- The CBDT confirms that all existing PAN cards remain valid under the Income Tax Act 2025.
- New application forms such as Form 95 for non-citizens were introduced on April 1, 2026.
- Aadhaar is no longer accepted as a valid proof of birth for new PAN applications.
(INDIA) — The Central Board of Direct Taxes issued a formal clarification on June 29, 2026, confirming that all existing Permanent Account Numbers remain valid under the newly implemented Income Tax Act 2025. No taxpayer needs to reapply for a fresh PAN.
The Income Tax Act 2025 repealed and replaced the Income-tax Act of 1961 on April 1, 2026. The transition raised concerns among Non-Resident Indians in the United States, particularly H-1B visa holders and green card holders who maintain financial accounts in India. The CBDT clarification addresses those concerns directly.
The official press release states that existing 10-character alphanumeric PANs issued under the 1961 Act will continue to function as the unique tax identifier. Pending allotment requests as of March 31, 2026, will be processed under the new framework without requiring new applications.
PAN cards are issued by the Government of India, not by USCIS or DHS. Maintaining valid foreign tax identification is often required for international tax reporting and background vetting. Green card holders who report foreign accounts to the IRS must ensure their PAN records are accurate and current.
The new Act introduces category-specific application forms for anyone seeking a new PAN or requesting changes after April 1, 2026. Form 93 applies to Indian citizens. Form 95 is reserved for individuals who are not citizens of India, including U.S. citizens and expatriates with Indian-source income. Form 96 covers entities incorporated outside India.
Documentation requirements shifted on the same date. Aadhaar is no longer sufficient as proof of birth for new PAN applications. Applicants must provide a birth certificate, passport, or other government-issued identification document.
| Requirement | Before (1961 Act) | After (2025 Act) |
|---|---|---|
| Existing PAN validity | Valid | Remains valid, no reapplication |
| New application (Indian citizens) | Form 49A | Form 93 |
| New application (foreign citizens) | Form 49AA | Form 95 |
| New application (foreign entities) | Form 49AA | Form 96 |
| Proof of birth document | Aadhaar accepted | Birth certificate, passport, or govt ID |
| Effective date of changes | N/A | April 1, 2026 |
Effective Date: The Income Tax Act 2025 took effect on April 1, 2026. Existing PANs remain valid without reapplication.
In early 2026, a data-sharing agreement took effect allowing Immigration and Customs Enforcement to access certain IRS records for individuals who have overstayed visas or face deportation orders. The agreement makes the accuracy of foreign tax identifiers, including PAN, especially important for anyone reporting global assets.
FBAR filing under FinCEN Form 114 is required when the aggregate balance of foreign accounts exceeds $10,000 at any point during the year. FATCA reporting on Form 8938 applies at $50,000 for single filers in the U.S. The threshold rises to $75,000 if measured at any time during the year. Married couples filing jointly face $100,000 and $150,000 thresholds respectively. PAN serves as the account identifier for Indian bank accounts and investments listed on these forms.
On May 22, 2026, USCIS announced restrictions on Adjustment of Status processing. Agency spokesman Zach Kahler said the agency was “returning to the original intent of the law” to ensure proper use of the immigration system. The policy routes more adjustment cases through U.S. consular offices abroad rather than domestic USCIS offices.
Warning: Foreign citizens applying for a new PAN after April 1, 2026, must use Form 95 and provide a TIN from their country of residence. Aadhaar alone is no longer accepted as proof of birth.
The CBDT clarification prevents what could have been a major administrative burden for NRIs and H-1B holders in the United States. Had reapplication been required, millions of individuals would have faced delays repatriating funds or managing Indian investments. Existing PAN
