Comparative Perspectives: Complete Notes

This note brings together three comparisons: PFRDA with India's other financial regulators, SEBI and IRDAI; the NPS with the EPF and PPF; and India's pension system with models abroad.

1. PFRDA, IRDAI and SEBI

Statutes: SEBI Act, 1992; IRDA Act, 1999 with the Insurance Act, 1938; PFRDA Act, 2013 (in force 1 February 2014).
Mandates: all combine regulation with development and protection of investors, policyholders or subscribers.
Composition: SEBI includes Government and RBI nominees; IRDAI up to five whole-time and four part-time members; PFRDA 3 + 3 with expertise in economics, finance and law.
Borrowed powers: PFRDA's interim measures and cease and desist orders mirror SEBI's Sections 11(4) and 11D.
Differences: PFRDA's search needs no court order; its adjudicating officer only recommends; no settlement mechanism; Court of Session rather than Special Courts.
Common: appeals to the SAT, Government directions and supersession, CAG audit.
Distinctive: product features fixed by statute (Section 20), system design, administration of Government schemes, and the offshore investment bar.

2. NPS, EPF and PPF

Basis: NPS under the PFRDA Act; EPF under the Code on Social Security, 2020; PPF under the PPF Scheme, 2019.
Returns: NPS market-linked; EPF 8.25% declared for 2025-26; PPF 7.1% for October to December 2026.
Liquidity: NPS locked to sixty with partial annuitisation; EPF full withdrawal on retirement; PPF fifteen-year lock-in.
Tax: NPS 60% exempt at exit, annuity taxable; EPF largely exempt within limits; PPF fully exempt-exempt-exempt.
Conclusion: complementary instruments rather than substitutes.

3. International Models

Framework: the World Bank multi-pillar model (1994, 2005).
Chile: individual accounts (1981), with an employer contribution and solidarity added in 2025.
US: Social Security plus 401(k) plans under ERISA.
UK: automatic enrolment (2012 onwards) and pension freedoms (2015).
Australia: Superannuation Guarantee of 12% from July 2025.
Singapore, Netherlands, Sweden: CPF LIFE payouts, collective funded pensions, and notional defined contribution accounts.
India: 52nd of 52, grade D, in the Mercer CFA index 2025; lessons on auto-enrolment, employer contributions, social pension floors, payouts, costs and governance.

⚠ Key point

PFRDA shares a dual mandate, SAT appeals and Government control with SEBI and IRDAI, and borrows SEBI's interim and cease and desist powers, but differs on search, adjudication, settlement and trial forum, and is unique in having statutory product features and an offshore bar. The NPS, EPF and PPF differ in risk, returns, liquidity and tax, and work best together. Internationally, India ranks last in the Mercer CFA index 2025; models from Chile, the UK, Australia, Singapore, the Netherlands and Sweden point to auto-enrolment, employer contributions, social floors and better payouts.

4. Related Topics and Provisions

PFRDA and other financial regulators
EPF and the Code on Social Security, 2020
Pension coverage in India
Evaluation of the Act and the way forward