Can We Register For ESI And PF Without Employees?

Hi, we have opened a security agency. Now, I’m done with all the registrations apart from ESI and PF. As per the 2005 security act, every security company has to have a INTERNAL SECURITY DIVISION certification and in order to do so a security company should have ESI and PF registration otherwise the certification cannot be done. Hence, I spoke to one of the auditors and he told me that, ESI PF can be registered only when we have employees. Is he correct? I didn't think so because If we go for a business without the INTERNAL SECURITY DIVISION certification, it will be a crime. Please help. Thank you!

Sir, under ESI & EPF coverage depend upon occurrence of engagement of minimum number of persons ( as laid down in said Acts) for and in connection with the work of unit. What is expected to occur in future or what is being planned by employer is irrelevant and of no importance.