FCRA registration, grant records and annual reporting support

Trusts and institutions

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Year-end

Review a proposed foreign contribution before it reaches the organisation’s bank account. TheTaxCo assesses the receipt route, handles registration or prior-permission applications, authority queries and annual reporting, supported by reconciled grant records.

The starting questions are the donor’s status, the nature of the receipt, the organisation’s existing approval, the proposed purpose and the permitted banking route. A transfer from abroad is not classified solely from the currency or the bank account used.

Registration and prior permission

FCRA registration and prior permission are distinct routes. Prior permission concerns a specified donor, amount and purpose; registration requires its own eligibility and activity review. An overseas donor’s willingness to pay does not establish the recipient’s permission to receive the contribution. MHA FCRA guidance.

We examine the constitution documents, approval history, activities and donor agreement before preparing the selected application. For an existing registration, expiry, renewal conditions and any change in purpose, geography, bank accounts or governing particulars form part of the review.

The 2026 purpose and geography requirements

Registration now records the approved purposes and States or Union territories of operation. Existing registered associations have a one-year transition period from commencement of the 2026 rules to intimate the purposes and territories they seek to retain through FC-6F. This does not, by itself, require them to apply for fresh registration. PIB explanation of the 2026 FCRA changes.

Rule 14A, effective from 22-06-2026, treats an association as having undertaken “reasonable activity” for renewal under section 16 if it has used at least ₹10 lakh of foreign contribution in its chosen field during the last two financial years. The test counts only activity funded from foreign contribution received under the Act. Meeting it leaves the other renewal conditions and the authority’s inquiry to be assessed. Foreign Contribution (Regulation) Amendment Rules, 2026, rule 14A and PIB FCRA factsheet, 22-07-2026.

The review compares the grant’s intended activity and location with that approval record. Changes need to be assessed before funds are committed to a new purpose or territory.

Where prior permission provides for instalment release, FC-3BB is the application for release of a second or subsequent instalment. MHA’s current application services and 2026 amendment.

Where a prior-permission contribution is released in instalments, the government’s current guidance requires 75% of an instalment to be used and verified before the next instalment is released. The permission’s other conditions still need to be met; the percentage alone does not establish an automatic right to release. PIB FCRA factsheet, 22-07-2026

Keep receipts and expenditure traceable

Foreign contribution must follow the prescribed FCRA banking route, including receipt into the designated SBI New Delhi Main Branch account and the applicable rules for other FCRA and utilisation accounts. Domestic funds must be kept out of the FCRA accounts. MHA guidance on FCRA accounts.

We reconcile opening balances, receipts, interest, transfers between permitted accounts, expenditure and closing balances. Each grant needs its agreement, budget, activity evidence and expense support. Transfers between the organisation’s own accounts should not be counted as fresh donations or expenditure.

The 2026 reporting changes require more detailed project, activity and donor information. We include those fields in the records request so that the annual return is supported by the actual programme records. Government explanation of donor and reporting changes.

Annual reporting

FC-4 is ordinarily due within nine months of financial-year end, by 31 December. A nil return is required where the rules require annual filing even though no foreign contribution was received or used. The supporting certification and accounts requirements differ for a nil return. MHA annual-return guidance.

We prepare the annual reconciliation, supporting schedules and reporting information. Our FCRA team arranges the required professional certification, completes filing after authorised verification and responds to queries. We also prepare donor grant reports, reconciling their requested period or format to the statutory records.

Start with the proposed receipt or current gap

For an initial review, provide the organisation’s legal form, existing FCRA status, the donor’s legal description and the proposed purpose and location. At the document stage we request approval orders, donor terms, bank statements, books and programme records relevant to the assignment.

You receive a route assessment, preparation checklist, application or reporting pack, filing acknowledgements and the recorded authority outcome. Any unresolved condition is identified before receipt or reporting proceeds. Authority review, bank readiness and donor evidence affect timing.

Related services

Email TheTaxCo, message us on WhatsApp or book a call. Tell us whether you need a first approval, an existing-registration review or an annual return, and the nearest grant or reporting date.