Accounting Standards

Ind AS 26 – Accounting and Reporting by Retirement Benefit Plans: Complete Guide

📅 Updated: June 2025 ⏱ 16 min read 🏛 MCA Notified Standard 📊 Applies to: EPF Trusts, Gratuity Funds, Pension Plans

📋 Table of Contents

  1. Overview & Objective
  2. Scope & Applicability
  3. Types of Retirement Benefit Plans
  4. Defined Contribution Plans — Reporting
  5. Defined Benefit Plans — Reporting
  6. Investments by Retirement Benefit Plans
  7. Actuarial Valuation Requirements
  8. Disclosure Requirements
  9. IGAAP vs Ind AS 26
  10. Case Studies: Indian Retirement Funds
  11. FAQs
📜 Standard Reference: Ind AS 26 — Accounting and Reporting by Retirement Benefit Plans is notified by MCA under Companies (Indian Accounting Standards) Rules, 2015. This standard deals with how retirement benefit plans themselves (the funds/trusts) prepare and present financial statements — not how the sponsoring employer accounts for retirement benefits (which is covered by Ind AS 19). It is based on IAS 26 and applies to funds established for the benefit of employees.
💡 Important Distinction: Ind AS 26 governs the financial reporting of the retirement benefit plan itself (the trust/fund entity). The sponsoring employer's accounting for the cost of providing retirement benefits (gratuity expense, PF contribution, etc.) is governed by Ind AS 19 — Employee Benefits.

Overview & Objective

Retirement benefit plans are arrangements under which an employer provides benefits to employees after retirement. These plans accumulate assets over the working lives of employees to fund future obligations. In India, the most common forms are:

Ind AS 26 establishes how these plans should present their financial statements to members and other stakeholders. The primary objective is to provide information about the resources and activities of a retirement benefit plan so that users can assess the plan's ability to meet its future obligations to members.

🔑 Key Objectives of Ind AS 26

  • Standardise financial reporting by retirement benefit plans in India
  • Ensure members can assess whether the plan can meet its future benefit obligations
  • Distinguish between defined contribution and defined benefit plan reporting requirements
  • Mandate actuarial valuation disclosures for defined benefit plans
  • Prescribe investment reporting requirements for plan assets
  • Ensure adequate disclosure of funding status and actuarial assumptions

Scope & Applicability

Ind AS 26 applies to the financial statements of retirement benefit plans where such plans are required to prepare financial statements. In India, the following entities typically fall under its scope:

Entity TypeExamplesRegulatory Oversight
Exempted PF TrustsTata Group PF Trust, Infosys PF Trust, SAIL PF TrustEPFO + Income Tax (Section 17)
Approved Gratuity FundsCompany-specific gratuity trusts of large PSUsIncome Tax Act, Payment of Gratuity Act
Superannuation FundsCompany superannuation trusts of banks, insurance companiesIRDA + Income Tax
Pension FundsPrivate sector defined benefit pension schemesPFRDA + Trust Deed

Exclusions from Scope

Types of Retirement Benefit Plans

Ind AS 26 distinguishes between two fundamental types of retirement benefit plans, each with different reporting requirements:

Defined Contribution (DC) Plans

In a DC plan, the amount contributed by the employer (and often also the employee) is fixed, and the eventual benefit depends entirely on contributions made plus investment returns. The employer has no obligation beyond making the specified contributions.

Indian Examples:

Defined Benefit (DB) Plans

In a DB plan, the benefit to be paid to members is defined by the plan formula (e.g., based on years of service and final salary). The employer bears the investment risk — if assets underperform, the employer must make up the shortfall.

Indian Examples:

Defined Contribution Plans — Reporting Requirements

For DC plans, the financial statement requirements under Ind AS 26 are relatively straightforward:

Financial Statements Required

  1. Statement of Net Assets Available for Benefits — showing total assets at fair value less any liabilities
  2. Statement of Changes in Net Assets Available for Benefits — showing contributions, investment income, benefit payments, and expenses
  3. Description of the Plan — summarising key terms and conditions

Measurement Basis

For DC plans, there is no need for actuarial valuation of liabilities. The "liability" of a DC plan is simply the accumulated account balances of members — the plan's net assets should equal these balances (with any surplus/deficit arising from timing differences).

