# Social Security Agreement India 2026 and the Certificate of Coverage

> Source: https://krystal7.com/insights/social-security-agreement-certificate-of-coverage-india
> Publisher: Krystal7 Consultants (Krystal7 Innovations Private Limited), Gurugram, India
> Author: CA Nandini
> Published: 15 Mar 2026; updated 24 Oct 2026
> Summary: India has social security agreements with 19 countries and Quebec. A certificate of coverage keeps a posted worker at home for up to 72 months.

*Written by CA Nandini Hasija, Krystal7 Consultants. Last updated 23 October 2026.*

## AI Overview Summary

- EPFO lists social security agreements in operation with 19 countries and Quebec, from Belgium on 1 Sep 2009 to Brazil on 1 Jan 2024. The UK convention on contributions only started on 15 Jul 2026.
- A worker posted between India and an agreement country stays in the home scheme for the detachment period, usually 60 months, only with a certificate of coverage from the home authority.
- An expat in India with a valid foreign certificate is an excluded employee under paragraph 2 of the EPF Scheme, 2026. Without it, PF membership starts on the first day under paragraph 9(5).
- Indian staff posted to an agreement country apply for the Indian certificate on EPFO's International Workers Portal with their UAN. The employer attests the application and the EPFO Regional Office approves it.
- Paragraph 69 of the EPF Scheme, 1952, upheld on 4 Nov 2025, let a worker from a non agreement country such as the US withdraw PF only at 58 or on incapacity.

**India has social security agreements in operation with 19 countries and the Canadian province of Quebec, as listed by the Employees' Provident Fund Organisation (EPFO). A contributions only convention with the UK started on 15 Jul 2026. A posted worker with a certificate of coverage keeps paying into the home scheme for the detachment period, usually 60 months. EPFO issues the Indian certificate online.**

This page is for foreign parents that second staff to India, Indian companies that post staff abroad, and the payroll teams that run both. It covers the country list, the certificate of coverage, totalisation, PF withdrawal for international workers and the changes under the Code on Social Security, 2020.

## What is a social security agreement in India?

A social security agreement (SSA) is a bilateral treaty that coordinates India's provident fund and pension schemes with another country's scheme. It stops a posted worker paying into two schemes at once. It also counts service in both countries for pension and lets benefits be paid abroad. EPFO is the Indian agency for every agreement.

EPFO's [International Workers page](https://www.epfindia.gov.in/site_en/International_workers.php) says EPFO is authorised to issue the certificate of coverage. It issues it to employees posted to countries with an agreement. EPFO's [brochure on international workers](https://www.epfindia.gov.in:443/site_docs/PDFs/Updates/Brochure_on_International_Workers_17082022.pdf) of 17 Aug 2022 lists four benefits:

1. **Detachment.** A posted worker stays in the home scheme and pays nothing in the host country for the period the agreement sets.
2. **Totalisation.** Service in the other country counts towards eligibility for an Indian pension. India then pays a pension only for Indian service, on a pro rata basis.
3. **Portability.** Pension is paid without reduction, direct to the beneficiary, whether they live in India or elsewhere.
4. **Equality of treatment.** Nationals of one country get the same treatment as the host country's nationals under the covered law.

An agreement covers pensions, not every Indian labour benefit. Article 2 of the [India France agreement](https://www.mea.gov.in/images/pdf/ssa-france.pdf) lists, for India, old age and survivors' pension and the permanent total disability pension for employed persons. Article 1 names EPFO as the Indian competent agency. Employees' State Insurance and gratuity sit outside the agreements, so an expat stays inside both where the Code on Social Security applies.

The Union Cabinet's [approval of the Brazil agreement](https://www.pib.gov.in/Pressreleaseshare.aspx?PRID=1595963) on 11 Dec 2019 described the same three core features: detachment, totalisation and exportability. It said India had signed agreements with 18 countries at that date.

## Which countries have a social security agreement with India?

EPFO's International Workers page lists 20 operating agreements: 19 countries and the Canadian province of Quebec. They start with Belgium on 1 Sep 2009 and end with Brazil on 1 Jan 2024. The UK and India Double Contributions Convention took effect on 15 Jul 2026. India has no agreement with the United States, the UAE or Singapore.

EPFO publishes one page per agreement. Each states the date of effect and the posting period during which contributions stay in the home country. Where we could read the agreement text on the [labour ministry site](https://labour.gov.in/sites/default/files/brazil.pdf), we checked the page against it. Where neither could be read, the table uses EPFO's 2022 brochure.

| Country | Date of effect | Detachment period (months) | Source |
|---|---|---|---|
| Belgium | 1 Sep 2009 | 60 | Country page |
| Germany | 1 Oct 2009 | 48 | Country page |
| Switzerland | 29 Jan 2011 | 72 | Country page; agreement, Article 5 |
| Denmark | 1 May 2011 | 60 for Indian workers posted to Denmark; 36 for Danish workers posted to India | Agreement, Article 8 (country page shows 60 for both) |
| Luxembourg | 1 Jun 2011 | 60 | 2022 brochure (5 years) |
| France | 1 Jul 2011 | 60 | Country page |
| Republic of Korea | 1 Nov 2011 | 60 | Agreement, Article 7 |
| Netherlands | 1 Dec 2011 | 60 | Country page |
| Hungary | 1 Apr 2013 | 60 | Country page |
| Finland | 1 Aug 2014 | 60 | Country page |
| Sweden | 1 Aug 2014 | 24 | Country page |
| Czech Republic | 1 Sep 2014 | 60 | 2022 brochure (5 years) |
| Norway | 1 Jan 2015 | 60 | Country page |
| Austria | 1 Jul 2015 | 60 | Country page |
| Canada | 1 Aug 2015 | 60 | Country page |
| Australia | 1 Jan 2016 | 60 | Country page |
| Japan | 1 Oct 2016 | 60 | Country page; agreement, Article 7 |
| Quebec (Canada) | 1 Apr 2017 | 60 | Country page |
| Portugal | 8 May 2017 | 60 | Country page; agreement, Article 8 |
| Brazil | 1 Jan 2024 | 36, extendable by 24 with the consent of both authorities | Agreement, Article 11 (country page shows the 60 month outer limit) |
| United Kingdom | 15 Jul 2026 | 60 | PIB, 17 Jun 2026; UK government explainer |

