Transition from Form 15G/15H to Form 121 under New Income-tax Act, 2025

This is to inform you that the Employees’ Provident Fund Organisation (EPFO), vide its communication dated 13 April 2026, has issued important instructions regarding the transition from Form 15G/15H to the newly introduced Form 121 pursuant to the implementation of the Income Tax Act, 2025, effective 1 April 2026.

Under the revised tax framework, Form 121 has been introduced as a consolidated self-declaration form for claiming non-deduction of TDS on eligible incomes, replacing the earlier Forms 15G and 15H.

As per the notification and implementation guidance, the following key aspects require attention:

The declaration under Form 121 can be submitted only by resident taxpayers whose estimated total tax liability for the financial year is nil. While the submission of the form is optional, it becomes essential where the taxpayer intends to avoid TDS deduction on eligible payments such as EPF withdrawals.

From a compliance perspective, the responsibility of the payer (including EPFO and employers, where applicable) has been significantly enhanced. A Unique Identification Number (UIN) is required to be generated for every Form 121 received. This UIN must be duly reported in the monthly statements as well as in the quarterly TDS returns, ensuring proper traceability and audit trail under the new system.

It has also been clarified that until the online filing utility is operational, physically signed Form 121 may be accepted and maintained for compliance purposes. However, once the system is enabled, digital submission and reporting will become mandatory.

Further, it is important to note that non-compliance, including failure to generate a UIN or incorrect reporting, may attract penal consequences under the Income Tax Act, 2025. Accordingly, all offices and stakeholders must ensure strict adherence to the revised procedure.

In cases where Forms 15G/15H have already been submitted on or after 1 April 2026, it is advisable to additionally obtain Form 121 to align with the current legal framework and avoid any compliance gaps.

Practical Implication:

All employers, payroll teams, and EPF-related processing units should immediately update their internal processes to discontinue reliance on Forms 15G/15H and transition to Form 121 for all applicable cases.