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FCRA Registration Services in India – FCRA 2010 Foreign Contribution Approval, FC-3A Registration, FC-3B Prior Permission, SBI Main Branch Designated Account Setup & FC-4 Annual Return Compliance Advisory
FCRA Registration under the Foreign Contribution (Regulation) Act, 2010 (FCRA 2010) read with the Foreign Contribution (Regulation) Rules, 2011 is the mandatory regulatory licence issued by the Ministry of Home Affairs (MHA), Government of India for any Indian charitable trust, society, or Section 8 company seeking to receive, accept, or utilise foreign contribution for definite cultural, economic, educational, religious, or social programmes. Without FCRA approval, no Indian non-profit can lawfully receive a single rupee from a foreign donor — whether an individual, foreign corporation, multilateral agency, foundation, or international NGO. Receiving foreign contribution without registration is a serious offence under Sec 35 / 37 / 41 of FCRA 2010, attracting heavy penalties, prosecution, asset freezing, and disqualification of office bearers.
The FCRA framework operates through two routes — Form FC-3A for full FCRA Registration (5-year licence for organisations with at least 3 years of existence and ₹15 lakh of social-program activity in the preceding 3 years), and Form FC-3B for Prior Permission (project-specific approval for a defined foreign donor and a defined activity, typically used by newer organisations). All foreign contribution must be received only in the dedicated FCRA Designated Bank Account at State Bank of India, New Delhi Main Branch (NDMB), mandated since the FCRA Amendment Act 2020. Our FCRA registration consultancy services provide end-to-end MHA approval support — eligibility diagnostic, FC-3A / FC-3B drafting, online filing on the FCRA portal, SBI NDMB account opening, FC-4 annual returns, FC-6 changes (Rule 17A), 5-year renewal under Sec 16, response to MHA show-cause notices, and post-suspension / cancellation defence. We also handle FCRA-FEMA-PMLA-IT Act interplay for organisations with Sec 12AB / 80G / CSR-implementer status.
FCRA 2010
Governing Act
FC-3A / FC-3B
Registration / Prior Permission
3-Year + ₹15 Lakh
Eligibility for FC-3A
SBI NDMB
Mandatory Designated Account
Frameworks & Provisions We Work Under
FCRA 2010
FCRR 2011
FCRA Amendment 2020
Sec 11 – Registration
Sec 12 – Prior Permission
Sec 16 – Renewal
Sec 17 – SBI NDMB
Sec 8(1) – 20% Admin Cap
Sec 7 – No Sub-Granting
Form FC-3A / 3B / 3C
Form FC-4 – Annual Return
Form FC-6 – Changes
Rule 17A Intimation
FCRA Registration Use Cases We Handle
FC-3A
FCRA Full Registration
Established trusts / societies / Sec 8 companies with 3+ years' existence and ₹15 lakh of activity — Form FC-3A application, MHA scrutiny, and 5-year FCRA registration.
- 3-year track record
- ₹15 lakh activity test
- Form FC-3A filing
- MHA scrutiny defence
- SBI NDMB account
- 5-year licence
FC-3B
Prior Permission (Project-Based)
Newer organisations or specific project-based foreign funding — Form FC-3B prior permission for a defined foreign donor and defined activity, valid for the project lifecycle.
- Donor-specific approval
- Activity-specific approval
- Donor commitment letter
- Project budget upload
- SBI NDMB linkage
- Project-cycle validity
5-Year Renewal
FCRA Renewal under Sec 16
Existing FCRA-registered entities approaching 5-year expiry — Sec 16 renewal application 6 months before expiry, activity-evidence pack, and FC-3C portal filing.
- 6-month-before window
- Form FC-3C renewal
- 5-year activity evidence
- FC-4 history pack
- Bank statement audit
- Fresh 5-year licence
CSR-Aligned
CSR & Foreign Donor
NGOs working with corporate CSR funding from MNCs & foreign donors — FCRA + Sec 12AB + Sec 80G + Form CSR-1 stack, dual fund-flow protection, and donor-side reporting.
