**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 under the Multiple Scheme Framework (MSF) with Pension Funds (PFs). It details the data sharing protocols, data usage guidelines, and privacy provisions that Central Recordkeeping Agencies (CRAs) and PFs must adhere to. CRAs and PFs must align their systems and confirm compliance with the authority within prescribed timelines.
**Key Points / Main Content**
* **Purpose of MSF:**
* Enables Pension Funds (PFs) to design, own, and distribute schemes under their brand identity.
* Facilitates NPS growth in the Non-Government Sector through improved outreach and innovation.
* **Subscriber Information Sharing:**
* CRAs will share subscriber information with concerned PFs as per their requirements, using a prescribed common template.
* Periodicity to be mutually agreed upon between CRAs and PFs.
* Only subscriber information on subscribers enrolled under schemes implemented by a particular PF under MSF will be shared.
* No subscriber information on subscribers enrolled only under common schemes will be shared.
* All fields are to be made available to PFs for subscribers who have joined under its MSF, irrespective of whether the subscriber has a common account or not.
* **Data Usage and Privacy:**
* Data must be used solely for scheme design, distribution, subscriber outreach, value-building, and servicing under MSF.
* Compliance with the Digital Personal Data Protection Act, 2023, and other applicable laws is mandatory.
* Appropriate technical and organizational safeguards are required to maintain data confidentiality, integrity, and security.
* Unauthorized data use, disclosure, or processing is strictly prohibited and will attract regulatory/legal action.
* **Regulatory Guardrails:**
* Framework implemented under provisions of PFRDA (Central Record keeping Agency) Regulations, 2015 and PFRDA (Pension Fund) Regulations, 2015
* CRAs must establish systems for record-keeping, administration, and customer service.
* CRAs and PFs must maintain absolute confidentiality of records, data, and information.
* CRAs and PFs will comply with applicable privacy/data protection laws and cooperate on complaints.
* **Compliance and Oversight:**
* Both CRAs and PFs must maintain audit trails of shared subscriber data.
* The Authority or NPS Trust will inspect/audit compliance.
**Impact Analysis**
**Central Recordkeeping Agencies (CRAs)**
* **Impact:** Increased responsibility for sharing subscriber information in accordance with specified standards and ensuring data privacy and security.
* **Action Required:** Implement necessary systems to share subscriber data, adhere to data usage and privacy guidelines, maintain audit trails, and align systems with requirements, and confirm compliance.
**Pension Funds (PFs)**
* **Impact:** Access to subscriber information for targeted communication, relationship management, and subscriber servicing under the MSF, with added responsibility for data protection.
* **Action Required:** Establish processes for using shared subscriber data, adhere to data usage and privacy guidelines, maintain audit trails, align systems with requirements, and confirm compliance.
**Subscribers (Stake Holders)**
* **Impact:** Increased personalized communication and tailored services from PFs, but subject to enhanced data privacy and security measures.
* **Action Required:** No direct action required, but subscribers should be aware of how their data is being used and protected.
Key Entities Referenced
Pension Fund Regulatory and Development Authority (PFRDA): The regulatory body responsible for promoting and regulating pension schemes in India, and the primary issuer of this circular.
PFRDA Act, 2013: The governing legislation that empowers the PFRDA to regulate the pension sector, including the National Pension System (NPS).
National Pension System (NPS): The main pension scheme being regulated, specifically addressed in the context of data sharing among CRAs and Pension Funds.
Multiple Scheme Framework (MSF): A framework allowing Pension Funds to design and manage multiple schemes under the NPS, which is the context for sharing subscriber information.
Central Recordkeeping Agencies (CRAs): Entities responsible for maintaining subscriber records within the NPS, obligated to share data with Pension Funds under specific conditions.
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 – 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 – Service to stakeholders or intermediaries:
“CRA 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 — viz. subscribers,
Trustee Bank, nodal offices, and Pension Funds — in accordance with the provisions of the
Act, rules, regulations, or directions issued by the Authority.”
Regulation 43 – Confidentiality:
“CRA 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.”
B. PFRDA (Pension Fund) Regulations, 2015
Regulation 9A(1)(g) – Terms and Conditions of Registration:
“The 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.”
Schedule XI (42) – Privacy:
“The 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.”
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