**Executive Summary**
This circular, issued by the Pension Fund Regulatory and Development Authority (PFRDA) on January 12, 2026, outlines the framework for sharing subscriber information between Central Record Keeping Agencies (CRAs) and Pension Funds (PFs) under the Multiple Scheme Framework (MSF). It specifies data usage, privacy, and security provisions for this information sharing. CRAs and PFs are required to align their systems and processes accordingly and confirm compliance within prescribed timelines.
**Key Points / Main Content**
* **Purpose of MSF:**
* Enables PFs to design, own, and distribute their respective schemes under their brand identity.
* Facilitates the growth of NPS within the Non-Government Sector.
* **Information Sharing:**
* CRAs shall share subscriber information with PFs as per their requirement, using a prescribed common template and periodicity mutually agreed upon.
* PFs will only receive subscriber information for subscribers enrolled under schemes implemented by that particular PF under MSF.
* No subscriber information shall be shared on subscribers enrolled only under common schemes.
* All fields are to be made available to the PFs in respect of subscribers that have joined under its MSF irrespective of whether such subscriber has a common account or not.
* **Data Usage and Security:**
* Subscriber data must be used solely for scheme design, distribution, outreach, value-building, and servicing under MSF.
* Data handling must strictly comply with the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and other applicable data privacy laws.
* PFs and CRAs must implement technical and organizational safeguards to maintain data confidentiality, integrity, and security.
* Unauthorized use, disclosure, or processing of subscriber data is strictly prohibited.
* **Regulatory Compliance:**
* Data sharing framework is implemented under the enabling provisions with adequate safeguards of the following regulations of the respective intermediary:
* PFRDA (Central Record keeping Agency) Regulations, 2015
* PFRDA (Pension Fund) Regulations, 2015
* **Compliance and Oversight:**
* Both CRAs and PFs shall maintain audit trails of all subscriber data shared.
* They are subject to inspection or audit by the Authority or NPS Trust.
* CRAs and PFs must align their systems, processes, and data management protocols.
**Impact Analysis**
**CRAs**
* **Impact:** Responsible for sharing subscriber information with PFs as per the prescribed template and agreed-upon periodicity. Must ensure compliance with data privacy and security provisions.
* **Action Required:** Implement necessary systems and procedures for sharing subscriber information with PFs and align with regulatory requirements.
**Pension Funds (PFs)**
* **Impact:** Will receive subscriber information for targeted communication, relationship management, and subscriber servicing under MSF. Must ensure compliance with data privacy and security provisions.
* **Action Required:** Align systems and processes to receive and manage subscriber information, and ensure adherence to data privacy regulations.
**Subscribers**
* **Impact:** May receive more targeted and personalized communication from Pension Funds, but their data privacy must be protected.
* **Action Required:** No direct action required, but subscribers should be aware of their data privacy rights.
Key Entities Referenced
Pension Fund Regulatory and Development Authority (PFRDA): The regulator responsible for promoting and regulating pension schemes in India, including the National Pension System (NPS). The document is a circular from PFRDA.
Multiple Scheme Framework (MSF): A framework within the National Pension System (NPS) that allows Pension Funds to design and manage multiple schemes for Non-Government Sector Subscribers.
Central Recordkeeping Agencies (CRAs): Entities authorized by PFRDA to maintain records of subscribers under NPS.
Pension Funds (PFs): Entities managing the investments of pension contributions under NPS.
PFRDA Act, 2013: The primary legislation governing the Pension Fund Regulatory and Development Authority and the regulation of pension schemes in India.
CIRCULAR
PFRDA/2026/04/REG-PF/02 Date: 12th Jan 2026
To
CRAs and
Pension Funds
All Stake Holders
Subject: Sharing of Subscriber Information under Multiple Scheme Framework (MSF)
with Pension Funds
Vide Circular No. PFRDA/2025/09/Reg-PF/01 dated 16th September 2025 on the
Introduction of Multiple Scheme Framework (MSF) for Non-Government Sector Subscribers
under NPS β issued under Section 20(2) of the PFRDA Act, 2013, the Pension Funds (PFs)
were permitted to design, operate, and manage multiple schemes under the National Pension
System (NPS).
2. The fundamental premise of the MSF framework is to enable PFs to design, own, and
distribute their respective schemes under their brand identity, thereby facilitating the growth of
NPS within the Non-Government Sector through improved outreach, innovation, and
subscriber engagement.
3. As per the provisions of the said circular, PFs shall be provided with demographic
information of subscribers who have invested in their schemes for the purposes of targeted
communication, relationship management, and subscriber servicing.