Five rows need care:

1. **Sweden** allows only 24 months, so a three year posting to Stockholm outlasts the exemption.
2. **Germany** allows 48 months.
3. **Switzerland** allows 72 months, the longest on the list.
4. **Denmark** has two limits. Article 8(2) of the agreement keeps a Danish worker posted to India in the Danish scheme only for postings not expected to exceed three years. EPFO's country page shows 60 months for both sides, so we plan Danish inbound postings on 36 months.
5. **Brazil** allows 36 months under Article 11(2)(e) of the agreement. Article 11(3) lets both competent authorities extend that by 24 months in writing. EPFO's page shows the 60 month total, and its 2022 brochure showed three years.

Quebec runs its own pension plan, so India signed a separate understanding with Quebec in addition to the Canada agreement.

The Ministry of External Affairs also keeps a [list of agreements](https://www.mea.gov.in/social-security-agreements). The list carries no date. On 23 Oct 2026 it still showed the Japan and Portugal agreements and the Quebec understanding as not in force, and it did not list the UK convention. We rely on EPFO's country pages and the agreement texts, because EPFO administers the agreements.

## What is a certificate of coverage?

A certificate of coverage (CoC) is the document that proves a posted worker stays in the home country's scheme. The home country's authority issues it for the posting dates. The host country then exempts the worker from its own contributions for those dates. Without the certificate, the host country's law applies from the first day.

The certificate works in both directions:

- **Inbound.** A French engineer posted to India gets a French certificate from the French authority. The Indian employer keeps it on file and shows it to EPFO on inspection.
- **Outbound.** An Indian engineer posted to Japan gets an Indian certificate from EPFO. The Japanese host shows it to the Japanese authority.

The certificate is valid only for the period it states, inside the agreement's limit. Paragraph 15(e) of EPFO's [handbook on international workers](https://www.epfindia.gov.in/site_docs/PDFs/Operating_SSAs_PDFs/Hand_Book.pdf) makes the employer jointly responsible for misuse. The employer must report any change in the employee's status during the posting.

EPFO had issued 3,34,322 certificates by 27 Jul 2022, of which 29,008 were active on that date, according to its 2022 brochure.

## Who is an international worker under EPF?

An international worker is an employee holding a non Indian passport who works for an establishment in India covered by PF. The term also covers an Indian employee who has worked, or will work, in a country with an agreement with India and is eligible for its benefits under that agreement. Paragraph 2 of the Employees' Provident Funds Scheme, 2026 defines the term.

The [EPF Scheme, 2026](https://egazette.gov.in/WriteReadData/2026/273957.pdf), G.S.R. 525(E), took effect on 29 Jun 2026. It carries forward the definition from paragraph 83 of the EPF Scheme, 1952, which the Delhi High Court reproduced in its judgment of 4 Nov 2025. Both texts count an Indian employee only if they are or will be eligible for the other country's benefits under the agreement.

The passport decides the category, not residence or origin:

- An Overseas Citizen of India cardholder with a Canadian passport is an international worker.
- A foreign national hired locally in India is an international worker.
- An Indian employee posted to Germany, and eligible for German benefits under the agreement, is an international worker.
- An Indian employee posted to the United States is not, because the United States has no agreement with India.
- Nepalese and Bhutanese nationals count as Indian workers, according to [EPFO's FAQs](https://pmvbry.epfindia.gov.in/faq-epfo/).

Every international worker in a covered establishment joins PF from the date of joining. EPFO's 2022 brochure names two groups outside that rule. The first is a national of an agreement country who holds a home country certificate. The second is a Singapore national contributing to the Singapore scheme under the India Singapore Comprehensive Economic Cooperation Agreement of 2005. Paragraph 2 of the 2026 scheme keeps the second group in general words. It excludes a worker exempt under a comprehensive economic agreement with a social security chapter concluded before 1 Oct 2008.

Our guide to [PF and ESI for foreign owned companies](/insights/pf-esi-foreign-owned-company-international-workers) covers registration thresholds, rates and due dates for the whole workforce.

## How does the detached worker exemption work for expats coming to India?

An expat posted to India by an employer in an agreement country is an excluded employee while their home certificate is valid. The Indian employer pays no PF for them. Paragraph 2 of the EPF Scheme, 2026 sets this exclusion. When the certificate lapses, paragraph 9(5) makes the expat a PF member at once.

Paragraph 2 excludes an international worker who contributes to the home country's scheme as its citizen or resident. India must have a reciprocal agreement with that country, and the worker must hold detached worker status under it. The exclusion lasts only for the period and on the terms the agreement sets.

Article 8(1) of the India France agreement shows the usual wording. A worker posted by an employer normally operating in one country stays under that country's law. The worker is exempt in the other country "for the maximum duration of 60 months".

