Is It Possible To Register For ESI And PF Without Having Any Employees?

Hi, we have opened an establishment. Now, I’m done with all the registrations apart from ESI and PF. Currently, we do not have any employees and One of the auditors told me that, without 19 employees the ESI and PF registration cannot be done, another one told me opposite to it. I'm confused! Can any known person would like to let me know whether is it possible to have just the registration done in ESI and PF office without empoyees. (once the employees are hired, we’ll start paying the ESI and PF amount) I need to have these registrations since my future clients need it when I go for the business. (We are the security guard service provider and when I approached clients they had asked me for ESI and PF registrations numbers and since I didn't have that, I was rejected.) Please help. Thank you!

Once you have registered for PF/ESI even if you do not have employees you will have to file for appropriate returns. So it is a call that you have to take after discussing with an experienced PF/ESI practitioner

As a matter fact you can register, but it is of no use. You need to pay the minimum charges of Administrative charges every month, which is an unwanted expenditure.
You can inform or give a declaration to your client that after appointing the guards, the PF and ESI registration will be done and the requisite data will be submitted.

Sir, coverage of a factory/establishment under ESI Act, 1948 is based on actual engagement of minimum persons as required under said Act and in addition it is also essential that the area where the unit is situated must be implemented area under section 1(3) of said Act. Under said Act Code Number cannot be obtained in anticipation of engagement/employment of minimum number of persons as required in future.

Dear PRASHANTH007007,
Since you do not have any employee as stated by you, you can not go for PF as well as ESI registration.
What one of the auditors told you is correct. Unless you have 20 head counts, you can not register with EPF. But you can go for registration voluntarily when you have less than 20 head counts with consent by you and majority of employees. Subject to certain criteria the registration on voluntarily is granted by CPFO.
Registration under ESI, if you are applying in Maharashtra or HP or in Assam, you should have minimum 20 coverable employees under the ESIS. In rest of India, if you have 10 head counts, you need to register your establishment under ESI. Here there is no provision for registration voluntarily.
You need to convince your prospective client that once you start with him with 20 or more employees, you will submit the PF and ESI registration number within couple of days. Now you get those numbers immediately on application submitted online.

Whether it is mandatory for charitable and religious trust to register under the Shop and Establishment Act before registering under ESI and EPF Act ?

1. Sir, ESIC has its own system of identifying factories and other notified establishments viz. shops etc. for coverage and it does not depend on coverage under any other Act. Though, coverage under Shop & Commercial Estt. Act is not a pre-condition, it can serve only an evidence for coverage under ESI Act, 1948 and rules/regulations framed thereunder. If an establishments fails/faults its coverage under any other statutory requirements, it does not mean that it should not be covered under ESI Act.
2. In case of any doubt, and for more clarity in respect of coverage of your establishment, if desired, you can contact appropriate ESIC authorities of your area.
3. I think, similar position may be in respect of coverage under EPF & MPs Act, 1952.