4. In continuation thereof, it has now been decided by the Authority that the requisite
subscriber information (as per the attached template) shall be shared by the Central Record
keeping Agencies (CRAs) with the concerned PFs as per their requirement, using a prescribed
common template and at such periodicity as may be mutually agreed between the CRAs and
PFs. Under this Data sharing Framework, PF would only get subscriber information on the
subscriber enrolled under scheme implemented by a particular PF under MSF. CRA shall not
provide the subscriber information if the subscriber is not enrolled under the scheme
implemented by PF under MSF. Similarly, no subscriber information on subscriber enrolled
only under common schemes shall be shared. All fields are to be made available to the PFs
in respect of subscribers that have joined under its MSF irrespective of whether such
subscriber has a common account or not.5. Data Usage, Privacy and Security Provisions
While sharing and handling subscriber information, the following principles shall be strictly
adhered to by the CRAs and PFs:
a. All subscriber data shared under this structure shall be used solely for the intended
purposes of scheme design, distribution, subscriber outreach, value-building, and
servicing under the MSF framework.
b. The data shall be handled strictly in compliance with the Digital Personal Data
Protection Act, 2023 (DPDP Act), the Information Technology Act, 2000, and other
applicable Indian laws, rules, and regulations governing data privacy and protection.
c. PFs and CRAs shall ensure that the appropriate technical and organizational
safeguards are implemented to maintain the confidentiality, integrity, and security of
subscriber information.
d. Any unauthorized use, disclosure, or processing of subscriber data beyond the
stated purpose is strictly prohibited which shall attract appropriate regulatory and legal
action.
6. Regulatory Guard rails
This data sharing framework is implemented under the enabling provisions with adequate
safeguards of the following regulations of the respective intermediary:
A. PFRDA (Central Record keeping Agency) Regulations, 2015
Regulation 19 β Service to stakeholders or intermediaries:
βCRA shall establish necessary systems and procedures to facilitate record keeping,
administration, and customer service functions, including statements, MIS, and reports
across various stakeholders or intermediaries of the NPS architecture β viz. subscribers,
Trustee Bank, nodal offices, and Pension Funds β in accordance with the provisions of the
Act, rules, regulations, or directions issued by the Authority.β
Regulation 43 β Confidentiality:
βCRA shall maintain absolute confidentiality with respect to all records, data, and information
received or acquired during the course of its working, and shall not, without the prior
permission of the Authority, produce or share such data or information as evidence or for
any other purpose, except as required by due process of law.β
B. PFRDA (Pension Fund) Regulations, 2015
Regulation 9A(1)(g) β Terms and Conditions of Registration:
βThe PF shall maintain confidentiality with respect to all transactions, records, data, and
information received while discharging its obligations and shall not, without the priorpermission of the Authority, produce or share such data or information as evidence or for
any other purpose except as required under the process of law or as directed by the
Authority or the NPS Trust.β
Schedule XI (42) β Privacy:
βThe PF shall comply with all applicable privacy or data protection laws in force from time
to time, including any privacy code or guidelines issued by the Government of India, and
shall cooperate in the resolution of any complaint under or relating to such laws or
guidelines.β
7. Compliance and Oversight
Both CRAs and PFs shall maintain audit trails of all subscriber data shared under this
arrangement and shall be subject to inspection or audit by the Authority or NPS Trust to ensure
compliance with the above provisions.
All CRAs and PFs are advised to align their systems, processes, and data management
protocols accordingly and confirm compliance to the Authority within the prescribed timelines.
Chief General ManagerInformation Sharing Template
S. No. Field from the Form Purpose for Personal Connect & Targeted Communication
Enables personalised communication and respectful addressing
1 Applicant Name / Address
of the subscriber
Supports age-based engagement (life stage, retirement horizon,
2 Date of Birth
milestone messaging)
Helps in inclusive, sensitive and appropriately framed
3 Gender
communication
Marital Status/ Nominee Useful for life-event based communication (marriage, family
4
(for succession planning) planning, nominations)
Enables family-oriented messaging and nomination-related
5 Spouse Name (if married)
engagement
Occupation Details/ Allows tailoring of communication based on employment type
6
Employer information and career stage
Helps align communication with affordability, contribution
7 Annual Income Range
planning and tax messaging
8 Nationality Relevant for communication and cross-border tax awareness
9 Place / Country of Birth Supports contextual communication
10 Mobile Number Primary channel for timely, personalised alerts and engagement
Enables detailed, educational and value-oriented digital
11 Email ID
communication
Allows region-specific communication, language preferences
12 Current City / State
and local outreach
Tier-II Account Activation Helps identify subscribers for cross-sell, upsell and deeper
13
(Yes/No) relationship building
14 Other relevant information For Product building, Value Based relationship
15 Associated POP Information on POP/POP SP/e NPS