You received an EOBI notice. What happens next, and what the deadlines are.

1. First, work out which kind of notice you are holding

EOBI correspondence falls into four families; the section the letter quotes tells you which one you have.

Before anything else, write down the date on the notice, the date you received it, and the date by which it asks you to respond.

2. Does the Act even apply to you?

Under s.1(4)(i) of the Employees' Old-Age Benefits Act 1976, the Act applies to every industry or establishment in which five or more persons are employed, or were employed on any day during the preceding twelve months. Smaller establishments may opt in voluntarily under s.1(4)(ia), and the Federal Government can extend the Act to other classes of establishment under s.1(4)(ii). Once the Act applies, s.11(1) obliges the employer to notify the Institution within thirty days, and the Institution then registers the establishment under s.11(3).

Two points catch employers out. The headcount test looks back twelve months, so a business that briefly had five people on the payroll last year can still be inside the Act today. And "persons employed" is read widely in practice: probationers, daily-wage workers and contractor-supplied workers are often counted. Whether the Act applies at all is exactly the kind of question s.33 exists to decide, on the records you can produce.

3. The figures: what a demand should be built on

The contribution rates are in the Act itself. Under s.9(1) the employer pays five per cent of wages for each insured person each month, and under s.9B the insured person contributes one per cent, which the employer deducts from pay under Rule 3(4) of the Employees' Old-Age Benefits (Contributions) Rules 1976. Section 9(3) prohibits the employer from recovering its own five per cent share from the employee's wages, and doing so is an offence under s.37.

For contribution purposes "wages" is pegged to the minimum wage in force rather than to the employee's actual salary, and EOBI issues a circular each time the figure changes. The federal budget for 2026-27 raised the federal minimum wage from Rs 37,000 to Rs 40,700 per month (source: The Nation, 12 June 2026, reporting the Finance Minister's budget speech). At Rs 40,700 the monthly contribution is Rs 2,035 (employer) plus Rs 407 (employee), Rs 2,442 in total per insured person; at the previous Rs 37,000 base it was Rs 1,850 plus Rs 370, Rs 2,220 in total. Which base applies to each month in a demand depends on the EOBI circular in force for that month, so check the demand against the circulars, not just against the headline rate.

4. The deadlines that matter

The 15th of the following month

Rule 3(2) of the Contributions Rules makes each month's contribution fall due at the end of that month and payable not later than the 15th of the next. Payment goes into the Institution's collection account at an authorised bank on the PR-03 slip (Rule 3(6)) or through EOBI's online facility, and is recorded in each insured person's Pass Book (Form PR-11).

The late-payment increase

Section 13(1) of the Act allows the amount of an unpaid contribution to be increased by a prescribed percentage, and Rule 4 prescribes it: two per cent for every month or part of a month the contribution remains unpaid, capped at fifty per cent of the contribution. The cap matters: on a very old arrear the increase stops growing once it reaches half the original contribution, so a demand showing an increase larger than fifty per cent of the principal is wrong on its face.

Thirty days to register

Section 11(1) gives a newly covered employer thirty days to notify the Institution. If a coverage notice has arrived, that clock has usually already run; what matters now is responding within the period the notice itself gives.

The response date on the notice

The Act does not fix one response period for every notice; the date on the letter is the one that counts. If it is unrealistic, ask for an extension in writing before it expires and keep proof. Silence is treated as having nothing to say.

5. The dispute ladder: s.33, s.34 and s.35

1. Determination under s.33. The Institution must decide any question about whether a person is an insured person, what their wages are, the amount of contribution payable, who the employer is, and entitlement to benefit. The decision must be in writing and must give reasons. If a demand has reached you without a reasoned decision, you are entitled to ask for one, and that request is the first step.
2. Review under s.34. The Institution may review its own decision on the basis of new facts, but only after giving the affected person an opportunity to be heard and to produce evidence. A review is the right route where the demand rests on a factual error, such as a wrong headcount, a wrong period or employees who had already left.
3. Appeal to the Board under s.35. A person aggrieved by a decision under s.33 or s.34 may appeal to the Board, subject to the rules, which set the procedure and the time allowed. Count the appeal period from the date you received the written decision, and lodge within it; an appeal filed late is the easiest for the Board to dismiss.

Separately, s.37 makes non-payment, false returns, deducting the employer's share from wages and obstructing an official offences, punishable by up to two years' imprisonment, a fine of up to ten thousand rupees, or both; s.38 requires prior sanction and a complaint within six months. Prosecution is rare compared with assessment and recovery, but it is why an inspection notice should never be ignored.

6. What to do in the first 48 hours

1. Log the three dates (notice date, receipt date, response date) and photograph the envelope and every page.
2. Identify the notice type from the table above and the section it relies on.
3. Pull the records the Act expects you to hold under s.10 and Rule 3: wage registers, attendance, appointment letters, PR-02 or PR-02A annual returns, PR-03 challans, and the Pass Books. Gaps in these are what an assessment under s.12(3) is built on.
4. Recompute the figures month by month, as described in section 3, and note every difference.
5. Reply in writing before the response date. Acknowledge receipt, state whether you accept or dispute the figures, ask for the reasoned s.33 decision if none was given, and ask for an extension if you need one.
6. If a visit is scheduled under s.12, nominate one person to receive the official, provide what is asked for, and keep a record of what was examined and copied.
7. Decide, on the figures, whether to pay, pay under protest, or dispute. Paying the undisputed part promptly stops the s.13 increase running on that part.

Frequently asked questions

General guidance, not legal advice. This page summarises the Employees' Old-Age Benefits Act 1976 and the Employees' Old-Age Benefits (Contributions) Rules 1976 as they stood on the date of publication, together with publicly reported wage figures with their source named. It does not address the facts of any particular notice, and it is not a substitute for advice on your own case. Figures and section numbers should be verified against the current text of the Act, the Rules and the EOBI circular in force for the period in question. Sources: Employees' Old-Age Benefits Act 1976 (text published by the Ministry of Overseas Pakistanis and Human Resource Development); Employees' Old-Age Benefits (Contributions) Rules 1976; The Nation, 12 June 2026 (federal minimum wage Rs 40,700).

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