows); 1 July 2026 (Enrolment Campaign window). Source: Government notification G.S.R. 525(E). Last reviewed by CA Harun Raaj: January 2026.
For Indian employers, the new Employees' Provident Funds Scheme, 2026 replaces the EPF Scheme, 1952 and introduces three distinct amnesty-type schemes effective 29 June 2026. These windows close between October and December 2026. Missing them means returning to full Section 7A enquiries, Section 14B damages (up to 25% of arrears), and potential prosecution under Section 14, EPF & MP Act.
What Changed: Three Compliance Windows Under EPF Scheme 2026
Key point: The Enrolment Campaign (31 October 2026) has no announced extension; employers with unenrolled workers from April 2009 onward must prioritise this window.
Scheme 1: VISHWAS — Settle Section 14B Damages at ₹100 Nominal Cost
Who qualifies: Any employer against whom Section 14B damage proceedings are pending, disputed, or unrecovered for contribution payment defaults occurring before 14 June 2024.
What VISHWAS requires you to pay:
- Principal EPF and EPS contributions (mandatory; not waived)
- Interest at 12% per annum on the arrear amount (not waived)
- Flat ₹100 nominal damage fee per establishment
What VISHWAS eliminates:
- All pending Section 14B damage demands (normally 5–25% of arrears)
- Pending Section 7A enquiries and finalized appeal orders for the eligible period — fully abated
Illustrative scenario: A manufacturing MSME accumulated ₹8.7 lakhs in PF arrears from 2021–22 with ₹1.8 lakhs in Section 14B damages pending. Under VISHWAS, the company pays ₹8.7 lakhs principal + 12% interest thereon + ₹100. The ₹1.8 lakh damage demand is completely waived. (Illustrative only; actual liability depends on establishment records.)
Window duration: 29 June–29 December 2026 (6 months); further extension possible on application.
Scheme 2: Employees' Enrolment Campaign 2026 — Urgent for MSMEs and Gig Platforms
Deadline: 31 October 2026. No extension has been announced.
If your establishment had 20 or more employees at any point between 1 April 2009 and 31 March 2026 and eligible workers (monthly wages ≤ ₹15,000, or voluntarily covered) were never enrolled into EPFO, this scheme applies. The employee must be in current employment at the time of declaration.
What you pay under the Enrolment Campaign:
- Employer share (12% of wages) for the backdated period + administrative charges + interest on arrears
- Employee share for the entire backdated period: completely waived
- Section 14B damages: ₹100 per establishment (flat)
What this saves versus normal enforcement:
- Avoids employee share liability (typically 10% of wages)
- Eliminates Section 14B penalty (5–25% of arrears)
- Removes risk of prosecution under Section 14, EPF & MP Act
Implementation steps:
- Generate Face Authentication-based UAN via the UMANG app (EPFO discontinued the member portal route for UAN activation from 3 July 2026)
- Submit ECR (Electronic Challan-cum-Return) with TRRN for the declaration period
- Deposit employer contributions within the stated timeline
- Ensure employee documents (ID, address, wage records) are on file
Who must act before 31 October 2026: Gig economy platforms, retail chains, construction contractors, hospitality businesses, labour-intensive manufacturing, and any MSME that crossed the 20-employee threshold without timely EPFO registration.
Scheme 3: PF Trust Amnesty — Regularise Unnotified/Unexempted Private Trusts
Announced: 12 July 2026.
Many established Indian companies maintain provident fund trusts recognised under income tax law (Section 17 / Section 80C) but never obtained a formal exemption notification from the Central or State Government under the EPF & MP Act or Code on Social Security, 2020. These trusts operate in legal ambiguity: employees' PF sits in the private trust, but without EPFO exemption, the company technically remained within EPFO jurisdiction and was never properly exempted.
