FAQ

A review under Section 7B(1) must be filed within 45 days of the order; an appeal to the CGIT under Section 7(2) of the Rules 1997, must be filed within 60 days of the order.

There is no general bar on recovery pending appeal. Courts have held that the EPFO is not required to wait for the appeal period to expire before initiating recovery, though a stay may be sought from the appellate forum.

An appeal under Section 45AA must be filed within 60 days of the order. An application before the Employees’ Insurance Court must generally be filed within three years of the cause of action.

Once a recovery certificate is issued, the correctness of the underlying amount generally cannot be challenged before the Recovery Officer, whose role is limited to execution. The demand itself must be contested before the Assessing/Authorised Officer or in appeal.

An Enforcement Officer or Social Security Officer may examine wage records, ECR/contribution filings and related registers, and may record statements. Findings from an inspection frequently form the basis for a subsequent 7A inquiry or 45A determination of contributions.

The Code, along with the Central Rules and schemes notified under it, is now in force and governs dues and defaults arising on or after 21 November 2025. Matters arising before that date continue to be governed by the legacy EPF Act, 1952 and ESI Act, 1948. Because rules continue to be notified and refined, we assess the applicable framework separately for each matter.