The exemption has limits we see employers miss:

1. **It needs a posting.** A French national hired directly by the Indian subsidiary on a local contract is not detached. That person joins Indian PF.
2. **It needs the paper.** A promise that the certificate is on its way does not exclude anyone. We ask for the certificate before the first Indian payroll.
3. **It ends on a date.** The day after the certificate expires, paragraph 9(5) makes the expat a member.
4. **It is pension only.** ESI and gratuity still apply where the Code reaches the employee.

| Situation of a foreign employee in India | PF position | Rule |
|---|---|---|
| Posted from an agreement country with a valid home certificate | Excluded employee; no Indian PF | EPF Scheme, 2026, para 2 |
| Posted from an agreement country, certificate not yet issued | Member from the first day | EPF Scheme, 2026, para 9(5) |
| Posted from an agreement country, certificate expired | Member from the day after expiry | EPF Scheme, 2026, para 9(5) |
| Hired locally by the Indian company, any nationality | Member from the first day | EPF Scheme, 2026, para 9(5) |
| Singapore national contributing to the Singapore scheme | Excluded under the 2005 CECA, per EPFO | EPF Scheme, 2026, para 2; EPFO brochure, 17 Aug 2022 |
| National of the US, UAE or another country without an agreement | Member from the first day; no exclusion | EPF Scheme, 2026, paras 2 and 9(5) |

Visa status runs in parallel. A seconded expat needs an employment visa and, for most postings, FRRO registration within 14 days. Our notes on the [employment visa](/insights/employment-visa-india-for-foreign-employees) and [FRRO registration](/insights/frro-registration-foreign-employees-india) cover both.

## How does an Indian employer apply for a certificate of coverage from EPFO?

The employee applies online on EPFO's International Workers Portal, using their UAN and password. The employer verifies and attests the application with an electronic signature. The EPFO Regional Office approves or rejects it. The employee then downloads the certificate from the portal. EPFO's 2022 brochure sets out these steps.

The portal needs a UAN and a member ID. So only a PF member of a covered establishment can apply. An Indian start up below the PF threshold of 20 employees, with no voluntary coverage, has no Indian scheme to keep the employee in.

| Step | Who acts | What happens |
|---|---|---|
| 1. Log in to the International Workers Portal | Employee | Uses UAN and password; selects "Application for CoC" |
| 2. Select the member ID | Employee | Picks the member ID with the posting employer |
| 3. Enter detachment details | Employee | Gives the posting country, host and dates |
| 4. Upload the passport | Employee | Uploads a scanned passport copy |
| 5. Verify and attest | Employer | Checks the details and attests with an electronic signature in the employer login |
| 6. Approve or reject | EPFO Regional Office | Examines the application against the agreement |
| 7. Download | Employee | Downloads the approved certificate from the portal |

Source: EPFO brochure on international workers, 17 Aug 2022.

EPFO's brochure gives no processing time and no fee for the certificate. We file at least six weeks before the travel date. A host country authority can ask for the certificate at the first payroll in that country.

A posting longer than the agreement allows needs a different route. EPFO's [circular of 20 Nov 2018](https://www.epfindia.gov.in/site_docs/PDFs/Circulars/Y2018-2019/IWU_COC_20112018.pdf) (File No. IWU/7(31)2017) says a certificate beyond the agreement period needs the consent of the other country's competent authority. The process runs in four stages:

1. The employee and the employer file a joint application with the Regional Office for the establishment.
2. The Regional Office forwards it to EPFO Head Office with a recommendation based on the agreement.
3. The International Workers Unit at Head Office sends the request to the foreign competent authority.
4. Once consent arrives, Head Office informs the Regional Office, which may issue the extended certificate.

Under the same circular, the Regional Office that issued a certificate decides on its cancellation, change or extension. The officer in charge of the Regional Office is the final authority on disputes.

While the employee is abroad, the Indian employer keeps paying PF. EPFO's 2022 brochure says an Indian worker with a certificate pays nothing in the host country but must still contribute to EPFO on full salary. Without a certificate, the worker can end up paying in both countries.

## What is totalisation and how does it affect the Indian pension?

Totalisation adds insurance periods from both countries to decide whether a worker qualifies for a pension. Under the Employees' Pension Scheme, a member needs 10 years of eligible service for a monthly pension. An agreement lets the worker count foreign periods towards those 10 years. India then pays only for Indian service, on a pro rata basis.

Article 11 of the India France agreement counts the other country's periods where needed, so long as they do not overlap. Article 12 sets the pro rata method. The agency first computes a theoretical benefit as if all periods were under its own law. It then applies the ratio of its own periods to the total.

The Employees' Pension Scheme, 2026 (G.S.R. 527(E)) carries the rule forward. Paragraph 36 adds service under an agreement to actual service and pays pension under the agreement. Paragraph 2(g) uses the same international worker definition as the EPF scheme.

Portability means the pension follows the worker. EPFO's FAQs say a claimant from an agreement country can opt for payment of pension benefits in their home country.

Totalisation depends on the text of each agreement. The 2022 brochure table marks each agreement for detachment, totalisation and portability. We still read the agreement itself before we tell an employee that foreign years will count.

## When can an international worker withdraw PF?

Under the EPF Scheme, 1952, an international worker could withdraw the full PF balance on retirement after 58, or on permanent and total incapacity. A worker covered by an agreement could also withdraw on ceasing employment in India. A worker from a country without an agreement had no such exit. The Delhi High Court upheld these rules on 4 Nov 2025.

The Delhi High Court decided SpiceJet Ltd v Union of India (W.P.(C) 2941/2012) on 4 Nov 2025. It heard the LG Electronics India Private Limited petition (W.P.(C) 6330/2021) with it. The [judgment](https://delhihighcourt.nic.in/app/showFileJudgment/68304112025CW29412012_155558.pdf) reproduces the withdrawal grounds in paragraph 69. Paragraph 69(1)(a) allows withdrawal "on retirement from service in the establishment at any time after the attainment of 58 years". Paragraph 69(4) covers members under an agreement, on ceasing to be an employee in a covered establishment.

The Court found the classification reasonable. It noted that foreign workers usually spend two to five years in India. It declined to follow an earlier Karnataka High Court decision in Stone Hill Education Foundation, which had struck down paragraph 83.

The 2026 scheme keeps the structure. Paragraph 10(2) keeps an international worker a member until one of three events:

1. Full withdrawal under paragraph 49.
2. An exemption under section 143 of the Code or paragraph 12 of the scheme.
3. Settlement of benefits under the agreement with the home country.

