(INDIA) — The Pension Fund Regulatory and Development Authority issued Circular No. PFRDA/2026/09/REG-PF/03 on February 23, 2026, allowing Central Recordkeeping Agencies to share structured subscriber information with Pension Funds under the NPS Vatsalya Scheme.
PFRDA positioned the move as a way to boost outreach, compliance, and growth of NPS Vatsalya by giving pension funds access to subscriber information in a structured form.
Central Recordkeeping Agencies, known as CRAs, sit at the centre of recordkeeping in the system and will now have a defined channel to share specified subscriber data for scheme-related uses under the circular.
The circular frames the data-sharing arrangement as a functional tool for pension funds to run structured outreach, assess performance, and pursue scheme growth initiatives under NPS Vatsalya.
PFRDA set out the types of subscriber information that can be shared, covering geographical distribution, gender diversity, contribution behaviour, and personalized communication data.
Geographical distribution data supports a view of where subscribers are located across regions, enabling pension funds to plan and sequence outreach and servicing activity in a structured manner.
Gender diversity data gives pension funds a way to evaluate and shape engagement across different subscriber segments as part of scheme promotion and distribution work under the framework.
Contribution behaviour data supports analysis of how subscribers contribute, which the circular links to performance assessment and growth initiatives tied to NPS Vatsalya.
Personalized communication data aims to support direct engagement with subscribers, with the circular tying that information to outreach, communication, and servicing under the scheme.
PFRDA embedded regulatory safeguards into the permission to share subscriber information, describing strict conditions that apply to how the data is used and controlled.
Purpose limitation anchors the framework, restricting data sharing and use to scheme management, outreach, communication, and servicing under NPS Vatsalya.
The circular also requires strict adherence to data usage, privacy, and security provisions, placing compliance expectations on the entities that handle and act on the information.
Pension funds and CRAs must comply with the Digital Personal Data Protection Act, 2023, the IT Act, 2000, and other applicable laws when they share, process, or use the structured subscriber information.
PFRDA set out governance hooks for oversight, including audit trails, inspections, and reporting requirements as prescribed by the regulator for data sharing under NPS Vatsalya.
Regulatory oversight in the circular links the data-sharing permission to ongoing supervisory mechanisms, creating a framework in which the sharing itself sits within a monitored environment.
Audit trails form part of that structure, supporting traceability around data access and use under the conditions tied to NPS Vatsalya.
Inspections and reporting requirements, as prescribed by PFRDA, add another layer to the governance approach embedded in the circular’s design.
Beyond operational controls, PFRDA described a set of regulatory objectives behind the framework, tying data access to how pension funds promote and distribute NPS Vatsalya.
The circular says the framework aims to enable pension funds to actively promote and distribute the scheme through evidence-based outreach and promotional strategies.
PFRDA also linked the structure to facilitating innovation and targeted engagement, indicating that pension funds can use structured information to shape how they approach subscribers.
Another stated objective is to strengthen the scale and sustainability of NPS Vatsalya, positioning growth as a regulatory goal alongside ongoing scheme operation.
Enrolment sits at the centre of the stated objectives, with the circular saying the framework aims to enhance enrolment in alignment with transparency, subscriber protection, and inclusive NPS growth.
The regulator also connected the framework to timely corrective measures, indicating that structured information can support action when performance or engagement requires adjustment.
Objective performance assessment appears as a final element of the circular’s stated aims, tying permitted data sharing to evaluation of outcomes under NPS Vatsalya.
Alongside data sharing, PFRDA used the circular to clarify provisions on asset allocation under NPS Vatsalya.
Pension funds opting for custom allocations under NPS Vatsalya must clearly disclose the allocation pattern to subscribers at onboarding, according to the circular.
Those pension funds must also publish the allocation pattern prominently on their websites in an easily accessible manner, the circular said.
PFRDA tied custom allocation choices to a broader compliance baseline, requiring that all allocation decisions follow the NPS Master Circular dated December 10, 2025.
The disclosure approach in the circular links asset allocation flexibility to upfront transparency for subscribers, pairing optional custom allocations with required communication at onboarding.
Website publication requirements add a continuing visibility element, ensuring allocation patterns remain available in a prominent and easily accessible form after onboarding.
By combining data-sharing permissions and allocation disclosure rules in one circular, PFRDA set out a framework that touches both how pension funds engage subscribers and how they communicate investment choices.
The compliance implications fall across multiple parties, because CRAs handle records and structured subscriber information while pension funds use the shared data to conduct outreach and scheme activity.
Governance requirements in the circular place emphasis on privacy, security, and auditability, connecting permitted sharing to controls that can be checked through oversight tools.
PFRDA’s oversight and prescribed reporting requirements also mean the framework is designed to operate within a system of ongoing supervision rather than a one-time permission.
At the same time, the framework keeps data use bounded by purpose limitation, confining use to scheme management, outreach, communication, and servicing rather than wider or unrelated activity.
The circular’s reference to the Digital Personal Data Protection Act, 2023 and the IT Act, 2000 embeds the data-sharing arrangement within existing legal obligations that apply to the handling of personal information and information technology systems.
The combination of legal compliance and regulatory oversight aims to set conditions for how shared subscriber information moves from CRAs to pension funds and how it is then used under NPS Vatsalya.
PFRDA’s stated objectives connect the mechanics of information sharing to outcomes, with evidence-based outreach and promotional strategies forming the explicit link between data access and distribution work.
Targeted engagement and innovation appear as another intended use-case, with the structured nature of the data framed as a resource for planning and executing subscriber-facing activity.
The circular’s emphasis on performance assessment aligns with its reference to objective performance assessment, using structured information as an input for evaluation under the scheme.
Corrective measures, also cited in the objectives, reflect the regulator’s intent that performance monitoring can lead to timely action within the system operating under NPS Vatsalya.
Subscriber protection and transparency run through both the data-sharing safeguards and the allocation disclosure requirements, with the framework tying access and flexibility to constraints and visibility.
Inclusive NPS growth appears in the objectives as well, linking enrolment efforts to a wider regulatory posture around how the scheme expands.
For pension funds, the circular creates a structured basis to receive and use information for scheme-related activity, while requiring that any handling and processing stays within the privacy and security conditions set out.
For CRAs, the circular sets a permissioned route to share structured subscriber information, with the same safeguards framing the sharing activity and its traceability through audit trails and oversight.
PFRDA’s circular places NPS Vatsalya at the centre of the framework, naming it explicitly as the scheme under which the data-sharing permission, safeguards, objectives, and asset allocation clarifications apply.
The new framework, as set out by PFRDA in Circular No. PFRDA/2026/09/REG-PF/03, ties growth goals to structured information sharing and disclosure rules, while keeping purpose limitation, legal compliance, and oversight as core conditions.
Pfrda Permits Subscriber Data Sharing Under NPS Vatsalya in Circular No. Pfrda/2026/09/reg-Pf/03
PFRDA Circular No. PFRDA/2026/09/REG-PF/03 permits sharing structured subscriber information to enhance the NPS Vatsalya Scheme. By providing pension funds with data on geography, gender, and contributions, the regulator seeks to improve outreach and enrolment. The framework is anchored in strict regulatory oversight, requiring compliance with national data protection laws, audit trails, and transparent asset allocation disclosures to ensure subscriber protection and inclusive growth.
