Donor PAN missing for Form 10BD - what to do

It's the last week of May. You're closing Form 10BD for the prior FY. The CSV lists 180 donors. Six of them gave above ₹2,000 - but you don't have their PAN. Reporting them blank rejects the row. Skipping them denies the donor's 80G claim. Here's the legal landscape, the practical options, and the workflow that actually works.

Why this happens

10BD rules require PAN for every donor whose aggregate donations in the FY crossed ₹2,000. PANs are typically missing in three operational situations:

1. Cash-counter donations at religious institutions, walk-in events, or fundraising melas. The donor handed over money, took a paper receipt, and walked away - no PAN ever captured.
2. Online donations from before you required PAN capture. Your form changed in October; donations from April-September are PAN-less.
3. Donor refused to share PAN. They donated knowing they wouldn't claim 80G. Now the FY is closing and you have to decide what to file.

The legal framework

Rule 18AB of the Income-Tax Rules requires every 12A/80G-approved donee to file Form 10BD. The form mandates PAN for every donor with FY-aggregate donations ≥ ₹2,000. The IT portal rejects rows submitted without a valid PAN (or with PAN/name mismatches caught by NSDL validation).

Cash donations above ₹2,000 are not 80G-eligible at all under §80G(5D), so cash above the limit doesn't go in 10BD regardless. Only digital donations (UPI / card / netbanking / cheque) above ₹2,000 trigger the PAN requirement.

Option 1 - Get the PAN now

The cleanest fix. Most donors will share PAN when you explain that not sharing means they can't claim deduction. Outreach script that works:

Send via WhatsApp first (highest open rate), email if no reply in 48 hours, phone call if no reply in 5 days. PAN format: 5 letters + 4 digits + 1 letter (e.g., ABCDE1234F). Validate before saving - Donateazy auto-runs PAN-name validation against the IT portal API on save.

Option 2 - Treat as anonymous donation

If the donor genuinely won't share PAN, the legal options are:

1. Don't report in 10BD. Skip the row entirely. The donor cannot claim 80G. You're still compliant.
2. Anonymous-donation tax. Under §115BBC, anonymous donations to a charitable trust above ₹1 lakh aggregate (or 5% of total receipts, whichever is higher) are taxed at 30%. Below that threshold there's no tax. Most NGOs sit comfortably below the threshold.
3. Refund the donation if the donor specifically wanted 80G but won't share PAN. Awkward but legal - refund and ask them to redonate with PAN if they change their mind.

Religious / charitable trusts that receive cash at the temple/mosque/church entrance are explicitly handled by §115BBC's 5%-or-₹1L threshold. The rule was designed for exactly this scenario.

Option 3 - Use a verified surrogate ID (limited cases)

If the donor is an entity (company, trust, society) and doesn't have a PAN on file with you but has TAN, GSTIN, or CIN, you can sometimes use the entity's registered PAN obtained from MCA / GSTN public records. Caveat: only use this when you can verify the entity is the actual donor (e.g., bank credit shows the entity name). Don't guess.

Option 4 - Filing the rejection

This is the "do nothing" option. You don't get the PAN, you skip the donor in 10BD, you note the situation in your internal records. The donor doesn't get a 10BE. The donor's 80G claim, if they attempt one, gets rejected at AIS reconciliation (see our AIS reconciliation guide).

The NGO is compliant. The donor is unhappy. This is the worst-case acceptable outcome and is what most NGOs end up doing for 1-2% of donors.

The recommended workflow

1. By 1 May: Run a "missing PAN" report. Donateazy auto-generates this - lists every donor with FY-aggregate ≥ ₹2,000 and no PAN on file.
2. 1-15 May: First outreach wave - WhatsApp + email. Use the script above. Track replies.
3. 15-25 May: Second outreach wave - phone calls to non-responders. Higher-touch but higher-conversion.
4. 25-30 May: Final reconciliation. Donors who responded: PAN added, validated, included in 10BD. Donors who didn't respond: marked "anonymous-no-claim" and excluded from 10BD.
5. By 31 May: File 10BD with the donors who provided PAN. Generate 10BE certificates after the IT-portal ack lands (typically 1-3 working days).
6. Post-filing: Email the excluded donors to confirm they cannot claim 80G this FY and to invite PAN sharing for next year.

What to do for next year (preventive)

1. Mandatory PAN field above ₹2,000. Donateazy's donation form requires PAN above the 80G-eligible threshold. Without PAN, the donation is recorded but flagged as "10BD-not-eligible".
2. PAN-name validation at capture time. Hit the IT portal's PAN-name verification endpoint at the moment of submission. Reject PAN/name mismatches at capture, not at filing.
3. Real-time PAN reminder. If a donor donates anonymously, email them within 24 hours with: "Your donation receipt is ready. To claim 80G tax deduction, please share your PAN here: [link]." Most donors comply within a week.
4. Mid-year missing-PAN audit. Run the "missing PAN" report in October (mid-FY). 6 months is plenty of time to backfill before 10BD filing.
5. Counter-side PAN capture for cash donations. If you accept cash >₹2,000 at a fundraiser, capture PAN at the counter. Cash donations above ₹2,000 are not 80G-eligible per §80G(5D) - but capturing PAN means you can still report the donor in 10BD if the donation was actually digital and was just collected at the counter.

Frequently asked questions

If a donor's aggregate crosses ₹2,000 only in March, do we still need PAN? Yes. The threshold is FY-aggregate, not per-donation. If 4 donations of ₹600 each cross ₹2,000 by March, you need PAN for the 10BD row.

Can we file 10BD without PAN for under-₹2,000 donors? Yes - donors below ₹2,000 aggregate don't go in 10BD at all. Don't report them.

What if the donor gives PAN after we've filed 10BD? File a revised 10BD adding the donor. The revised return is accepted any time after the original filing; the IT portal stamps it as an amendment. Donateazy auto-handles revised 10BD generation.

Is Aadhaar a substitute for PAN? No. The 10BD form field is PAN-only. Don't enter Aadhaar in the PAN field; the IT portal rejects it.

What about NRI donors without Indian PAN? NRIs need an OCI/PIO + Indian PAN to claim 80G. If they don't have Indian PAN, they cannot claim deduction - don't include them in 10BD. FCRA-route donations from foreign donors don't qualify for 80G at all.

Donateazy's missing-PAN dashboard

• Real-time "missing PAN" list with FY-aggregate per donor
• One-click WhatsApp outreach with pre-filled message
• PAN format + name validation on save (against IT portal)
• Auto-aggregation per donor per FY for 10BD
• Auto-flag cash donations above ₹2,000 as 10BD-ineligible
• Auto-revise 10BD when a donor adds PAN post-filing
• Email + WhatsApp reminders to donors at T+0, T+7, T+30 after donation