PMGKY - whether ECR can be filed without payment of Salary

Our Company's administrative office is situated in Kolkata (West Bengal) which has been declared as "RED ZONE"  in view of spread of COVID-19. Our Office  has been  closed ( Under Lock & Key) since 22nd March, 2020. Hence, we could not disburse Salary for March & April  2020 till date. Salary could only be disbursed once Lock Down is relaxed. In view of this reason, we are not in a position to file ECR for wage months March and April 2020.

But, the EPFO / RO of Provident Fund Office has been advising us to file ECR. We have been receiving a number of SMS and mails from RPFO. for filing ECR  by 15/05/2020 in order to avail PMGKY benefits.

Now, my question is:  Whether we can file ECR without actual payment of Salary for those 2 months?

Replies (2)
Quick Summary
This discussion addresses whether companies can file their Employees' Provident Fund (EPF) Electronic Return (ECR) without having disbursed salaries for March and April 2020, particularly in light of the PMGKY scheme. Due to COVID-19 lockdowns, some businesses have been unable to pay salaries and are receiving pressure from EPFO to file ECR. The consensus suggests that ECR can be filed without simultaneous salary payment, with contributions potentially being paid at a later date.

I think it can be done. You can just file the returns and in future pay the Salary and Govt Dues as notified. Employers can file the ECR without the need of simultaneous payment of contributions, which may be paid later by the employer after filing the ECR.

Dear Mr. Sharma,

Thanks a lot for your valued opinion.

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