PAN card for NRIs — when you need one, how to use it, 2026

A Permanent Account Number (PAN) is the single most-asked-for identifier in an NRI's Indian paperwork trail. It is not a legal consequence of being an NRI — you are not pushed into PAN by virtue of holding an Indian passport abroad or an OCI card — but the list of Indian transactions that require one is long, and the cost of not having it at the moment you need it is steep. This page covers the NRI-specific questions: when do you actually need a PAN, which form to use, how to keep the record clean through citizenship changes, what Section 206AA does when there is no PAN, and what the ten characters on the card mean.

Two questions NRIs usually start with

Is PAN compulsory just because I am an NRI? No. Having foreign residence does not by itself trigger a PAN requirement.
Does having a PAN mean I have to file an Indian tax return every year? No. Tax filing is triggered by taxable Indian-source income crossing the exemption threshold, not by the existence of a PAN.

Both of these sit in more detail in the myths page — see PAN card myths. The rest of this page is the positive version: when PAN is worth having, and how to run it properly.

The triggers — when an NRI actually needs a PAN

Any of the following routinely require PAN on file with the counterparty:

Opening an Indian bank account — NRE, NRO, FCNR. The bank will not complete KYC without PAN.
Opening a demat / trading / portfolio investment account — PAN mandatory.
Buying or selling immovable property in India — mandatory for the sale deed, stamp duty, and any transaction above ₹10 lakh.
Receiving rental income from Indian property.
Receiving dividend / interest / capital gains from Indian sources — PAN determines whether TDS applies at the domestic NRI rate or the higher Section 206AA 20% floor.
Claiming a DTAA treaty rate on Indian-source withholding — PAN is one of the three documents (with TRC and Form 10F).
Inheriting Indian shares, mutual funds, or property — PAN required for the heir to receive transmission.
Applying for a loan from an Indian bank / housing-finance company.
Purchasing life insurance above ₹50,000 in annual premium.
Directorship or shareholding in an Indian company.
Repatriating NRO funds abroad — Form 15CA / 15CB reference PAN.
Filing an Indian income-tax return to claim a TDS refund or reconcile DTAA relief.

If your Indian activity is genuinely just tourist visits with no financial footprint, you do not need PAN. Once any of the above hits, apply.

Which form — 49A or 49AA?

The rule is citizenship, not residence:

You hold	Form	Why
Indian passport (NRI)	Form 49A	Indian citizens use 49A regardless of where they live.
Foreign passport + OCI / PIO card	Form 49AA	OCI is not a citizenship; the foreign passport decides.
Foreign passport without OCI	Form 49AA	Any foreign-citizen applicant.

An Indian-passport NRI who wanders onto Form 49AA because they see "foreign applicants" and think that describes them will have the application rejected on scrutiny. Conversely, an OCI cardholder who files 49A because they feel Indian for most purposes creates a record mismatch that banks will question later.

For the detailed form comparison see Form 49A vs Form 49AA.

Documents for an Indian-passport NRI (Form 49A)

Since an Indian-passport holder is legally an Indian citizen, the domestic-document set applies — with the NRI's overseas address as the correspondence address:

Proof of Identity — Indian passport.
Proof of Date of Birth — Indian passport.
Proof of Address — overseas bank statement, utility bill, driver's licence, residence permit, or the Indian passport itself if it still shows a current address. Overseas documents are typically self-attested; Apostille is not required for Indian-citizen applicants (the Apostille / consular-attestation regime is a Form-49AA requirement).
Aadhaar field — left blank (with the NRI self-declaration ticked) if the applicant does not hold Aadhaar. See PAN without Aadhaar.

Documents for an OCI / foreign-citizen NRI (Form 49AA)

Proof of Identity / Date of Birth — foreign passport.
Proof of Address — OCI card (carries address; no attestation needed), or another foreign-issued document attested by Apostille / Indian consulate.

See PAN for foreigners and foreign passport as proof of address for the mechanics.

Apply online, either agency

The Income Tax Department authorises two agencies for PAN applications:

Protean eGov Technologies (NSDL) at onlineservices.nsdl.com.
UTIITSL at pan.utiitsl.com.

Either is fine. Fees in 2026:

Dispatch to an Indian address — approximately ₹107.
Dispatch to a foreign address — approximately ₹1,017.

Foreign-issued credit / debit cards now work at the portal payment gateways; demand draft payable at Mumbai remains available as a fallback. For the full application workflow see PAN card — how to apply.

