Understanding PF Enrollment: Does a Holding Company Need to Register Under Section 2A?

Hi,

In this case, one holding company has three subsidiary companies. One of the subsidiary companies has the PF number, while the other subsidiary has not started its operations and is at an infant stage. Does the holding company have to enroll for the PF under section 2A of the PF Act?

Regards,
Rajesh

If the holding company and subsidiaries do not have separate registrations under the Factories/Shops and Commercial Establishments/Plantations/Mine Act, as the case may be, for PF applicability, all the units will be treated as one, and accordingly, the employees will be covered.

Regards, Madhu.T.K

Dear Madhu.T.K,

Thank you for the reply.

In this case, the holding and subsidiary are separate entities registered under the Companies Act and have separate licenses under the Shops and Establishment Act. Still, the holding company, having 14 employees, has to be registered with PF.

If you could provide clarification along with a couple of case law references, it would be advantageous.

Rajesh

If the holding company has never had a workforce exceeding 20 in the past, there is no chance of it being covered by PF. If you have separate registrations for each unit and separate financial statements for these units, you may present the same before the EPF Organisation.

Regards, Madhu.T.K