Paragraph 42(1) of the 2026 scheme refers to final payment on a claim under paragraph 49 or 50, so paragraph 49 now holds the withdrawal grounds. The Gazette copy of G.S.R. 525(E) that we could read gave paragraphs 1 to 45 only. Read paragraph 49 in the Gazette text, or ask the EPFO Regional Office, before you tell an expat when they can withdraw. Until EPFO issues guidance, we brief expats on the 1952 grounds.

Pension follows separate rules. EPFO's FAQs say only international workers covered by an agreement get the EPS withdrawal benefit. They must have under 10 years of eligible service even after totalisation. Workers from countries without an agreement get no EPS withdrawal benefit. Paragraph 36(3) of the EPS, 2026 adds a wait for a worker who leaves before superannuation age. The benefit is payable 36 months after the last contribution due date, or at superannuation age if that comes first.

| Exit point | Worker from an agreement country | Worker from a country without an agreement |
|---|---|---|
| Leaves India before 58 | Withdraws PF on ceasing employment, as the agreement provides | Cannot withdraw; balance stays with EPFO |
| Reaches 58 | Withdraws PF | Withdraws PF |
| Permanent and total incapacity | Withdraws PF | Withdraws PF |
| EPS with under 10 years after totalisation | EPS withdrawal benefit; after 36 months if the worker leaves early (EPS, 2026, para 36(3)) | No EPS withdrawal benefit |
| EPS with 10 years or more | Pro rata pension for Indian service, payable abroad | Pension under the scheme |
| Source | EPF Scheme, 1952, para 69, upheld 4 Nov 2025; EPFO FAQs; check para 49 of the 2026 scheme | Same |

The balance keeps earning interest while it waits. For a US national who leaves India at 35, that can mean 23 years before access.

## What do international workers contribute, and does the wage ceiling apply?

EPFO collects PF from international workers on full salary, with no wage ceiling. Its 2022 brochure says contributions are payable "on full salary, irrespective of the wage ceiling". The EPF Scheme, 2026 is less clear. Paragraph 18(3) makes every member's contribution subject to the notified ceiling, which became INR 25,000 a month on 17 Sep 2026.

The Delhi High Court judgment of 4 Nov 2025 records the old rule. Indian employees were covered only up to the INR 15,000 pay limit. Non excluded international workers were covered whatever their pay. The Court held the difference reasonable under Article 14.

The 2026 text points both ways:

- Paragraph 18(3) caps contributions at the ceiling the Centre notifies, with no carve out for international workers.
- Paragraph 9(4) lets employer and employee jointly choose to contribute above the ceiling.
- Paragraph 9(6) has a table with one country, the United Kingdom. An employee working in a listed country who opts for detachment contributes on total wages.

We found no EPFO circular on the wage base for international workers under the 2026 scheme. Our course is to keep paying on full wages until EPFO says otherwise in writing. Underpaying brings arrears, damages and interest. Overpaying only builds the employee's balance.

The base is "wages" under section 2(88) of the [Code on Social Security, 2020](https://www.labour.gov.in/static/uploads/2025/07/b0620548445580767b5c0d18c95c26f7.pdf). Basic pay and dearness allowance count. Excluded allowances above half of total pay come back in. Our guide to the [new labour codes](/insights/new-labour-codes-foreign-owned-companies-india) works through the 50 percent test.

Full salary PF has an income tax cost for senior staff. [Section 17(1)(h)](https://www.incometaxindia.gov.in/w/section-17-225) of the Income Tax Act, 2025 covers employer contributions to a recognised provident fund and two other retirement schemes. The total above INR 7,50,000 in a tax year is a perquisite. Clause (i) adds the yearly interest on that excess. Our note on [tax residency for foreign employees](/insights/tax-residency-foreign-employees-india-182-day-rule) covers the rest of the expat tax picture.

## How does the Code on Social Security change the rules for international workers?

The Code on Social Security, 2020 took effect on 21 Nov 2025 under S.O. 5319(E). PF moved across in stages. The EPF Scheme, 1952 and its paragraph 83 stayed in use until the EPF Scheme, 2026 replaced them on 29 Jun 2026. The new scheme keeps the international worker framework but spreads it across new paragraphs.

At the 15 Mar 2026 publish date of this guide, paragraph 83 still governed international workers. The Press Information Bureau's [release of 2 Sep 2026](https://www.pib.gov.in/PressReleasePage.aspx?PRID=2305867) records that the EPF Scheme, 2026 was notified on 29 Jun 2026.

Section 15 of the Code lets the Central Government frame the EPF scheme, covering the matters in the Fifth Schedule. Section 16(1)(a) sets the base contribution at 10 percent of wages. The Centre restored 12 percent for notified establishments by S.O. 3582(E) of 1 Jul 2026. Section 2(89) leaves the wage ceiling to notification.

| Topic | EPF Scheme, 1952 | EPF Scheme, 2026 |
|---|---|---|
| Definition of international worker | Para 83, clause (ja) | Para 2 |
| Exclusion for detached workers | Para 83, clause (f) | Para 2, excluded employee, clause (ii) |
| Membership from the date of joining | Para 83 | Para 9(5) |
| Detachment for listed countries on total wages | None | Para 9(6), table lists the UK only |
| Membership until withdrawal or agreement settlement | Para 83 | Para 10(2) |
| Withdrawal grounds | Para 69 | Para 49, read with para 10(2) |
| Statements of international workers | Monthly return through the employer portal | Para 24(3) |
| Pension service under an agreement | EPS, 1995, para 43A | EPS, 2026, para 36 |

Paragraph 24(3) of the 2026 scheme sets two filing duties. Within 15 days of the scheme applying to an establishment, the employer files a consolidated statement of international workers, with nationality and wages. A nil statement is due if there are none. Every month, within 15 days of the month end, the employer uploads joiners, transfers in and leavers among international workers.

