FCRA compliance checklist: FC-4, disclosures and renewal

An FCRA-registered NGO must file an annual return on Form FC-4 by 31 December every year, put its foreign contribution accounts on its website, report changes within 45 days, and renew its registration every five years on Form FC-3C. Since 22 June 2026 it must also confirm its purposes and states on Form FC-6F within a year, and show at least ₹10 lakh of foreign contribution used in the last two financial years to renew.

Missed paperwork is behind many lost registrations: the government says nearly 20,000 were cancelled, and about 15,000 more deemed to have ceased, over the last decade. This checklist sets out every recurring duty under the Foreign Contribution (Regulation) Act, 2010 (FCRA) and its Rules, with the dates, the forms and what happens if you’re late. It is for finance staff, company secretaries and trustees of FCRA-registered organisations, and for prior-permission holders.

The compliance calendar

The annual return: Form FC-4

Rule 17 requires every organisation with registration or prior permission to file Form FC-4 online for each financial year, within nine months of its end, that is by 31 December. It goes with a balance sheet and a receipts and payments account for the foreign contribution, certified by a chartered accountant.

• Nil returns are compulsory. File FC-4 even in a year with no foreign contribution.
• Prior-permission holders file every year until the permitted money is fully used.
• Renewal depends on it. Every past return, including nil returns, is needed when you renew.

The form has grown almost every year since 2023:

A UDIN is the unique document identification number a chartered accountant generates for each certificate they sign. The 2026 form also reminds organisations that Section 3(1)(g) bars them from producing or broadcasting news or current affairs through any mass medium.

Your website

Rule 13(a) requires the organisation to put its annual foreign contribution accounts on its website. The quarterly disclosure of foreign contribution received, under the old Rule 13(b), was dropped from 1 July 2022. Missing the website rule is compoundable at ₹10,000 each time.

Reporting changes: the FC-6 forms

The 45-day limit replaced 15 days on 1 July 2022. Each form is filed online with the documents the portal lists, which were expanded in May 2025. For bank account changes, see the FCRA bank accounts.

Renewal: when, how and the ₹10 lakh test

A registration lasts five years. Apply to renew on Form FC-3C “within six months before the expiry” (Section 16(1) and Rule 12(2)). The Ministry of Home Affairs (MHA) asked, in a public notice of 30 September 2025, for applications at least four months before expiry, because many organisations were applying with less than 90 days to go. The legal window is still six months.

• If you don’t renew in time, the registration ceases at the end of the five years. You can’t receive or use foreign contribution, and you have to apply afresh.
• The MHA may inquire before renewing, to check the conditions in Section 12(4), under a power added in 2020.
• The activity test (since 22 June 2026). An organisation has undertaken “reasonable activity” only if it has used at least ₹10 lakh of foreign contribution in the last two financial years, and only foreign-funded activity counts (Rule 14A).
• What you’ll need: an NGO Darpan ID; Aadhaar verification of each member; the SBI New Delhi FCRA Account; every past annual return, including nil returns; and affidavits in the MHA’s proforma “AA”. Since May 2025 the documents also include three years’ accounts and activity reports, and affidavits about any foreign contribution received after expiry.
• The fee was ₹5,000 in the MHA’s 2022 FAQ. Check the portal for the current fee.

The MHA has at times extended, by public notice, the validity of registrations whose renewal applications were pending: one of 27 December 2024 extended them to 31 March 2025. Don’t count on an extension, and check the latest notice.

The rule doesn’t say how the MHA will treat an organisation that falls short for reasons outside its control, such as a donor’s delay. If that’s you, take advice early, and keep evidence of what happened.

Audits and records

• A chartered accountant certifies the FC-4 statements, reports any violations and, since 2025, certifies receipts and use by project and location, with a UDIN.
• The MHA can order an audit. Under Section 20, if returns are late or wrong, or it has reason to suspect a breach, it can have the books audited by an officer or body it authorises.
• Keep the records your returns rely on: separate books for foreign contribution, a register of investments, asset registers, donor and ultimate-donor records, key functionaries’ details, and activity reports with evidence.

Foreign contribution also appears in income-tax filings; see accounts and audit for NGOs.

Penalties, compounding and lost registrations

The MHA’s FAQ warns that late or missing returns can lead to a penalty, cancellation and prosecution. Many breaches can be compounded under Section 41, using the table notified on 1 July 2022, which lists 12 compoundable offences. The application costs ₹3,000 and is made online, and the amount can’t exceed the foreign contribution received. Some examples:

The government says many cancellations are administrative, such as unfiled returns or missed renewals. Our guide to suspension and cancellation explains what follows.

The year-end checklist

1. Reconcile the New Delhi FCRA Account, any other FCRA account and every utilisation account with your books.
2. Check administration against the 20% cap, and record any allowance you carry forward, with reasons.
3. Update the asset and investment registers.
4. Gather ultimate-donor details from every intermediary.
5. Get the chartered accountant’s certificates, with UDINs.
6. File FC-4 by 31 December, even if nil, and put the accounts on your website.
7. Check that every change in the year was reported on an FC-6 form within 45 days.
8. Diary your expiry date, the date six months before it and your ₹10 lakh position.
9. If you were registered before 22 June 2026 and haven’t filed FC-6F, do it well before 21 June 2027.

The Academy’s Starting an NGO course includes a full-year compliance calendar for tax, registrar and FCRA filings.