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PFRDA Issues Comprehensive Master Circular on Investment Guidelines for UPS/NPS/APY Schemes

PFRDA releases a fresh Master Circular detailing investment rules for UPS, NPS, and APY schemes.

The Pension Fund Regulatory and Development Authority (PFRDA) has released a new Master Circular on Investment Guidelines dated 10 December 2025, bringing together and superseding earlier circulars for UPS, NPS, NPS Lite, APY and APY Fund Scheme applicable to Central Government, State Government (default), Corporate CG and other government-sector subscribers.

The circular, issued under Section 14(2)(b) read with Section 23 of the PFRDA Act, 2013, aims to consolidate decades of investment norms, enhance transparency, and streamline compliance among Pension Funds and the NPS Trust.


Earlier Circulars Subsumed; New Guidelines Effective Immediately

The Master Circular replaces the previous circular dated 28 March 2025, along with all circulars and letters listed in its Appendix. However, PFRDA has clarified that:

  • All actions taken under earlier circulars will remain valid.
  • Rights, obligations, liabilities, and proceedings linked to earlier circulars will continue uninterrupted.

This ensures full continuity for both pension funds and subscribers while adopting the new framework.


Key Components of the New Investment Framework

The Master Circular provides detailed investment norms grouped under five broad categories.


1. Government Securities – Up to 65%

Pension Funds may invest up to 65% of scheme assets in:

  • Government Securities
  • Fully and unconditionally guaranteed securities
  • “Govt. of India Fully Serviced Bonds” issued post 3 June 2020 under EBR
  • G-Sec-dedicated mutual funds (up to 5% of the G-Sec portfolio)

A maximum of 10% of the G-Sec portfolio may be invested in guaranteed securities.


2. Debt Instruments – Up to 45%

This category includes a wide set of permissible debt investments such as:

  • Listed corporate bonds
  • Basel-III Tier-1 bonds (up to 2% of scheme AUM)
  • Rupee bonds issued by IBRD, IFC, ADB
  • Term deposits of eligible scheduled commercial banks (subject to strict NPAs, profit history and CRAR conditions)
  • Debt mutual funds (up to 5% of the debt portfolio)
  • REIT/InvIT debt instruments
  • Infrastructure-related bonds, including those issued by Indian Railways and Government authorities

Rating requirements are stringent, with AA or above required across most categories.

Pension Funds may also invest below AA ratings only within a tightly capped 10% exposure, and excess exposure must be fully covered by Credit Default Swaps (CDS).


3. Short-Term Debt & Money Market – Up to 10%

Short-term investments may include:

  • Treasury Bills
  • Commercial Papers (must be A1+ rated by at least two agencies)
  • Certificates of Deposit
  • Units of short-duration mutual funds
  • Lending in TREPS through CCIL

Banks issuing CDs or TDRs must meet the same financial criteria applied under the main debt category.


4. Equities & Related Investments – Up to 25%

Equity exposure is allowed through:

  • Stocks in the NIFTY 250 Index, and BSE 250 constituents not in NIFTY 250
  • Equity Mutual Funds (up to 5% of equity portfolio)
  • ETFs replicating Nifty 50 or BSE Sensex
  • ETFs created for Government disinvestment
  • IPO, FPO, OFS, subject to strict eligibility and reporting norms

PFRDA mandates that 90% of Equity AUM be invested in the top 200 stocks of the NIFTY 250 index.


5. Asset-Backed, Trust-Structured & Miscellaneous – Up to 5%

This includes:

  • RMBS/CMBS
  • REIT units
  • InvIT units
  • SEBI-regulated AIF Category I & II
  • Gold and Silver ETFs (aggregate cap of 1% each of scheme AUM)

AIF investments must meet corpus, eligibility, sponsor-restriction, and asset-allocation norms.


Additional Restrictions and Portfolio Controls

The circular also introduces robust safeguards to manage concentration risk:

Equity Exposure Caps

  • Up to 5% of paid-up capital of sponsor-group companies
  • Up to 10% for non-sponsor companies

Debt Exposure Caps

  • Up to 5% of net worth of sponsor-group companies
  • Up to 10% for non-sponsor companies

Industry-wise Exposure

  • Exposure to any single industry capped at 15% of total AUM.
  • Bank FDs are exempt from this limit.

InvITs/REITs

  • Cumulative investments capped at 3% of total AUM.

Brokerage Limits

Brokerage on equity transactions is capped at 0.03%, inclusive of stamp duty and taxes.


Rules for IPO/FPO/OFS Participation

Pension Funds may invest in public offerings only if:

  • IPOs are proposed to be listed on BSE/NSE and meet minimum float criteria
  • FPO/OFS shares belong to the Top-250 NIFTY list
  • Investments are reported to NPS Trust within 30 days
  • Non-compliant IPO investments must be exited within one year of listing

NPS Tier-II Tax Saver Scheme (TTS) Investment Limits

The circular prescribes:

Asset ClassAllowed Allocation
Equity10%–25%
DebtUp to 90%
Cash/Money Market & Liquid MFUp to 20% (after corpus reaches ₹5 crore)

Increase in Overall Asset Class Flexibility

PFRDA has increased the combined caps across asset classes from 140% to 150%, providing greater flexibility for Pension Funds to manage risk-return strategies.


Comprehensive List of Consolidated Circulars

The Appendix of the document lists 27 circulars, ranging from 2013 to 2025, now merged into this single Master Circular. This unifies guidance related to investment ratings, IPO participation, operational norms, APY fund management, and more.


Conclusion

With this Master Circular, PFRDA has delivered a fully harmonised investment framework for all Government-Sector pension schemes—including UPS, NPS, NPS Lite, APY, and APY Fund. The consolidation enhances clarity, reduces compliance burden, and strengthens risk management protocols across Pension Funds and the NPS Trust.

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