Amnesty benefits:
- Retrospective formal recognition as either (a) unexempted establishment (Category I) or (b) formally exempted establishment (Category II)
- Minimum employee headcount requirement: waived
- Corpus size or adequacy norms: waived
- Prior three-year EPFO compliance history: waived
- All pending EPFO assessments, finalized damage orders, and past enquiry orders: treated as void
Application process:
- Email: rc.exemption@epfindia.gov.in
- Mandatory Chartered Accountant audit of trust financial statements
- EPFO compliance audit within 3 months of application approval
Window duration: 29 June–29 December 2026 (6 months); further extension possible on application.
Can You Use Multiple Schemes at Once?
Yes. VISHWAS addresses pending damage liability from payment defaults; the Enrolment Campaign covers gaps in worker registration; the PF Trust Amnesty handles trust regularisation. These operate on different factual bases and timelines — an employer with all three issues should address each within its respective window.
I'm CA Harun Raaj, Visakhapatnam. If your establishment falls under any of these three windows, reach out to discuss your compliance position and timeline.
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See Also
Frequently Asked Questions
Can an employer use VISHWAS, the Enrolment Campaign, and PF Trust Amnesty simultaneously?+
Yes. These three schemes address different compliance gaps: VISHWAS settles Section 14B damage proceedings on past defaults; the Enrolment Campaign regularises unenrolled eligible employees; the PF Trust Amnesty formalises unexempted private trusts. An employer facing all three issues can apply under each scheme within their respective windows, as they operate on non-overlapping timelines and factual bases.
What happens if I miss the 31 October 2026 Enrolment Campaign deadline?+
The campaign window closes without extension on 31 October 2026. After that date, any unenrolled eligible employees from April 2009 onwards trigger full enforcement under Section 7A: EPFO will demand both employer and employee shares, 12% interest, Section 14B damages (5–25% of arrears), and possible prosecution under Section 14, EPF & MP Act.
Is the ₹100 damage fee per employee or per establishment under VISHWAS and the Enrolment Campaign?+
Per establishment, regardless of how many employees are being declared or how many defaults/enrolment gaps are being regularised. A single ₹100 nominal fee applies per establishment under both VISHWAS and the Enrolment Campaign.
Does the Enrolment Campaign cover employees who have already left my company?+
No. Under the Enrolment Campaign, the employee must be in current employment at the time of declaration. If a worker left after the April 2009–March 2026 period, they cannot be enrolled retroactively under this amnesty scheme.
What does 'unexempted private PF trust' mean, and who needs the PF Trust Amnesty?+
A private provident fund trust set up under income tax law (Section 17 / Section 80C) but never granted formal exemption from the Central or State Government under the EPF & MP Act or Code on Social Security, 2020. These trusts exist in legal grey zone: the company is technically still within EPFO jurisdiction. The amnesty allows retrospective regularisation as either an unexempted or formally exempted establishment, with all prior EPFO assessments and damage orders treated as void.
Does VISHWAS cover Section 14B damages from defaults after 14 June 2024?+
No. VISHWAS covers only Section 14B proceedings arising from contribution defaults **prior to 14 June 2024**. Defaults after that date fall outside VISHWAS eligibility and remain subject to normal enforcement and penalty procedures.
How do I prove that an employee was 'eligible' but never enrolled under the Enrolment Campaign?+
Eligible employees are those with monthly wages ≤ ₹15,000 or voluntarily covered, in an establishment with 20 or more employees between 1 April 2009 and 31 March 2026. EPFO will verify employment through payroll records, attendance registers, and statutory documents. A Chartered Accountant audit of wage records is strongly recommended before submission to strengthen the declaration.
Can I extend VISHWAS or the PF Trust Amnesty window beyond 29 December 2026?+
Both schemes mention a further extension of up to 6 months on application. However, EPFO has not published automatic extension terms. You must apply for extension formally before 29 December 2026 if you cannot complete by that date. The Enrolment Campaign (31 October 2026) has no announced extension provision.
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