DC Plan Financial Statements — Statement of Changes in Net Assets (Illustrative)
Opening Net Assets Available for Benefits ₹500,00,00,000
Add: Employer Contributions Received ₹120,00,00,000
Add: Employee Contributions Received ₹60,00,00,000
Add: Investment Income (Interest + Dividends) ₹42,00,00,000
Add: Net Realised Gains on Investments ₹18,00,00,000
Less: Benefits Paid to Members (₹85,00,00,000)
Less: Plan Administration Expenses (₹3,00,00,000)
Closing Net Assets Available for Benefits ₹652,00,00,000

Defined Benefit Plans — Reporting Requirements

DB plans have more complex reporting requirements under Ind AS 26 because they must disclose the relationship between plan assets and the actuarial present value of promised benefits.

Financial Statements Required

  1. Statement of Net Assets Available for Benefits — at fair value
  2. Statement of Changes in Net Assets Available for Benefits
  3. Actuarial Present Value of Promised Benefits — either in the main statements or in accompanying notes/actuarial report
  4. Description of Relationship — between plan assets and the actuarial liability

Three Acceptable Presentation Approaches

Ind AS 26 permits three approaches for presenting the actuarial liability in DB plan financial statements:

ApproachDescriptionNet Assets
Approach 1Actuarial present value shown in the main statement of net assets, enabling direct calculation of surplus/deficitNet assets shown AFTER deducting actuarial liability = net surplus/(deficit)
Approach 2Actuarial present value shown as a note to the main statement of net assetsNet assets shown at face value; actuarial liability disclosed separately
Approach 3Actuarial present value included in a separate actuarial report accompanying (but separate from) the financial statementsNet assets shown at face value; reader cross-refers to actuarial report

🏦 Case Study 1: Tata Group Employees' Provident Fund Trust — Reporting Framework

The Tata Group maintains one of India's largest exempted PF trusts, covering employees across Tata Steel, Tata Motors, TCS, and other group companies. The trust manages assets worth several thousand crore rupees.

Plan Type: Primarily defined contribution, but with an EPFO-mandated guaranteed minimum interest rate (currently 8.15% for FY 2023-24) — creating a DB element for the guaranteed return
Investment Portfolio: Predominantly government securities and bonds (per EPFO investment pattern norms — minimum 45% in central/state government securities, 15-20% in bonds of public financial institutions)
Reporting Under Ind AS 26: Annual report with Statement of Net Assets at fair value; separate actuarial report quantifying the guaranteed interest rate obligation vs expected investment returns
Key Risk: If market interest rates fall significantly below the EPFO-mandated guaranteed rate, the trust faces a DB-type shortfall risk — requiring employer top-up

The employer (Tata companies) discloses in their own financial statements (under Ind AS 19) any expected liability arising from this interest rate guarantee — connecting the plan's Ind AS 26 reporting to the employer's Ind AS 19 accounting.

Investments by Retirement Benefit Plans

Ind AS 26 requires retirement benefit plan investments to be carried at fair value in the plan's financial statements. This is a significant difference from some other standards that permit cost or amortised cost.

Fair Value Requirement

Investment Pattern Restrictions (India)

In India, retirement benefit plans must comply with EPFO investment pattern guidelines (for PF trusts) or IRDA investment norms (for insured plans). These prescribe minimum allocations to government securities to ensure capital safety.