The Code also widened PF coverage. Chapter III applies to establishments with 20 or more employees in any industry, under the First Schedule. More Indian companies now have a PF code, and so a route to an Indian certificate for staff they post abroad.

## What about countries without an agreement, such as the US, UAE and Singapore?

A national of a country without an agreement gets no exemption in India. They join PF from the first day as an international worker. Under the withdrawal rules the Delhi High Court upheld on 4 Nov 2025, they could not withdraw on leaving India. EPFO's list has no agreement with the United States or the UAE. Singapore nationals have a separate exclusion under the 2005 CECA, according to EPFO's 2022 brochure.

For a US hire, the exit rule is the hard part. On the 1952 grounds, the PF balance stays in India until 58 or permanent and total incapacity. We put this in the offer letter, because expats often assume they can take the money home.

For outbound postings to these countries, the Indian employee is not an international worker. They stay in Indian PF as an ordinary employee, if covered. The host country's own rules then decide whether they also pay there. A US posting usually brings US social security tax, so ask a US adviser before the move.

For Singapore, the exclusion depends on the worker contributing to the Singapore scheme. We ask for proof of that before we leave a Singapore national out of PF. Paragraph 2 of the 2026 scheme describes the exempting agreement without naming Singapore, and the India Singapore CECA of 2005 fits that description. EPFO's 2022 brochure names Singapore. We have not seen an EPFO circular that applies the exclusion under the 2026 scheme.

Many US groups use an employer of record for one or two early hires. The PF rules apply to the employer of record just the same. Our comparison of an [employer of record and a subsidiary](/insights/employer-of-record-vs-subsidiary-india) covers that choice.

## What does the UK convention change?

The UK and India Double Contributions Convention took effect on 15 Jul 2026, with the trade agreement. A detached worker stays in the home scheme for up to 60 months. The convention covers contributions only. It gives no totalisation and no access to UK benefits such as the State Pension.

The [PIB release of 17 Jun 2026](https://www.pib.gov.in/PressReleasePage.aspx?PRID=2274280) announced the date. It said the exemption period "has been increased from 3 years to 5 years". It also expects more than 75,000 Indian professionals and over 900 companies to benefit.

The [UK government's explainer](https://www.gov.uk/government/publications/uk-india-trade-deal-double-contributions-convention-explainer/uk-india-double-contributions-convention-dcc-explainer) says the UK's 52 week exemption extends to 60 months for detached workers. Indian detached workers keep paying into the EPF scheme. They do not build UK State Pension rights. It describes the Indian payment as similar to what the worker would have paid in UK National Insurance.

Paragraph 9(6) of the EPF Scheme, 2026 gives effect to the Indian side. Its table names "United Kingdom of Great Britain and Northern Ireland". An employee working in a listed country who opts for detachment contributes on total wages under section 2(88) of the Code. We read it as aimed at Indian employees posted to the UK.

For UK groups with Indian subsidiaries, the change cuts the cost of short secondments both ways. Our note on the [UK India trade agreement](/insights/uk-india-free-trade-agreement-impact-on-businesses) covers the rest of the deal.

## What changed in 2026

The agreements themselves did not change in 2026, apart from the new UK convention. The rules around them did. The Code moved PF to a new scheme, the UK convention started, and the wage ceiling rose.

| Date | Old position | New position | Instrument |
|---|---|---|---|
| 4 Nov 2025 | Karnataka High Court had struck down paragraph 83 | Delhi High Court Division Bench upheld paragraphs 83 and 69 | SpiceJet and LG Electronics judgment |
| 21 Nov 2025 | EPF and Miscellaneous Provisions Act, 1952 | Code on Social Security, 2020 in force; PF moved in stages | S.O. 5319(E) |
| 8 May 2026 | Rules under the old Acts | Social Security (Central) Rules, 2026 | G.S.R. 344(E) |
| 29 Jun 2026 | EPF Scheme, 1952, paragraph 83 | EPF Scheme, 2026, paragraphs 2, 9, 10 and 24(3) | G.S.R. 525(E) |
| 29 Jun 2026 | EPS, 1995, paragraph 43A | EPS, 2026, paragraphs 2(g) and 36 | G.S.R. 527(E) |
| 1 Jul 2026 | 12% rate under the 1952 Act | 12% under the first proviso to section 16(1)(a) of the Code | S.O. 3582(E) |
| 15 Jul 2026 | No UK convention in EPFO's list | UK convention in force; detached workers exempt up to 60 months | India UK Double Contributions Convention |
| 17 Sep 2026 | Wage ceiling INR 15,000 | Wage ceiling INR 25,000; wage base for international workers not clarified | S.O. 5109(E) |

### What has happened since 15 Mar 2026

This guide was first published on 15 Mar 2026. At that date, paragraph 83 of the 1952 scheme still governed international workers, and the UK was not in EPFO's list. Four changes came later:

1. The Social Security (Central) Rules, 2026 took effect on 8 May 2026.
2. The EPF Scheme, 2026 and the EPS, 2026 replaced the 1952 and 1995 schemes on 29 Jun 2026.
3. The UK convention took effect on 15 Jul 2026.
4. The PF wage ceiling rose to INR 25,000 on 17 Sep 2026, with no word yet on international workers.

## Worked example

### A Japanese secondee in India

A Japanese parent seconds an engineer to its Indian Private Limited subsidiary in Pune. The posting runs for four years from 1 Dec 2026. Code wages are INR 4,00,000 a month. Japan's agreement allows 60 months, so a four year posting fits.

| Monthly figures (INR) | Case A: no Japanese certificate | Case B: Japanese certificate for 1 Dec 2026 to 30 Nov 2030 |
|---|---|---|
| Code wages | 4,00,000 | 4,00,000 |
| Employee PF at 12% | 48,000 | Nil |
| Employer PF at 12% | 48,000 | Nil |
| Employer PF a year | 5,76,000 | Nil |
| Employer PF over four years | 23,04,000 | Nil |
| Employee PF over four years | 23,04,000 | Nil |
| Japanese contributions | Also payable under Japanese law | Continue under Japanese law |

**Step 1.** Check the passport. A Japanese passport makes the engineer an international worker under paragraph 2 of the EPF Scheme, 2026.

