Facing EPF and ESI Challenges in a Small Firm: What Are the Implications and Solutions?

pritamraju
I work in a small partnership firm that engages in a security and housekeeping personnel business. The firm has just three people who run the office, including me, and their job profiles are: a) Managing Partner, b) Chief Operations Officer, c) Chief Financial Officer. The firm entrusted me with the latter option, but in reality, it’s just a description with no actual powers whatsoever. The reason I write this post is due to a peculiar problem that was ignored (my assumption) for a long time and has now snowballed into a major issue.

The EPF Registration Issue

The firm, in order to be eligible to get contracts, tried to obtain every license and registration necessary for the smooth running of the business. In this process, it applied for EPF registration, with no workers to show, and somehow got it by adding 19 members and then putting them on the excluded list. So, in a sense, what they seem to believe is that they got the EPF registration and have no people to show for it. I found that information confusing. Later on, when we started getting business contracts and eventually hiring a few workers, it was found that the workers’ EPF money was not being credited to the accounts of the respective workers. When questioned, the COO answered that they did not meet the criteria of 20 people to deposit on the very first instance. I found that shocking and tried to explain to him that the 20 people criteria was for registration purposes only, and after registration, even if the number falls below 20, the EPF can still be paid, but it fell on deaf ears.

Current Situation and Dilemma

This month, i.e., June 2016, the company finally had the required numbers to make the "payments," but the dilemma is, the company started doing business in January 2016, and their EPF and ESI monies were being deducted from January itself, and as mentioned above, they were not deposited.

Summary of the Situation

1. The firm had around 8-16 employees from January to mid-May 2016.
2. The firm crossed 20 employees this June 2016.
3. The firm cut EPF and ESI for January.
4. The ESI registration is still not made; I wonder what the problem is this time.
5. The client is now asking for EPF and ESI challans, which the firm doesn’t have.

Now, my question is: what are the implications of the above scenario, and what is the solution to it? On the same note, I have calculated their EPF and ESI on the minimum wage rate prevalent in Odisha. Since they are wage workers, they get paid on a day-to-day basis and are not paid for any leave taken. The rates have been calculated on minimum wages * 26 days divided by 26 days * the days they worked. I hope this long post contains all the relevant information needed, and I can provide more information if needed to make this more conclusive.

Thank you in advance.
nathrao
Legal Implications of Non-Compliance with EPF and ESIC Regulations

Deduction of EPF and ESIC contributions without deposit can subject the company and its concerned officers to fines, penalties, and legal action. Please refer to the Penal Provisions under Sections 84 to 86 of the ESI Act, 1948 (as amended) and the EPF Act.

Penalties Under EPF Act

"Section 14. Penalties. X X X X (2-A). Whoever contravenes or makes default in complying with any provision of this Act or any condition subject to which exemption was granted under Section 17 shall, if no other penalty is elsewhere provided by or under this Act for such contravention or non-compliance, be punishable with imprisonment which may extend to three months or with a fine which may extend to one thousand rupees, or with both."

Please advise your company to comply with EPF/ESIC rules. If they are not willing, consider seeking alternate employment, as you will have to face PF authorities in your official capacity.

Regards,
[Username]
pritamraju
Thank you for your kind reply. Can you please advise me how much penalty has to be paid? I had already mentioned the same to them about the penalties earlier, but, as I said, it fell on deaf ears. They followed an ill-conceived thought that they could get away by citing a mere glitch in the formalities as "barriers" in their way. However, having said that, once EPF is registered, it must be deposited regardless of whether the employee numbers are more than or equal to 20, right?
pritamraju
Thank you very much for the reply. I will keep you posted on what happens next. The thing is that the employers are good and maintain a healthy rapport with the personnel, but they did make a blunder in the case of EPF and ESI. Ignorance can be a pain.
nathrao
Go to a consultant and work out the amount to be paid, including fines, etc. This will avoid any problems with the PF department. Today you have good relations with guards, but if some problem comes up, it will not take time for the PF/ESIC department to hear of non-deposit of PF contributions, etc., and legal troubles will start.
bijay_majumdar
Actually speaking, these kinds of ill practices are common with contracting agencies. In your case, I suggest being careful and not becoming part of such defaulting agencies. If you are the authority in such cases, you will be held responsible for all illegal matters happening, while others will simply enjoy the benefits. Furthermore, as a member suggested, please pay all dues as applicable at the earliest and avoid problems in the future. Also, educate clients about the seriousness of non-compliance issues.

Thanks
nathrao
The Symbiotic Relationship Between Contracting and Enforcement Agencies

Contracting agencies and enforcement agencies have a symbiotic relationship, where each feeds upon the other's shortcomings. There are well-intentioned Government of India (GOI) rules for labor welfare, but unknowingly or intentionally, business owners often try to avoid the expenditure on social welfare payments. As a result, they are forced to hide things from enforcement agencies or take the wrong approach in dealing with agency checks.

The best way to navigate this situation is to stay informed about the latest rules and comply with them to avoid any legal issues or penalties from enforcement agencies.

Regards
gannahope
It is better to send this information to the nearest EPF regional office and ESI manager and get it prosecuted under several violations of existing laws. Moreover, a cheating case has been done against workers. Please go ahead. This is a damn violation of labor laws.
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