Asset CategoryEPFO Pattern (Min %)Typical Allocation
Central Government Securities45%40-55%
State Government SecuritiesIncluded in 45%Within 45%
Public Sector Bonds (AAA)15-20%15-20%
Private Sector Bonds (AA+)Up to 10%5-10%
ETFs / EquitiesUp to 15%5-15%
Infrastructure BondsUp to 5%3-5%

🏥 Case Study 2: SAIL Gratuity Fund Trust — Defined Benefit Plan Reporting

Steel Authority of India (SAIL), as one of India's largest employers with 70,000+ employees, maintains a significant approved gratuity fund trust. SAIL's gratuity obligation is a classic defined benefit arrangement where the benefit formula is fixed by the Payment of Gratuity Act.

Benefit Formula: 15 days' last drawn salary × years of service (minimum 5 years, maximum ₹20 lakh for private sector; no cap for PSUs)
Plan Assets (FY 2024-25 approx): ₹2,500-3,000 crore — invested in LIC group gratuity policy and self-managed trust assets
Actuarial Assumptions: Discount rate ~7.2% (10-year G-Sec yield); salary escalation 6%; attrition rate 2-4% for senior staff
Funding Status: Plan assets vs Present Value of Obligation (PVO) — SAIL discloses the surplus/(deficit) in Ind AS 19 notes in its own accounts, while the trust prepares Ind AS 26 statements

Under Approach 2 (most common in India), the trust's financial statements show net assets at fair value, with the actuarial present value of the gratuity obligation disclosed as a note. The surplus/deficit is the difference between the two — indicating how well-funded the trust is.

Actuarial Valuation Requirements

For defined benefit plans, Ind AS 26 requires the actuarial present value of promised retirement benefits to be disclosed. This requires an actuarial valuation.

Vested vs Non-Vested Benefits

TypeDefinitionExample
Vested BenefitsBenefits that are not contingent on future employment — the member has earned these regardless of whether they continue employmentAccumulated EPF balance; gratuity after 5 years of service
Non-Vested BenefitsBenefits contingent on continued employment or other conditionsGratuity for employees with less than 5 years of service

Key Actuarial Assumptions (India)

Frequency of Valuation

Ind AS 26 encourages annual actuarial valuations. If the valuation is not performed annually, the plan must use the most recent valuation as a base and adjust for significant changes in the plan population, benefit terms, or economic conditions.

💼 Case Study 3: Infosys BPM Superannuation Trust — DC Plan with Ind AS 26 Application

Infosys BPM (formerly Infosys BPO) maintains a superannuation trust for senior employees — a defined contribution arrangement where the company contributes a fixed percentage of salary, and members choose investment options.

Contribution Rate: 15% of basic salary — entirely employer contribution; employee may optionally contribute
Investment Options: Members choose from equity (index funds), balanced (equity+debt), and conservative (debt-heavy) options — returns are market-linked
Ind AS 26 Application: Trust prepares simplified DC plan statements — Statement of Net Assets and Statement of Changes; no actuarial valuation required
Fair Value Disclosure: All investments (primarily mutual fund units) disclosed at NAV-based fair value on reporting date; significant unrealised gains/losses disclosed

The sponsor (Infosys BPM) recognises only the contribution paid/payable as an expense in its own P&L under Ind AS 19 — the market performance risk lies entirely with members. This is the essential DC characteristic that distinguishes it from DB plans.

Disclosure Requirements

Ind AS 26 mandates comprehensive disclosures in the financial statements of retirement benefit plans:

For Both DC and DB Plans

Additional Disclosures for DB Plans

Investment Disclosures

IGAAP vs Ind AS 26

🔴 Indian GAAP (Pre-Ind AS)

  • AS 15 covered employer's accounting; limited specific guidance for the plan itself
  • Plans typically prepared statements under trust deed requirements or EPFO norms
  • No standardised fair value requirement for plan investments — cost or amortised cost permitted
  • Actuarial valuation disclosure not uniformly mandated in plan statements
  • Varied presentation formats — no standard statement structure
  • Related party disclosures to sponsoring employer not specifically required

🟢 Ind AS 26

  • Comprehensive standard specifically for retirement benefit plan financial statements
  • Fair value measurement mandatory for all plan investments
  • Separate requirements for DC vs DB plans
  • Actuarial present value of promised benefits — mandatory disclosure for DB plans
  • Standardised financial statement format and disclosure requirements
  • Explicit disclosure of related party transactions with sponsoring employer

Frequently Asked Questions

Does Ind AS 26 apply to EPFO (Employees' Provident Fund Organisation) itself?

