EPFO’s New Compliance Trio: Enrolment Campaign, VISHWAS, and Amnesty, 2026- Closing India’s Social Security Coverage Gap
VKC 2026 | Vol.2 | LU | Issue 04 | 21 Oct 2026 | Author: Adv. Damini Devlekar, Contributors: Adv: Siddhi Nadgir, Adv. Rakesh Umarani
Why this Matters?
India is undergoing one of its most significant labour-law reforms in decades with the phased implementation of the four Labour Codes. As part of this transition, the Central Government notified the Employee’s Provident Funds Scheme, 2026 (EPFS, 2026), the Employee’s Pension Scheme, 2026 (EPS, 2026) and the Employee’s Deposit-Linked Insurance Scheme, 2026 (EDLIS, 2026) replacing the erstwhile framework under the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952. The notifications mark a significant step towards the practical operationalisation of the Code on Social Security, 20201. These schemes usher in a modern, technology-driven and compliance-focused social-security regime, alongside three key initiatives, the Employees’ Enrolment Campaign (EEC), VISHWAS and AMNESTY, 2026 prominently aimed at expanding PF coverage, encouraging voluntary compliance, resolving legacy disputes and regularising exempted establishments. This article examines their legal framework, key features and practical implications for employers and other stakeholders.
Three different EPF compliance gaps are addressed by the Employees' Enrolment Campaign (EEC), 2026, VISHWAS, 2026, and AMNESTY, 2026. EEC deals with missed employee enrolment and coverage; VISHWAS deals with damages for delayed PF remittances under Section 14B2 of the EPF & MP Act and Section 1283 of the Code on Social Security, 2020; and AMNESTY deals with PF trust and exemptions. Together, they offer employers a time-bound opportunity to identify legacy gaps, avail the appropriate relief, and strengthen EPF compliance before stricter, technology-driven enforcement takes effect.
Special Initiatives:
The EEC creates a one-time window for employers to bring previously excluded employees within EPF coverage, thereby expanding social security coverage while enabling structured regularisation of historical non-compliance. It commences from the publication of the EPFS, 2026 i.e. from 1st July 2026 remains open until 31 October 2026. The scheme is available to all employers, irrespective of prior EPF coverage, for employees who joined between 1 April 2009 and 31 March 2026, continue in employment on the declaration date, and were not previously enrolled under the EPF Scheme, 1952. It also covers establishments facing pending proceedings under Section 125 of the Code on Social Security or Section 7A of the repealed Act, with the declaration to be considered in such proceedings. However, concluded assessments pending in appeal or otherwise are excluded from EEC benefits.
The Employees’ Enrolment Campaign (EEC), 2026 offers employers a limited opportunity to regularise past PF enrolment gaps with substantial relief. While contributions, interest and administrative charges remain payable, the employee’s share is waived for the period from 1 April 2009 to 31 March 2026 where it was never deducted. Damages are also capped at a nominal ₹100. Employers may make multiple declarations, enabling phased compliance. Further, upon furnishing the prescribed undertaking, the EPFO will not initiate proceedings against employees who had already ceased employment before the declaration. The EEC thus provides a practical window to rectify legacy PF defaults and achieve compliance.
VISHWAS, 20265 – Closing Legacy PF Damage Disputes:
VISHWAS, 2026 introduces a one-time mechanism to resolve disputes relating to damages for delayed PF remittances for defaults prior to 14 June 2024. The scheme is available for six months from notification, extendable by up to a further six months by the Central Provident Fund Commissioner (CPFC), irrespective of the stage of proceedings under Section 14B6 of the of the Repealed Act read with Paragraph 32A of the EPF Scheme,19527 and Section 128 of the Code on Social Security, 20208 read with Paragraph 23 of the EPF Scheme, 2026.
Qualified employers may substitute concessional damages for statutory damages under VISHWAS. The disagreement is resolved when the required damages and any relevant statutory interest are paid, and any further appeals or actions cease. Only the difference, if any, will be due after amounts that have already been recovered or deposited have been properly credited. Any excess amount will be handled in compliance with the relevant Scheme criteria.
AMNESTY9, 2026 – Regularising PF Trusts
AMNESTY, 2026 introduces a one-time six-month window (extendable by up to six months) for establishments operating PF trusts recognised under the Income-tax Act, 1961 but lacking formal EPF exemption, enabling retrospective regularisation either while transitioning to the un-exempted regime or continuing as exempted establishments under the Code on Social Security, 2020.
The scheme permits retrospective exemption and recognition of eligible PF trusts from inception, deems their operational period to satisfy specified eligibility requirements, and waives prescribed minimum employee-strength and corpus conditions. Where employees received benefits and interest at least equivalent to statutory entitlements, proceedings for dues, damages and interest arising solely from the absence of formal exemption are protected from further action; pending proceedings are withdrawn/abated and completed assessments are rendered void ab initio, subject to the scheme, with amounts already recovered adjusted as prescribed. AMNESTY further facilitates retrospective pension membership recognition, transfer of PF accumulations, and orderly transfer of trust corpus where an establishment transitions to the un-exempted regime.
Key Takeaway10:|
The three initiatives address three distinct legacy risks: EEC corrects missed enrolments, VISHWAS resolves historical damages disputes, and AMNESTY regularises defective PF-trust structures. Employers should use the applicable window to identify and document legacy gaps before the respective relief periods expire.
Open Questions:
EEC, VISHWAS and AMNESTY can help employers resolve historical defaults while using the opportunity to audit, strengthen and future-proof their EPF compliance.
EEC vs Vishwas How should employers decide which scheme applies where enrolment and delayed remittance defaults overlap
Does the waiver of the employee’s share sufficiently encourage disclosure, despite the employer’s liability for contributions and interest
What documents and internal records should employers preserve to establish that historical defaults have been properly regularised
Discussion Prompt:
With EEC, VISHWAS and AMNESTY offering targeted relief for different categories of historical PF non-compliance, should employers treat these limited relief windows as more than amnesty schemes and undertake a comprehensive EPF compliance audit before the opportunity closes? What legal exposure, financial liabilities and enforcement risks could employers face if legacy defaults remain unaddressed?
Sources & Footnotes
1.The Code on Social Security, 2020, No. 36, Acts of Parliament, 2020 (India). https://www.labour.gov.in/static/uploads/2025/07/b0620548445580767b5c0d18c95c2 6f7.pdf ↩
2. Employees’ Provident Funds and Miscellaneous Provisions Act, 1952, § 14B, https://apps.labour.gov.in/cgit/sites/default/files/EPFAct1952.pdf ↩
3.The Code on Social Security, 2020, § 128, No. 36, Acts of Parliament, 2020 (India). https://www.labour.gov.in/static/uploads/2025/07/b0620548445580767b5c0d18c95c2 6f7.pdf ↩
4. Employees’ Enrolment Campaign (EEC), 2026, No.EEC/2025/E-1190921/4278204 dated 08/07/2026, https://www.staffnews.in/2026/07/implementation-of-employees-enrolment-campaign.html ↩
5. Vishwas, 2026, Noti. No. Compliance/E-1203096/2025/2823], https://www.scconline.com ↩
6. Supra note 3 ↩
7. Employee’s Provident Fund Scheme, 1952, https://pmvbry.epfindia.gov.in/epf-scheme/ ↩
8.Supra note 4 ↩
9. Supra Note 1 ↩
10. Disclaimer: This publication is intended solely for general informational purposes and should not be construed as legal advice or a legal opinion. For advisory, or specific queries on any of the above, we encourage our clients to reach out to our team at Vidyam Legal.↩