- Sec 12AB + 80G + CSR-1 combo
- Donor MNC alignment
- Sub-granting restriction
- Dual fund-flow setup
- Impact reporting
- Donor due diligence pack
FC-6 Changes
Rule 17A Change Intimation
Intimation of changes in name, address, key office bearers, or aims and objects within 15 days under Rule 17A — FC-6 series form filings on the FCRA portal.
- FC-6A — KMP / office bearers
- FC-6B — bank account
- FC-6C — registered address
- FC-6D — name change
- FC-6E — aims / objects
- 15-day timeline
Notice / Crisis
Suspension / Cancellation Defence
Defence against MHA show-cause for FCRA suspension under Sec 13 or cancellation under Sec 14 — strategy, written submission, hearing representation, and writ remedy.
- Show-cause analysis
- Sec 13 / 14 defence
- Written submission
- MHA hearing
- Writ remedy strategy
- Restoration application
Key FCRA Concepts You Must Know
Sec 2(1)(h)
Foreign Contribution Defined
Donation, delivery or transfer of any article, currency, or security from a foreign source — includes gifts, grants, sponsorships, in-kind donations, and even some Indian-currency receipts traceable to a foreign source.
Currency / Article
Foreign Source
Sec 11
Registration Requirement
No person (registered as a society / Sec 8 / trust / company) can accept any foreign contribution without (a) FCRA Registration under Sec 11(1), or (b) Prior Permission under Sec 11(2).
Registration
Prior Permission
Sec 17
SBI NDMB Mandate
Every FCRA-registered entity must receive foreign contribution only in the FCRA Designated Account at State Bank of India, New Delhi Main Branch (NDMB) — strict, no exceptions.
SBI NDMB
Single Account
Sec 8(1)
20% Administrative Cap
Administrative expenses cannot exceed 20% of foreign contribution received in a financial year — narrowed from 50% by the FCRA Amendment Act 2020.
20% Cap
Programme Spend
Sec 7
No Sub-Granting
FCRA Amendment 2020 prohibits transferring foreign contribution to any other person / NGO, even if such other person is FCRA-registered — funds must be utilised by the recipient only.
No Sub-Grant
Direct Use
Sec 16
5-Year Renewal Cycle
FCRA registration is valid for 5 years; renewal application must be filed at least 6 months before expiry in Form FC-3C — failure to renew leads to expiry and ban on receiving fresh foreign contribution.
5-Year Validity
6-Month Window
FC-4 Annual
Annual Return Filing
Mandatory annual return in Form FC-4 within 9 months from FY-end (i.e., by 31 December for FY ending 31 March) — donor-wise, project-wise, with receipts & payments and audited financials.
31 December
Donor-Wise
Sec 13 / 14
Suspension & Cancellation
MHA can suspend an FCRA registration for up to 360 days under Sec 13 pending inquiry; cancel under Sec 14 on findings — both are reasoned, hearing-based, and writ-amenable.
360-Day Suspension
Reasoned Cancel
Our FCRA Registration & Compliance Services
FCRA Eligibility Diagnostic
Diagnostic of 3-year track record, ₹15 lakh activity test, governance, financial discipline, Sec 12AB / 80G interplay, and FC-3A vs FC-3B route recommendation.
Form FC-3A Registration Filing
End-to-end Form FC-3A drafting and online filing on FCRA portal — activity report, 3-year financials, board details, and supporting affidavits till 5-year licence issuance.
Form FC-3B Prior Permission
Project-based prior permission filing — donor commitment letter, project budget, activity description, and timeline with MHA scrutiny and approval follow-up.
SBI NDMB Account Setup
State Bank of India, New Delhi Main Branch FCRA designated account opening, KYC pack, board resolution, signatories, and integration with FCRA portal.
FCRA Utilisation Account Setup
FCRA utilisation account at any scheduled bank for downstream programme spending — tagging, fund-flow controls, and FC-4 reporting integration.
FC-4 Annual Return
Annual FC-4 return filing — donor-wise breakup, activity-wise utilisation, audited receipts & payments, balance sheet, and CA audit certificate.