**Step 2.** Check the certificate. In Case B, the engineer is an excluded employee for the certificate dates. The subsidiary keeps a copy on file.

**Step 3.** Compute Case A. Paragraph 9(5) makes the engineer a member from 1 Dec 2026. On full wages, each side pays 12 percent of INR 4,00,000, or INR 48,000 a month. EDLI and administration charges come on top, at the notified rates.

**Step 4.** Check the tax. Employer PF of INR 5,76,000 a year is below the INR 7,50,000 limit in section 17(1)(h). It is not a perquisite, unless the employer also pays into the two other schemes that clause names.

**Step 5.** Plan the exit. In Case A, Japan has an agreement with India. On the 1952 grounds, the engineer could withdraw on ceasing employment, as the agreement provides. We check paragraph 49 of the 2026 scheme before the exit. The four year PF account holds INR 46,08,000 before interest.

**Step 6.** Diary the end date. If the posting runs past 30 Nov 2031, the 60 month limit, the engineer joins PF from 1 Dec 2031. An extension needs the Indian authority's consent through the Japanese side.

### An Indian engineer posted to Germany

A Bengaluru company posts an engineer to a client in Munich. The posting runs for 54 months from 1 Jan 2027. Code wages are INR 2,50,000 a month. Germany's agreement allows 48 months.

1. The engineer applies for an Indian certificate on the International Workers Portal. The employer attests it, and the Regional Office approves 1 Jan 2027 to 31 Dec 2030, which is 48 months.
2. The remaining six months exceed the agreement. The employee and employer file a joint application for an extension. It goes through EPFO Head Office to the German competent authority under the 2018 circular.
3. Indian PF continues on full salary throughout, on EPFO's stated position. Each side pays 12 percent of INR 2,50,000, or INR 30,000 a month. Employer PF comes to INR 3,60,000 a year.
4. If German consent does not arrive, German contributions apply from 1 Jan 2031. Indian PF also continues, so the last six months cost both schemes.

### Totalisation for an EPS pension

An Indian employee has 6 years of EPS service in India and 5 years of insurance in Canada. The total is 11 years, which meets the 10 year test for an EPS pension. India pays a pension for the 6 Indian years on a pro rata basis.

With only 3 Canadian years, the total is 9 years. The employee then gets the EPS withdrawal benefit under paragraph 36(3) of the EPS, 2026. If they leave before superannuation age, it is paid 36 months after the last contribution due date, or at superannuation age if earlier.

## Common mistakes

1. **Treating a locally hired foreign national as detached.** Detachment needs a posting by a home country employer. Fix: enrol local hires in PF from the first day, whatever their passport.
2. **Starting payroll before the certificate arrives.** Paragraph 9(5) makes the expat a member from joining. Fix: collect the home certificate before the first Indian payroll, or enrol the expat and stop on receipt.
3. **Ignoring the short limits.** Most agreements allow 60 months, but Sweden allows 24, and Brazil and Danish postings to India allow 36. Fix: read the table above and diary the limit for each country.
4. **Letting a certificate lapse.** Membership starts the day after expiry. Fix: diary every expiry date and start an extension three months before it.
5. **Posting Indian staff abroad without an Indian certificate.** The host country then charges its own contributions on top of Indian PF. Fix: apply on the International Workers Portal at least six weeks before travel.
6. **Stopping Indian PF during an outbound posting.** EPFO expects contributions on full salary while the certificate runs. Fix: keep the employee on the Indian payroll for PF.
7. **Telling a US hire they can withdraw PF on leaving.** Under the rules upheld on 4 Nov 2025, a worker without an agreement waits until 58. Fix: state the withdrawal rule in the offer letter, after checking paragraph 49 of the 2026 scheme.
8. **Capping an expat's PF at INR 25,000.** EPFO has not confirmed that the ceiling applies to international workers. Fix: contribute on full wages until EPFO says otherwise in writing.
9. **Assuming the agreement covers ESI and gratuity.** The agreements cover pensions only. Fix: apply ESI and gratuity rules to expats as to anyone else.
10. **Missing the paragraph 24(3) returns.** The 2026 scheme asks for a consolidated statement and monthly updates on international workers. Fix: add them to the monthly PF calendar.

Our [EPFO compliance team](/services/payroll-management.html) can review a secondment file and its certificates before the first payroll.

## Checklist

1. Record the passport country of every employee at onboarding.
2. Mark every international worker in the payroll master, including Indian staff posted to agreement countries.
3. Check whether the home country appears in EPFO's list of operating agreements.
4. Read the detachment limit for that country and compare it with the posting dates.
5. Collect the home country certificate before the first Indian payroll for each inbound secondee.
6. Enrol in PF from the first day every international worker without a valid certificate.
7. Contribute on full wages for international workers until EPFO issues guidance on the 2026 wage base.
8. File the paragraph 24(3) consolidated statement and the monthly updates on international workers.
9. Apply for an Indian certificate on the International Workers Portal at least six weeks before each outbound posting.
10. Attest each outbound application with the employer's electronic signature.
11. File a joint extension application early where a posting will pass the agreement limit.
12. Diary each certificate's expiry and the agreement's maximum period.
13. Brief every expat in writing on withdrawal rules, EPS and the section 17(1)(h) perquisite limit.
14. Keep copies of every certificate for EPFO inspection and for the host country authority.

