Key Details
PFRDA’s Exposure Draft on amendments to the Point of Presence Regulations, 2018, dated 2 September 2026, proposes changes to the intermediaries through which people join and receive services under the National Pension System and other PFRDA-regulated schemes.
Proposed change | What the draft provides |
|---|---|
Two distribution modes | Separate physical and exclusively digital modes. Any combination of physical and digital operations would be classified as physical. |
Wider digital eligibility | Financial-sector-regulated entities, eligible companies, cooperative societies, LLPs, registered societies or associations, and trusts could seek digital-mode registration, subject to applicable conditions. |
Physical presence requirement | A physical-mode Point of Presence would require at least five branches or offices in India, compared with the existing requirement of one. |
Application fees | The physical-mode application fee would rise from ₹10,000 to ₹25,000; no application fee would apply to digital-mode applicants. |
Processing timeline | PFRDA would acknowledge applications within seven days, communicate deficiencies within 14 days and dispose of complete applications within 30 days. |
Annual regulatory fee | The five-year renewal process would be replaced by an annual fee of 1% of charges earned, subject to a minimum of ₹3,000. |
Digital fund collection | A digital-mode PoP would maintain a separate digital collection account for each pension scheme. |
Agent nomenclature | “Pension Agent” would be renamed “NPS Mitra” without substantially expanding the functions assigned to the agent. |
Material-change reporting | A PoP would have to notify PFRDA within seven days of any material change that could adversely affect its registration. |
Consultation deadline | Stakeholders may submit comments until 2 October 2026. |
A Separate Digital Route Could Bring New Distributors into the NPS Network
A Point of Presence (PoP) is an intermediary authorised to enrol subscribers, collect contributions and process service requests under the National Pension System or another PFRDA-regulated scheme.
The current regulations recognise physical, online and combined modes. The draft instead creates two categories: physical and digital. Digital registration would apply only where onboarding, contributions and service requests are handled electronically through platforms authorised by PFRDA. An intermediary using even a combination of digital and physical channels would be treated as a physical-mode PoP.
This distinction allows PFRDA to prescribe different entry conditions for the two models. Physical operators would need at least five branches or offices, while digital operators would be assessed principally on their ability to connect with authorised platforms and process subscriber information, contributions and payouts electronically.
Eligibility Would Expand Beyond Companies, Banks and NBFCs
The draft would open the digital distribution route to a broader range of legal forms. Subject to the prescribed financial, technological and governance conditions, applicants could include cooperative societies, limited liability partnerships, registered societies or associations, and trusts, in addition to regulated financial entities and eligible companies.
For non-financial-sector-regulated companies, cooperatives, LLPs, societies and trusts, the draft generally prescribes minimum net worth of ₹2 crore, including capital, share capital or corpus of at least ₹50 lakh, depending on the legal form.
The proposed widening could help organisations with an established community or occupational presence distribute pension products in underserved areas. Yet organisational reach alone would not establish suitability: digital connectivity, financial capacity, governance and compliance with the fit-and-proper requirements would remain relevant.
Entry Becomes Cheaper for Digital Operators but Costlier for Physical Applicants
The draft creates a clear fee preference for exclusive digital distribution. It would waive the application fee for digital applicants, while increasing the physical-mode application fee from ₹10,000 to ₹25,000.
A larger change concerns continuing registration. The existing five-year renewal fee—0.5% of charges earned, with a ₹15,000 minimum and ₹1 lakh maximum—would be replaced by an annual payment of 1% of charges earned, subject to a minimum of ₹3,000. The draft does not reproduce the existing maximum fee.
The effect would differ across PoPs. The lower minimum could benefit smaller intermediaries, while the annual calculation and absence of an express cap could increase the regulatory cost for entities earning larger charges.
Digital Expansion Comes With Ring-Fenced Collection and Reporting Requirements
Every digital-mode PoP would have to maintain a separate digital collection account for each pension scheme. This would distinguish digitally received contributions and provide a defined route for transferring subscriber funds to the National Pension System Trust.
PoPs would also have to report within seven days any material change in previously supplied information that could adversely affect their registration. Existing entities that do not meet the proposed branch or net-worth requirements could seek an exemption, with PFRDA required to record its reasons and permitted to attach conditions.
These provisions seek to combine easier digital entry with traceability of funds and continuing regulatory visibility.
“Pension Agents” Would Become “NPS Mitras,” but PoPs Retain Responsibility
The proposed NPS Mitra is the renamed version of the existing pension agent. Such agents could distribute pension schemes, collect specified documents and facilitate subscriber services under an agreement with one or more PoPs.
The PoP would remain responsible for the Mitra’s conduct, including know-your-customer and anti-money-laundering compliance, training, supervision, record maintenance and subscriber losses caused by established fraud or negligence.
One governance change merits attention: the current requirement for a Board-approved policy on engaging pension agents would become a requirement for an “internal approved policy” for NPS Mitras. The draft does not specify in this provision which internal authority must provide that approval.
What Is a Point of Presence?
A Point of Presence is a PFRDA-registered intermediary that acts as an access and service point for pension subscribers. Depending on its authorisation, it may enrol subscribers, receive contributions, process account changes and facilitate other NPS or pension-scheme services.
Banks, financial institutions and other eligible organisations can operate as PoPs. They may also engage agents—proposed to be called NPS Mitras—for limited distribution functions, while retaining regulatory responsibility for their conduct.
Policy Relevance
For pension access: A digital-only route could extend distribution without requiring every intermediary to build a branch network. Its contribution to pension inclusion will depend on whether new entrants reach workers who are currently outside formal retirement-saving systems rather than competing only for existing urban customers.
For subscribers: A larger distributor network creates more points of access, but also increases the importance of clear disclosures, grievance resolution and accountability when services are delivered through NPS Mitras or digital platforms.
For intermediaries: Physical and digital applicants would face materially different entry requirements and costs. Stakeholder feedback will be important on whether the proposed classification appropriately treats an entity offering both online convenience and limited physical assistance as a physical-mode operator.
For PFRDA: Wider eligibility will require supervision across organisations with different governance structures. The regulator will need to ensure that easier entry does not produce uneven standards in cybersecurity, fund handling, KYC compliance or subscriber servicing.
Follow the Full Consultation Here: Exposure Draft: Amendments to the PFRDA Point of Presence Regulations, 2018
The draft remains open for comments until 2 October 2026. Exposure Draft dated 02 Sep 2026 - Proposed changes to the PFRDA PoP Regulations.pdf