Section 206AA — the cost of not having a PAN

Section 206AA is the provision that turns an absent PAN from a paperwork gap into a tax-rate issue. Where the payer does not have a valid PAN of the recipient, TDS applies at the higher of:

The rate specified in the relevant section (e.g. 20% on rent under Section 195, 10% on NRO interest, 12.5% on LTCG on property, 20% on STCG).
The rate in force.
20% — the statutory floor.

The practical effect for a non-PAN NRI:

NRO interest — 20% instead of 10% (the Section 195 domestic NRI rate).
LTCG on listed equity — 20% instead of 12.5%.
DTAA-lower rates — unavailable. A UK-resident NRI entitled to the 15% DTAA rate on dividends, for instance, cannot access it without PAN; TDS runs at 20%.

And you cannot file an Indian return to reclaim the over-deducted amount without PAN — the return itself requires one. Section 206AA makes the absent-PAN position genuinely costly.

Aadhaar-linkage and the NRI carve-out

From 1 July 2023, PAN-Aadhaar linkage became mandatory for Aadhaar-eligible persons. NRIs and OCIs are exempt — most are not Aadhaar-eligible in the first place (you must have resided in India for 182+ days in the preceding 12 months to enrol).

Two common issues:

PAN of an NRI was wrongly flagged inoperative on 1 July 2023 because the Department's record carried old "resident" data. Fix by updating residential status via a PAN correction application or by written declaration to the Jurisdictional AO.
NRI accidentally enrolled in Aadhaar on a long India trip. The Aadhaar now exists; linking it simplifies compliance but may complicate bank internal KYC where resident / non-resident flags conflict.

See PAN without Aadhaar for the detailed fix.

Keeping the PAN record in "NRI" mode

Banks, brokers and counterparties increasingly read the Department's PAN record directly — the old manual NRI- declaration to each counterparty is becoming obsolete. To keep everything clean:

Update the PAN address to the overseas address on first becoming NRI. The physical card is re-issued; the correspondence record is updated. See change of address on PAN.
Update the residential status field in the PAN record to Non-Resident.
Update the citizenship status on the PAN record when you acquire foreign citizenship. The PAN number does not change; only the associated data. Use the PAN Correction Application.
On return to India, update the record again to resident, enrol in Aadhaar after 182 days, and link.

The PAN number itself stays constant across all these transitions.

Form 60 — the PAN alternative for occasional transactions

Form 60 is a self-declaration substituting for PAN in specific transactions. It is available to:

Anyone without a PAN, including residents.
Non-residents (NRIs / foreigners) who are not otherwise required to hold PAN.

It is accepted for:

Opening a small / basic savings account (in some cases).
Cash deposits below thresholds.
Low-value transactions specifically listed in Rule 114B of the Income Tax Rules.

It is not accepted for:

Opening NRE / NRO accounts (full KYC needed).
Securities and demat accounts.
Property transactions above ₹10 lakh.
DTAA benefit claims.
Anything that will generate TDS on NRI income.

For more on what can be done without PAN, see transactions without PAN.

Tax-filing obligations for NRIs with a PAN

Simply holding a PAN does not create a filing obligation. The Indian-tax return is required if:

Indian-source taxable income in the financial year exceeds the basic exemption limit (₹2,50,000 in the old regime; ₹3,00,000 in the new; ₹3,00,000 / ₹5,00,000 for senior citizens).
There are assets outside India to disclose (not applicable for NRIs; this applies to ROR assessees).
The NRI wants to claim a refund of TDS over- withheld.
The NRI wants to carry forward losses (capital losses for future set-off).
There are TDS-exempt-but-substantial receipts requiring disclosure.

Typical NRI filing scenarios:

NRE / FCNR interest only — usually tax-exempt under Section 10(4)(ii) and 10(15)(iv); generally no filing obligation.
NRO interest + rental income — filing usually worthwhile to reconcile TDS and claim refund of overpayment.
Property sale by NRI — filing mandatory to reconcile Section 195 TDS against actual capital- gains tax.
DTAA-based lower withholding — filing recommended to maintain the treaty-relief trail.

For the broader NRI tax framework see NRI taxation in India.

What the characters on the PAN mean

A PAN is ten characters, AAAAA9999A — five letters, four digits, one letter. The structure:

Characters 1–3 — a random letter sequence.
Character 4 — the status code:
- P — Individual.
- F — Firm / LLP.
- C — Company.
- H — Hindu Undivided Family (HUF).
- A — Association of Persons (AOP).
- T — Trust.
- B — Body of Individuals (BOI).
- L — Local Authority.
- J — Artificial Juridical Person.
- G — Government.
Character 5 — the first letter of the surname for individuals, or the first letter of the entity name for others.
Characters 6–9 — a random number sequence.
Character 10 — a check-digit letter.