## Key terms

- **Social Security Agreement (SSA)**: A bilateral agreement that lets an employee posted between India and another country stay in the home social security scheme for a fixed period. The India France agreement allows up to 60 months, and the India UK Double Contributions Convention applies from 15 Jul 2026 and covers contributions only. (https://krystal7.com/glossary#social-security-agreement)
- **Certificate of Coverage (CoC)**: A certificate from the home country's social security authority that a posted employee stays in the home scheme under a social security agreement. In India it makes the expat an excluded employee under paragraph 2 of the EPF Scheme, 2026, so no PF is payable while it is valid. (https://krystal7.com/glossary#certificate-of-coverage)
- **International worker**: Under paragraph 2 of the Employees' Provident Funds Scheme, 2026, an employee holding a non Indian passport working for a covered establishment in India, or an Indian employee who has worked or will work in an agreement country and is eligible for its benefits under that agreement. Nepalese and Bhutanese nationals count as Indian workers. (https://krystal7.com/glossary#international-worker)
- **Detached worker**: An employee whom the employer posts temporarily from one agreement country to the other while keeping them on the home payroll. India's social security agreements let a detached worker pay only into the home scheme for a fixed period, set in each agreement's article on posted or detached workers. (https://krystal7.com/glossary#detached-worker)
- **Excluded employee (EPF)**: A person outside compulsory PF membership under paragraph 2 of the Employees' Provident Funds Scheme, 2026. It includes an international worker who pays into the home scheme and either holds detached worker status under a social security agreement, for the period it allows, or is exempt under an economic agreement with a social security chapter concluded before 1 Oct 2008. (https://krystal7.com/glossary#excluded-employee)
- **Totalisation**: The rule in a social security agreement that adds insurance periods completed in both countries to decide whether a person qualifies for a pension. Each country then pays a pension only for its own periods, on a pro rata basis. In India it applies to the Employees' Pension Scheme. (https://krystal7.com/glossary#totalisation)
- **Universal Account Number (UAN)**: The permanent number EPFO allots to each provident fund member, which links every member ID the person holds with different employers. An Indian employee needs an active UAN and member ID to apply for a certificate of coverage on EPFO's International Workers Portal. (https://krystal7.com/glossary#universal-account-number)

## Frequently Asked Questions

### How many countries have a social security agreement with India?

EPFO lists 20 operating agreements: 19 countries and the Canadian province of Quebec. Belgium was first, from 1 Sep 2009, and Brazil the latest, from 1 Jan 2024. The UK and India Double Contributions Convention, covering contributions only, also took effect on 15 Jul 2026.

### Does India have a social security agreement with the United States?

No. EPFO's list of operating agreements does not include the United States. A US national working for an Indian establishment covered by PF is an international worker. They join PF from the first day under paragraph 9(5) of the EPF Scheme, 2026. Under the rules upheld on 4 Nov 2025, they could not withdraw on leaving India.

### What is a certificate of coverage in India?

It is the document from the home country's authority confirming that a posted worker stays in the home scheme. For an expat in India, the foreign authority issues it and the expat becomes an excluded employee under paragraph 2 of the EPF Scheme, 2026. For Indian staff going abroad, EPFO issues it.

### How do I get a certificate of coverage from EPFO?

The employee logs in to EPFO's International Workers Portal with their UAN. They select "Application for CoC", pick the member ID, enter the posting details and upload a passport copy. The employer attests the application with an electronic signature. The EPFO Regional Office approves it, and the employee downloads the certificate.

### How long does a certificate of coverage last?

For the posting period it states, within the agreement's limit. Most of India's agreements allow 60 months. Germany allows 48, Sweden 24 and Switzerland 72, according to EPFO's country pages. Brazil allows 36, and Denmark allows a Danish worker posted to India 36, under the agreement texts. A longer posting needs the other country's consent.

### Can a certificate of coverage be extended beyond the agreement period?

Yes, but only with the consent of the other country's competent authority. EPFO's circular of 20 Nov 2018 requires a joint application from employee and employer to the Regional Office. The Regional Office forwards it to Head Office, which seeks the foreign authority's consent. Apply well before the certificate expires.

### Do expats with a certificate of coverage pay PF in India?

No, not while the certificate is valid. Paragraph 2 of the EPF Scheme, 2026 treats such an expat as an excluded employee. The expat must be a detached worker under a reciprocal agreement. On the day after the certificate expires, paragraph 9(5) makes them a PF member.

### Do Indian employees posted abroad still pay Indian PF?

Yes, if they are posted to an agreement country under an Indian certificate. EPFO's 2022 brochure says they pay nothing in the host country but must contribute to EPFO on full salary. For the UK, paragraph 9(6) of the EPF Scheme, 2026 sets contributions on total wages for detached workers.

### When can a foreign employee withdraw PF in India?

Paragraph 69 of the EPF Scheme, 1952 allowed withdrawal after 58 or on permanent and total incapacity. The Delhi High Court upheld it on 4 Nov 2025. A worker covered by an agreement could also withdraw on ceasing employment. Paragraph 49 of the 2026 scheme now holds the grounds, so read it or ask EPFO first.

### What is totalisation under a social security agreement?

Totalisation adds insurance periods in both countries to decide eligibility for a pension. Under the Employees' Pension Scheme, a member needs 10 years. Paragraph 36 of the EPS, 2026 adds agreement service to actual service. India then pays only for Indian service, on a pro rata basis.

### Can a worker from an agreement country get pension paid abroad?

Yes. EPFO's FAQs say a person covered by an agreement can opt for payment of pension benefits in their home country, because the agreements provide portability. Article 5 of the India France agreement, for example, bars reducing a benefit only because the beneficiary lives in the other country.

### Do social security agreements cover ESI and gratuity?

No. The agreements cover India's pension and provident fund schemes run by EPFO. Article 2 of the India France agreement lists, for India, only old age, survivors' and permanent total disability pensions. ESI under Chapter IV and gratuity under Chapter V of the Code on Social Security still apply.

