Does Casual or Contract Labor Count Toward the 20-Employee Threshold for EPF Act Compliance?

Our construction company has fewer than 10 permanent/temporary employees at any given point in time. We completed a RERA-registered residential colony in 2018 using casual labor and manpower supplied by labor contractors. However, we have recently received an EPF notice seeking to inquire into our business. Will the casual labor/contract labor be counted towards the threshold of 20 employees for the applicability of the EPF Act, 1952?

If your company has fewer than 20 employees (permanent/casual), then you don't need to worry. However, if including contract labor pushes the count beyond 20, then you need to enroll in PF and provide PF to all your employees.

If your contractor is complying with the PF Scheme for his employees, then you need not bother; otherwise, you are required to comply, and there is no escape from this legal obligation.