INTRODUCTION

The Employees’ Provident Fund Organisation (hereinafter referred to as “EPFO”), responsible for safeguarding the retirement savings of over 27 crore members across India, has launched a transformative digital initiative to modernize its account setup and verification process. Beginning August 1, 2025, EPFO mandates that every new Universal Account Number (hereinafter referred to as “UAN”) must be generated and activated exclusively through the UMANG mobile app using Aadhaar-based Face Authentication Technology, a secure biometric method designed to verify member identity remotely and digitally.

This significant move aims to empower employees with complete self-service capability. Individuals now independently initiate UAN generation and activation without employer intervention by simply downloading the UMANG app and the Aadhaar Face RD utility, entering Aadhaar-linked details, and completing live biometric authentication. Instant allotment and activation thereby reduce delays, eliminate paperwork, and curb common account errors previously arising from manual data entry, incomplete forms, or mismatched records.

By linking UAN creation directly to Aadhaar verification and biometric authentication, EPFO not only streamlines access to social security and provident fund management, but also enhances transparency and data integrity in India’s retirement ecosystem. This digital overhaul marks a new era of paperless, error-free, and biometric-backed social security, fully aligned with government goals of digital empowerment and citizen-centric service delivery.

WHY DID EPFO MAKE THE CHANGE?

EPFO’s shift to Aadhaar-based Face Authentication Technology via the UMANG app is a direct response to longstanding challenges and the need for modernization in the UAN generation process. Historically, UAN generation depended on employer-led submission and verification, often resulting in issues like clerical mistakes, documentation bottlenecks, and frequent creation of duplicate or erroneous accounts. These delays and data inconsistencies hampered real-time access and complicated account management for millions of workers.

Recognizing the power of biometric authentication and the widespread adoption of smartphones, EPFO piloted the digital Face Authentication Technology system from April 2025, ultimately mandating its national rollout in August. This change enables direct, tamper-proof self-service enrollment, providing instant provisioning of UANs, reducing paperwork, and offering a secure way to verify identities remotely, catering to both domestic staff and mobile or cross-border workers who need easy, efficient onboarding regardless of their physical location.

Importantly, inclusiveness has been maintained in this transition: international workers and citizens of Nepal or Bhutan, who are typically unable to complete Aadhaar-based authentication are still permitted to generate UANs using the traditional employer-driven process, ensuring no loss of coverage as India’s social security system evolves for the digital age.

THE NEW UAN GENERATION PROCESS: STEP-BY-STEP
  1. Preparation
  • Smartphone with Internet Access: Employee should have a working smartphone, internet connectivity, and an Aadhaar-linked mobile number.
  • Install Essential Apps: Download the UMANG app (for EPFO services) and Aadhaar Face RD app (for biometric scan).

 

2. UAN Generation & Activation

  • Initiate Process in UMANG: Onboard via EPFO – UAN Allotment & Activation.
  • Enter Aadhaar & Mobile Details: Fill the 12-digit Aadhaar and linked mobile number, and consent for Aadhaar verification.
  • OTP Verification: Input OTP sent to registered mobile to validate the details.
  • Live Face Scan: Launch Aadhaar Face RD for real-time facial authentication against UIDAI’s secure database.
  • Instant UAN Generation: If biometric match succeeds, UAN is allotted and activated instantly. UAN details are sent via SMS and e-UAN Card is available for download.
  • Employer Linkage: Employees share their UAN with the employer to enable PF contributions and access further EPFO services.