### Are Singapore nationals exempt from PF in India?

They can be. EPFO's brochure of 17 Aug 2022 excludes Singapore nationals who contribute to their home scheme under the India Singapore CECA of 2005. Paragraph 2 of the EPF Scheme, 2026 keeps an exclusion for such pre 2008 economic agreements. India has no social security agreement with Singapore. Keep proof of Singapore contributions on file.

### Does the UK convention give UK State Pension credit for time in India?

No. The UK and India Double Contributions Convention, in force from 15 Jul 2026, covers contributions only. The UK government's explainer says detached workers stay in the home scheme for up to 60 months but build no UK State Pension rights. There is no totalisation under the convention.

### Does the INR 25,000 PF wage ceiling apply to international workers?

EPFO has not said. Its 2022 brochure collects contributions on full salary, irrespective of the ceiling. Paragraph 18(3) of the EPF Scheme, 2026 makes contributions subject to the notified ceiling, with no carve out. The ceiling rose to INR 25,000 on 17 Sep 2026. We contribute on full wages until EPFO clarifies in writing.

### What changed for international workers under the Code on Social Security?

The EPF Scheme, 2026 replaced paragraph 83 of the 1952 scheme on 29 Jun 2026. The definition moved to paragraph 2, membership to paragraph 9(5), continuation to paragraph 10(2) and statements to paragraph 24(3). Paragraph 9(6) added a UK detachment rule. EPS, 2026 paragraph 36 keeps totalisation.

## Sources

- Employees' Provident Fund Organisation, International Workers page, accessed 23 Oct 2026, https://www.epfindia.gov.in/site_en/International_workers.php
- Employees' Provident Fund Organisation, Operating SSA country pages (Belgium, Germany, Switzerland, Denmark, France, Netherlands, Hungary, Finland, Sweden, Norway, Austria, Canada, Australia, Japan, Quebec, Portugal, Brazil), accessed 23 Oct 2026, https://epfindia.gov.in/site_en/Operating_SSA.php
- Employees' Provident Fund Organisation, Brochure on International Workers, 17 Aug 2022, https://www.epfindia.gov.in:443/site_docs/PDFs/Updates/Brochure_on_International_Workers_17082022.pdf
- Employees' Provident Fund Organisation, Circular IWU/7(31)2017, Application for COC and COC software, 20 Nov 2018, https://www.epfindia.gov.in/site_docs/PDFs/Circulars/Y2018-2019/IWU_COC_20112018.pdf
- Employees' Provident Fund Organisation, Handbook on special provisions for international workers and the India Belgium agreement, undated, https://www.epfindia.gov.in/site_docs/PDFs/Operating_SSAs_PDFs/Hand_Book.pdf
- Ministry of Labour and Employment, Agreement on Social Security between India and Brazil, signed 25 Jan 2020 (Article 11), https://labour.gov.in/sites/default/files/brazil.pdf
- Ministry of Labour and Employment, Agreement on Social Security between India and Denmark (Article 8), https://labour.gov.in/sites/default/files/denmark.pdf
- Ministry of Labour and Employment, Agreement on Social Security between India and Switzerland (Article 5), https://labour.gov.in/sites/default/files/switzerland.pdf
- Ministry of Labour and Employment, Agreement on Social Security between India and Japan (Article 7), https://labour.gov.in/sites/default/files/japan.pdf
- Ministry of Labour and Employment, Agreement on Social Security between India and the Republic of Korea (Article 7), https://labour.gov.in/sites/default/files/korea.pdf
- Ministry of Labour and Employment, Agreement on Social Security between India and Portugal (Article 8), https://labour.gov.in/sites/default/files/portugal.pdf
- Employees' Provident Fund Organisation, FAQs (international workers and SSA withdrawal benefit), https://pmvbry.epfindia.gov.in/faq-epfo/
- Gazette of India, Employees' Provident Funds Scheme, 2026, G.S.R. 525(E), 29 Jun 2026, https://egazette.gov.in/WriteReadData/2026/273957.pdf
- Gazette of India, Employees' Pension Scheme, 2026, G.S.R. 527(E), 29 Jun 2026, https://egazette.gov.in/WriteReadData/2026/273951.pdf
- Ministry of Labour and Employment, The Code on Social Security, 2020, https://www.labour.gov.in/static/uploads/2025/07/b0620548445580767b5c0d18c95c26f7.pdf
- Press Information Bureau, Amnesty provisions in EPF Scheme 2026 (scheme notified on 29 Jun 2026), 2 Sep 2026, https://www.pib.gov.in/PressReleasePage.aspx?PRID=2305867
- Press Information Bureau, India and the United Kingdom CETA and Agreement on Social Security Contributions to enter into force on 15 Jul 2026, 17 Jun 2026, https://www.pib.gov.in/PressReleasePage.aspx?PRID=2274280
- Press Information Bureau, Cabinet approves Agreement on Social Security between India and Brazil, 11 Dec 2019, https://www.pib.gov.in/Pressreleaseshare.aspx?PRID=1595963
- UK Government, UK India Double Contributions Convention explainer, https://www.gov.uk/government/publications/uk-india-trade-deal-double-contributions-convention-explainer/uk-india-double-contributions-convention-dcc-explainer
- Ministry of External Affairs, Agreement on Social Security between India and France, https://www.mea.gov.in/images/pdf/ssa-france.pdf
- Ministry of External Affairs, Social Security Agreements list, https://www.mea.gov.in/social-security-agreements
- High Court of Delhi, SpiceJet Ltd v Union of India, W.P.(C) 2941/2012, with LG Electronics India Private Limited v Union of India, W.P.(C) 6330/2021, 4 Nov 2025, https://delhihighcourt.nic.in/app/showFileJudgment/68304112025CW29412012_155558.pdf
- Income Tax Department, Income Tax Act, 2025, section 17, https://www.incometaxindia.gov.in/w/section-17-225

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