An NRI individual's PAN will therefore look like AAAP?9999A where the fifth character matches the surname's first letter. If the fifth character doesn't match the surname as currently used (after marriage / legal name change), file a PAN correction to update the record rather than applying for a new PAN.

Common NRI scenarios

Opening an NRO account to deposit rental income

Pre-requisite — PAN required for bank KYC.
Form — 49A if Indian passport, 49AA if OCI / foreign passport.
Before the bank visit — e-PAN in hand.

Selling Indian property as an NRI

Pre-requisite — operative PAN updated with NRI status and current overseas address.
Buyer deducts TDS under Section 195; without PAN, Section 206AA applies the 20% floor.
File an Indian return in the year of sale to reconcile TDS against actual capital gains tax.
See buying and selling property.

Inheriting Indian securities

Pre-requisite — PAN of the heir.
Routed through an NRO non-PIS demat account; sale proceeds repatriable via Form 15CA/CB within the USD 1 million cap.
See transferring inherited shares.

Receiving Indian pension abroad

Pre-requisite — PAN on file with the pension- paying branch.
Without PAN, Section 206AA 20% floor on pension TDS.
See receiving an Indian pension abroad.

DTAA-rate withholding on Indian-source interest

Pre-requisite — PAN + TRC + Form 10F filed on the Income Tax e-Filing portal.
Missing any of the three, the payer deducts at domestic rates + Section 206AA floor.

Common pitfalls

Applying on the wrong form. 49A for Indian passport, 49AA for OCI / foreign — based on citizenship, not residence.
Listing an Indian address on a 49A NRI application to save on foreign-dispatch fees, then losing track of the PAN record. Use the overseas address or a reliable family address in India.
Assuming the PAN was deactivated because a bank flagged an "inoperative" status. NRI PANs are rarely deactivated; they are misflagged as inoperative due to stale residential status. Update the record rather than reapplying.
Holding two PANs — one issued years ago as a resident, another applied for after becoming NRI. Section 272B penalty ₹10,000. Surrender the duplicate.
Filing the Indian return without DTAA detail. Claim treaty relief explicitly with TRC, Form 10F and the relevant schedule.
Forgetting to update PAN on citizenship change. Run a PAN correction to reflect OCI / foreign passport status.
Using the physical card printed years ago as the only proof. The e-PAN is the current canonical copy; download it fresh when needed.

Checklist — an NRI's PAN in 2026

Decide if you actually need one — run through the triggers list.
Pick the form — 49A (Indian passport) or 49AA (OCI / foreign passport).
Apply online on Protean / NSDL or UTIITSL; pay ~₹107 Indian dispatch or ~₹1,017 foreign dispatch.
Keep the PAN record updated — residential status, overseas address, photograph, citizenship change all run through the PAN correction application without changing the PAN number.
Confirm NRI carve-out applies for Aadhaar linkage; fix inoperative flags proactively.
File the Indian return whenever you have taxable Indian income or want to reclaim over-withheld TDS.
Use Form 60 for low-value occasional transactions where PAN is asked and you don't have one.
On return to India, update the record to resident; enrol in Aadhaar after 182 days; link.

Summary

PAN is not mandatory on the basis of NRI status. It becomes required when Indian financial activity hits specific thresholds.
Form 49A for Indian-passport NRIs; Form 49AA for OCI and foreign-passport applicants. Citizenship decides.
Section 206AA imposes a 20% TDS floor on non-PAN recipients and blocks DTAA relief — the single biggest reason to get PAN once Indian-source income appears.
NRIs are exempt from PAN-Aadhaar linkage under Section 139AA; update the residential status on the PAN record to keep the PAN operative.
The PAN number is permanent across name, residence and citizenship changes — use the correction application, not a new application.
Form 60 covers low-value occasional transactions; it does not substitute for PAN in NRE / NRO account opening, property, securities, or DTAA claims.

For the full application mechanics, see PAN card — how to apply. For the form split, see Form 49A vs Form 49AA. For the foreign-citizen path, see PAN for foreigners. For the Aadhaar-linkage rule, see PAN without Aadhaar. For validity checks, see verify your PAN. For transactions that don't need PAN, see transactions without PAN.