PMGKY - whether ECR can be filed without payment of Salary

Rajib Saha (Accounts Officer) (239 Points)

11 May 2020  

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?