Is My Friend's Company Liable for PF Deductions Without Registration Since 2018? What Are the Penalties?

Hello, in my friend's company, there are 20+ people working, and the company was established in December 2018. They are deducting PF amounts from employees; however, they are not registered yet. Now, he has a question: does he have to pay the full amount from December 2018 till date? If so, what would be the deadline (in months) and what would be the penalties?

PF Contribution Payment Timeline

If you started deducting PF contributions from employees in December 2018, the amount needs to be paid to the PF authorities by the 15th of January 2019. Similarly, if you start deducting PF from employees for a particular month, the same needs to be deposited into the PF account (now electronically by preparing ECR) by the 15th of the following month. Any late payment shall attract interest from the 16th onwards and damages. This is the procedure by EPFO.

Question About Unregistered Companies

However, my question is: if the company is not yet registered under the Employees' Provident Fund & Miscellaneous Provisions Act, 1952, why are they deducting PF contributions from employees?