FCRA + FC-4 filing - the complete walkthrough.
Annual FC-4 return due 30 June 2026. FC-3C renewal window, 20%-admin cap, designated SBI account, NRI donations - all in one place.
- What is FCRA: Foreign Contribution Regulation Act, 2010. Required for any Indian NGO accepting foreign donations.
- FC-3C: Application for renewal of FCRA registration. Filed every 5 years.
- FC-4: Annual return reporting all foreign contributions received and utilised. Due 30 June every year.
- FC-6: Quarterly reporting of foreign donations received (now folded into FC-4 in many cases).
- Designated bank: All foreign contributions MUST go through the SBI Main Branch, New Delhi designated FCRA account.
- 20% admin cap: Maximum 20% of foreign contributions can be spent on administrative expenses.
- 2026 update: The FCRA Amendment Bill 2026 introduced a dedicated authority to take charge of assets of NGOs whose FCRA is cancelled or not renewed.
FC-4 annual return - what's reported
Form FC-4 is the comprehensive annual return that every FCRA-registered NGO must file with the Ministry of Home Affairs. It reports the full year's foreign contributions and utilisation.
- Opening + closing balance in the designated FCRA account
- Each foreign donor - name, address, country, purpose, amount
- Activities / projects funded with the foreign contribution
- Administrative expenses - must not exceed 20% of total foreign receipts
- Investments made from FCRA funds (must remain in FCRA-eligible instruments)
- Auditor's report certifying the above
The designated bank account requirement
Per the 2020 FCRA Amendment, all foreign contributions must be received in a designated FCRA bank account at the State Bank of India, New Delhi Main Branch (Sansad Marg). NGOs can then transfer funds to a utilisation account at any bank in India.
Donateazy enforces this routing at the model level - when an NGO is marked FCRA-active, the bank-account configuration requires the SBI designated account to be flagged before any foreign donations can be accepted.
The 2026 Amendment Bill - what changed
On 25 March 2026, the Union Government introduced the FCRA Amendment Bill 2026 in Lok Sabha. Key changes:
- Dedicated authority empowered to take charge of assets held by NGOs whose FCRA registration is cancelled, surrendered, or not renewed
- Stricter compliance requirements during the renewal cycle
- Enhanced reporting on the use of foreign contributions
Practical impact: NGOs whose FC-3C renewal lapses now face asset-level risk, not just inability to receive new foreign donations. Renewal windows are non-negotiable.
FCRA registration - how to get one
New FCRA registration is via Form FC-3A on the MHA portal (fcraonline.nic.in). Eligibility:
- The NGO must be a registered entity (trust, society, or Section 8 company)
- Must have been in existence for at least 3 years
- Must have undertaken reasonable activity in its chosen field
- Must have spent at least ₹15 lakhs on its core activity in the last 3 years
- Must have been incorporated/registered solely for definite cultural, economic, educational, religious, or social programmes
Provisional registration (FC-3B) is available for newer NGOs but allows only project-specific foreign funding for 2 years before requiring full registration.
The FC-4 filing process - step by step
Compile your FCRA-account bank statement for the FY
Designated SBI account + any utilisation accounts that received FCRA-routed funds. Reconcile to your books.
Categorise every foreign donor
Foreign donor name, address, country, purpose of donation, amount in INR (use the RBI reference rate on the date of receipt for foreign-currency conversion).
Tag activities funded
Match each foreign contribution to the activity/project it funded. Education, health, social, economic, religious, cultural.
Calculate the 20% admin cap
Administrative expenses ÷ total foreign receipts × 100. Must be ≤ 20%. If you breached, the excess is technically disallowed.
Get the FCRA audit done
A CA must audit your FCRA books separately from your general audit. The auditor signs Section A of FC-4.
Login to fcraonline.nic.in
Use your NGO's FCRA registration credentials. Navigate to e-Filing → File New Form → FC-4.
Fill the form online
Most fields are now structured (not free-text). Upload the bank statement, donor list (CSV), and auditor's report.
DSC sign + submit
DSC of the chief functionary is mandatory. Wait for the system-generated acknowledgement.
Common FCRA mistakes and penalties
Only the SBI New Delhi designated account can receive foreign contributions. Even a one-time deposit elsewhere can lead to FCRA cancellation. Penalty: registration cancelled.
Domestic donations must not enter the FCRA account, and vice versa. Even temporary mixing leads to penalties.
Admin includes rent, salaries of admin staff, utility bills, professional fees (CA, lawyer), travel for admin purposes. Programme staff salaries are NOT admin. The disallowed portion is treated as personal expense and triggers Section 271 penalties.
Late filing penalty: up to ₹1L. Repeat default leads to FCRA cancellation. No extension is granted.
FCRA registration expires every 5 years. If you don't apply for renewal at T-6 months, you get a 1-time T-3 month grace window. After that, registration lapses and the 2026 Amendment Bill empowers MHA to take charge of your assets.
FC-4 must be on the accrual basis. Cash-basis filing has been a frequent rejection reason.
Per Section 18 of the FCRA Act, FCRA NGOs must publish receipts on their website within 15 days of receipt. Skipping this is grounds for cancellation.
FC-6 quarterly publication - the often-missed requirement
Per Section 18 of the FCRA Act, every FCRA-registered NGO must publish, on its website, every foreign contribution received within 15 days. The published page must list:
- The foreign donor's name (or anonymous if requested)
- Country of the donor
- Amount in INR
- Date of receipt
- Purpose for which it was received
Many NGOs miss this - it's a continuous, not annual, obligation. The MHA portal now flags NGOs without an up-to-date FC-6 page during routine audits. Best practice: automate this via a public webpage that's updated as donations land.
The Donateazy shortcut
For FCRA-active NGOs, Donateazy provides:
- FCRA Sentinel agent - real-time monitoring of the 20%-admin-expense cap with alerts as you approach
- FC-3C renewal window tracker - alerts at 9, 6, and 3 months before expiry
- Dual-ledger fund segregation - foreign contributions are kept separate from domestic at the database level
- FC-4 generator - assembles the annual return from your transaction history
- NRI donation routing - automatic FCRA-route enforcement when a donor is flagged as foreign-source