No — Ind AS 26 specifically excludes social security arrangements administered by national governments. EPFO is a statutory body established under the Employees' Provident Funds & Miscellaneous Provisions Act, 1952, and is excluded from the scope of Ind AS 26.

EPFO prepares its accounts under government accounting standards and EPFO-specific norms, not under Ind AS 26.

However, Ind AS 26 does apply to exempted establishments — large employers (like Tata, Infosys, HUL, etc.) who maintain their own PF trusts with EPFO exemption. These private trusts are required to follow Ind AS 26 if they fall within the scope of Ind AS reporting.

The key test is whether the plan is established by a private entity (even if regulated by EPFO/IRDA/PFRDA) vs whether it is a government social security scheme. Private trusts with EPFO exemption → Ind AS 26 applies. EPFO itself → Ind AS 26 does not apply.

How does Ind AS 26 interact with Ind AS 19 from the employer's perspective?

Ind AS 19 and Ind AS 26 address two different entities but are closely related:

Ind AS 19 (Employer's Perspective): Governs how the sponsoring employer recognises and measures the cost of providing retirement benefits in its own financial statements. For DB plans, this includes recognising the net defined benefit liability (obligation minus fair value of plan assets), current service cost, interest cost, and actuarial gains/losses (through OCI).

Ind AS 26 (Plan's Perspective): Governs how the retirement benefit plan/trust itself prepares financial statements for the benefit of members and regulators.

The Connection: The "fair value of plan assets" in the employer's Ind AS 19 calculation should correspond to the "net assets available for benefits" in the plan's Ind AS 26 statements. Similarly, the actuarial present value disclosed in the plan's Ind AS 26 statements should tie to the "present value of defined benefit obligation" in the employer's Ind AS 19 calculations (though different actuarial assumptions may be used — Ind AS 26 uses current market conditions while Ind AS 19 also uses current conditions but specifically references high-quality corporate bond yields).

In practice, large Indian companies like Tata Steel or ONGC have their gratuity fund trusts prepare Ind AS 26 statements, and the same actuarial firm that values the trust for Ind AS 26 also provides the Ind AS 19 valuation for the company's financial statements — ensuring consistency.

What are the key challenges for Indian retirement benefit plan trustees in applying Ind AS 26?

Indian trustees face several practical challenges in implementing Ind AS 26:

1. Fair Value of Illiquid Investments: Many PF trusts hold significant portions in private placement bonds, unlisted NCDs, or real estate. Fair valuing these illiquid instruments requires a credible methodology — FIMMDA guidelines provide some direction for bonds, but real estate requires external valuation that may not be updated annually.

2. Actuarial Valuation Cost: Small company gratuity trusts may find the cost of annual actuarial valuations by qualified actuaries (Fellow of Institute of Actuaries of India — FIAI) disproportionate to the benefit. Ind AS 26 allows triennial valuations with annual updates, but even this requires actuarial expertise.

3. Interest Rate Guarantee Quantification: For EPFO-exempted PF trusts, quantifying the liability arising from the guaranteed minimum interest rate (currently 8.15%) when investment portfolios may not achieve this return creates a complex valuation challenge — part DC, part DB.

4. EPFO Compliance Overlap: Exempted PF trusts must simultaneously comply with EPFO reporting requirements (Form 3A, Form 6A, monthly ECR) AND prepare Ind AS 26 financial statements. These two sets of requirements have different bases (cost vs fair value for investments) requiring parallel records.

5. Governance and Trustee Capacity: Many company trustees lack accounting expertise. Managing the transition from simple cash-basis trust accounts to Ind AS 26 compliant statements with fair value investments and actuarial disclosures requires significant capacity building.

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