A recent update of IVG (Identity Verification Guidelines) has brought a lot of changes to the applicants of the Digital Signature Certificate (DSC) in India. Among the clarifications which should be regarded as the most important is connected with such a long-debated question: Is Aadhaar PAN Linking required to issue DSC?
The short answer: No, Aadhaar–PAN linking is no longer mandatory under the revised guidelines.
This is significant to the people, businesses and workers, who were previously unable to obtain a DSC due to a mismatch or lack of Aadhaar and PAN.
Major Update: Aadhaar PAN Linking Requirement Removed
As per Section 1.9 of the revised IVG:
Section 1.9 has changed to imply that Aadhaar does not need to be linked to PAN.
This means:
1. Applicants can now obtain a Digital Signature Certificate even if:
- Aadhaar is not linked with PAN.
- Aadhaar is unavailable.
- Aadhaar details mismatch with the PAN database.
2. PAN remains a valid identity document independently.
3. Aadhaar authentication is now only one of multiple verification methods — not compulsory.
Why This Change Matters
Earlier, many applicants faced rejection because:
- Aadhaar-PAN linking was incomplete.
- Mobile number not linked with Aadhaar.
- Aadhaar demographic mismatch.
- NRI applicants lacked Aadhaar.
The new rule removes these barriers and improves accessibility.
Section 1.25 Deleted: Physical Verification Requirements Simplified
Section 1.25 is completely done away with. It was employed to refer to additional procedures of physical checks.
The deleted provisions included:
- Optional physical verification procedures.
- Document checks and neighbourhood enquiry.
- Use of specific OID verification protocols.
- Manual identity confirmation layers.
Impact of This Deletion
The removal simplifies DSC issuance significantly:
- Faster approval timelines.
- Reduced compliance complexity for Certifying Authorities.
- Less documentation burden on applicants.
- More streamlined verification processes.
This is expected to accelerate the adoption of DSC across businesses and government compliance platforms.
New Section 2.7: CA Assisted Enrollment Mode Introduced
A new provision — Section 2.7: CA Assisted Enrollment Mode for DSC Issuance — has been introduced.
This is a major addition designed to include applicants who cannot complete Aadhaar-based online verification.
Who Can Use CA Assisted Enrollment Mode?
The new mode applies to:
- Applicants without Aadhaar.
- Applicants are unable to complete online Aadhaar authentication.
- Individuals requiring physical verification-based assurance.
- Special category applicants.
- Foreign nationals and NRIs.
- Cases with demographic mismatches.
- Organisations requiring enhanced identity assurance.
What is CA Assisted Enrollment Mode?
CA Assisted Enrollment Mode means the Certifying Authority (CA):
- Performs identity verification manually or through alternative methods.
- Uses approved documentation and verification processes.
- Provides assurance equivalent to Aadhaar-based authentication.
This ensures inclusivity while maintaining security standards.
PAN Without Aadhaar Linking: Now Possible Apply for DSC
With the revised guidelines, applicants can now obtain a Digital Signature Certificate (DSC) using PAN even if it is not linked with Aadhaar, as the mandatory Aadhaar–PAN linking requirement has been removed.
Applicants can:
- Apply using PAN + other identity documents.
- Choose CA-assisted verification.
- Complete video verification or physical verification if required.
- Obtain Class 3 DSC without Aadhaar linkage.
This is especially beneficial for:
- Senior citizens.
- Business owners with Aadhaar issues.
- Non-resident Indians.
- Professionals with multiple PAN records historically.
- Corporate directors and authorised signatories.
Benefits of the New IVG Guidelines
The revised rules bring several advantages:
For Applicants
- No dependency on Aadhaar linking.
- Higher approval success rate.
- Faster enrollment.
- More flexible identity verification options.
For Businesses and Professionals
- Easier onboarding for employees and directors.
- Simplified compliance for MCA, GST, and Income Tax filings.
- Reduced delays in tender participation and e-procurement.
For Certifying Authorities
- Standardised enrollment pathways.
- Improved coverage for special categories.
- Reduced rejection cases.
What Applicants Should Do Now
If you were previously rejected due to Aadhaar issues, you can now:
- Reapply for DSC.
- Opt for CA Assisted Enrollment Mode.
- Use PAN with an alternate identity proof.
- Complete verification through authorised RA partners like MeraDSC.
