Credit of Past Accumulations – Non-UAN Members of Exempted Trusts under Surrender/Cancellation Process

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🔍 EPFO Directs Mandatory Credit of Past Accumulations for Non-UAN Members of Exempted Trusts

Aadhaar Relaxed, Deadline for Compliance: 30th June 2025

By Compliance Monk | 28 July 2025

In a significant move to streamline the transition process of employees from exempted Provident Fund (PF) trusts to the Employees’ Provident Fund Organisation (EPFO), the Central Provident Fund Commissioner (CPFC) has issued a directive requiring all field offices to credit past accumulations of non-UAN members by 30th June 2025. This instruction is applicable in cases of surrender or cancellation of exemption by the PF trusts.

📌 Background

Exempted establishments are entities permitted to manage their own PF trusts under the EPF Scheme, subject to strict regulatory oversight. However, when these trusts voluntarily surrender their exemption or have it cancelled by the authorities, the entire administration of PF, including the transfer of accumulated PF balances, reverts to the EPFO.

A major bottleneck in this process has been the lack of Universal Account Numbers (UANs) for thousands of members, and the mandatory requirement of Aadhaar for UAN generation and balance transfer.

🆕 Aadhaar Relaxation for UAN Generation

Citing the need to avoid delays and protect workers' interests, the EPFO, via Head Office Circular No. WSU/Past Accumulations/E-683907/2025-26/19 dated 25.04.2025, relaxed the Aadhaar requirement for UAN generation and past accumulation credit. A new software functionality was introduced in the FO (Field Office) Interface to allow bulk UAN generation for such non-UAN members, even if they have not yet linked Aadhaar.

🛠️ Mandatory Compliance Before 30.06.2025

The present circular (Ref: 906104/09 dated 17.06.2025) mandates that all field offices must:

  • Utilise the provided software functionality to generate UANs without Aadhaar,

  • Credit the past accumulations from the exempted trusts to these UANs, and

  • Complete this process by 30th June 2025.

This applies in two categories:

  1. Trusts where exemption surrender/cancellation has already been approved by the CBT or notified by the government.

  2. Trusts whose exemption surrender/cancellation proposals are under consideration.

However, the circular reiterates that no debits (withdrawals or transfers) should be permitted from these UANs until Aadhaar is seeded.

📊 Action Taken Report Format

Each Zonal Office is required to submit an Action Taken Report (ATR) in the following format:

S. NoName of Establishment (with Code) Date of Order for    Compliance as Un-    exemptedNo. of Non-UAN MembersNo. of UANs Generated & Past Accumulations Credited Without Aadhaar

This report must be submitted to the Head Office on or before 30th June 2025.

🧭 Implication

This directive is a crucial step towards digital inclusion and aims to ensure that employees transitioning from exempted PF trusts are not denied access to their rightful accumulations due to procedural delays.

Relaxing Aadhaar conditions temporarily is seen as a progressive measure to avoid member hardship, especially for those in legacy records where Aadhaar seeding has not yet been completed.

📢 Final Word

With only a short window to comply, Zonal and Regional PF Offices must act swiftly and responsibly. This is not just a procedural requirement—it directly impacts thousands of workers' financial rights.

📅 Deadline to submit Action Taken Report: 30th June 2025
🔐 No debit transactions allowed without Aadhaar seeding

For templates, compliance support, or reporting formats, stay tuned to Compliance Monk for continuous legal and procedural updates in the EPFO domain.

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