 

3. Exceptions and Special Cases

  • Employer-Driven Enrollment: Still permitted as a fallback for international workers, Nepalese and Bhutanese citizens due to Aadhaar access gaps.
  • Support Channels: EPFO has released detailed manuals and FAQ support through UMANG to resolve issues like authentication failure, device compatibility, or unlinked Aadhaar.
CORE ADVANTAGES OF THE NEW DIGITAL SYSTEM
  1. Speed & Simplicity: UAN is activated in minutes, cutting out paperwork, long wait times, and third-party dependencies.
  2. Biometric Security: Face authentication ensures every UAN maps to a unique, live individual drastically reducing fraud, duplication, and identity mismatch.
  3. Universal Access: Employees can check balances, update KYC, download e-UAN, and file claims directly after activation using UMANG’s mobile platform.
  4. Employer Efficiency: No manual document collection; onboarding focuses on digital readiness, leaving PF compliance and record linkage in the employee’s control.
  5. Inclusive Governance: Exception handling, user guides, and multilingual support ensure stakeholders are not disadvantaged by the transition.
  6. Paperless, Error-Free Recordkeeping: All workflows are digital with instant validation and system-generated documents, supporting long-term data hygiene.
IMPLEMENTATION CHALLENGES AND STAKEHOLDER PREPARATION
  1. Technology Readiness: Not all new hires may possess Aadhaar-linked mobiles or digital fluency. Employers must help recruits download, register, and navigate the new workflow.
  2. Privacy and Data Security: All biometric scans are validated against UIDAI servers, and EPFO’s workflow complies with India’s Digital Personal Data Protection Act, ensuring encrypted, privacy-safe transactions.
  3. Exception Support: Employees facing authentication issues (e.g., photo mismatch, uploads) are advised to update their Aadhaar photo through UIDAI before retrying.
  4. Digital and Language Barriers: Many employees are unfamiliar with the UMANG app or digital KYC procedures and require hands-on guidance. EPFO and staffing federations recommend providing multilingual training materials, visual guides, and on-site demonstrations to empower new hires.
  5. Bulk Onboarding and Payroll Disruptions: For large employers, the inability to generate UANs in batches without immediate Face Authentication Technology delays provident fund compliance, timely registration, and salary disbursal for hundreds or thousands of workers at once.
  6. Risk of Employment Impact: Failure to promptly generate a UAN now carries the risk of delayed or denied employment offers for candidates unable to complete the digital onboarding, particularly affecting first-time jobseekers or those without digital exposure.
BEST PRACTICE RECOMMENDATIONS
  1. Employers are encouraged to initiate Aadhaar rectifications and digital familiarization for new recruits immediately after selection.
  2. Organize Face Authentication Technology awareness camps and technical assistance drives during onboarding seasons.
  3. Document issues for escalation to EPFO or UIDAI helpdesks, which are now expanding their resources to address Face Authentication Technology -related queries.
  4. Seek temporary exemptions or phased deadlines for high-turnover or resource-challenged industries, as suggested by industry groups.
AMLEGALS REMARKS

The Aadhaar-based face authentication initiative for UAN activation represents a groundbreaking leap in digital onboarding within India’s social security framework, setting a new standard for secure and efficient account creation. By mandating biometric verification through the UMANG app, EPFO empowers members with real-time, tamper-proof access and control over their retirement savings accounts from the moment of enrollment. This transformative approach eliminates dependency on employers for UAN generation, greatly reduces errors and delays, and unlocks instant access to services like passbook viewing, KYC updates, and claim submissions enhancing transparency and convenience.

For employers and employees alike, adopting a mobile-first mindset and embracing digital literacy are essential to fully harness these benefits and keep pace with India’s shift towards paperless, biometric-backed governance. Stakeholders must actively support new recruits in navigating the UMANG and Aadhaar Face RD apps, fostering a digitally inclusive ecosystem that bridges connectivity and knowledge gaps. This shift not only modernizes provident fund management but also strengthens data security by aligning with India’s Digital Personal Data Protection Act, ensuring privacy-safe, encrypted authentication processes.

Ultimately, EPFO’s biometric-first UAN model ushers in a user-centric, resilient social security system designed for scalability and future-ready service delivery engaging members more directly in safeguarding their financial futures through secure, seamless technology.

 

For any queries or feedback, feel free to connect with mridusha.guha@amlegals.com

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