FC-6 Rule 17A Intimation
Intimation of changes (KMP, address, name, bank, aims) within 15 days through FC-6A / 6B / 6C / 6D / 6E forms; pre-acceptance for object changes.
FCRA Renewal (Form FC-3C)
5-year renewal application 6 months before expiry — fresh activity report, 5-year fund-flow, FC-4 history, audit reports, and MHA follow-up till renewal order.
FCRA-PMLA Compliance Framework
Anti-money laundering checks, donor KYC framework, suspicious-transaction trigger map, and PMLA-aligned governance for high-value FCRA recipients.
Suspension / Cancellation Defence
Defence in Sec 13 suspension or Sec 14 cancellation proceedings — written submissions, MHA hearing, restoration application, and High Court writ remedy.
FCRA Audit & CA Certification
FCRA-specific audit by Chartered Accountant — receipts & payments, donor-wise reconciliation, 20% admin-cap testing, asset register, and Form FC-4 sign-off.
Trust Demerger / Conversion FCRA
FCRA impact handling on trust demerger, Sec 8 conversion, M&A — fresh registration application for resulting entity (no carry-over) and project-bridge planning.
When You Need FCRA Registration Support
First Foreign Donor Lined Up
Foreign foundation / multilateral / MNC CSR offering grant — without FCRA registration or prior permission, the funds cannot be received in India.
Approaching 3-Year Existence
NGO crossing the 3-year activity threshold and ₹15 lakh of social-program spend — eligible for full Sec 11(1) registration via Form FC-3A.
FCRA Renewal Approaching
Existing 5-year FCRA validity approaching expiry — renewal application must be filed at least 6 months before the expiry date to avoid lapse.
FC-4 Filing Pending
Annual FC-4 not filed by 31 December — non-filing attracts late fee, impacts renewal eligibility, and triggers MHA scrutiny.
Trust Deed / Object Change
Amendment to objects, name, address, or KMP — Rule 17A 15-day intimation in FC-6 series; object change requires pre-acceptance from MHA.
MHA Show-Cause Notice
Notice for FCRA violation — Sec 8(1) admin cap breach, Sec 7 sub-granting allegation, Sec 17 non-NDMB receipt, or governance lapse — defence pack and hearing.
Suspension / Freeze
FCRA suspended under Sec 13 — bank account frozen, fund flow halted — strategic response, MHA representation, and writ remedy where required.
Trust Demerger / Restructuring
Trust demerger or Sec 8 conversion impacts FCRA — registration is non-transferable; resulting entity needs fresh FCRA registration.
Documents Needed for FCRA Registration
Constitutional & Governance
- Trust deed / MOA & AOA / society bye-laws
- Registration certificate of the entity
- PAN of the entity
- Sec 12AB & 80G orders
- Trustee / director / KMP list
- KMP KYC (PAN, Aadhaar, photo)
- Affidavit of founding members
Activity & Financial
- 3-year activity report
- 3-year audited financials
- 3-year ITR-7
- Form 10B / 10BB audit
- Project / programme list
- Beneficiary & reach data
- Photographs / impact reports
Banking & Donor
- Existing bank account details
- SBI NDMB account opening pack
- Utilisation account details
- Donor commitment letter (FC-3B)
- Project-specific budget
- Foreign source profile
- Past foreign-grant evidence (if any)
Our FCRA Engagement Process
1
Diagnostic & Strategy
Eligibility diagnostic — 3-year activity test, governance review, Sec 12AB / 80G alignment, donor profile, and FC-3A vs FC-3B route recommendation.
2
Document Pack Build
Activity report curation, financial pack, KMP KYC, board resolutions, donor letters, and SBI NDMB account opening preparation.
3
FCRA Portal Filing
Online Form FC-3A / FC-3B filing on FCRA portal, supporting affidavits, fee payment, and ARN tracking till MHA queries.
4
MHA Follow-Up
Response to MHA queries, additional submissions, hearing where required, and follow-through till FCRA registration / prior permission order.
5
Post-Registration Compliance
FC-4 annual returns, FC-6 changes, 20% admin-cap monitoring, donor-wise reporting, and 5-year renewal calendar.
Why Choose Us for FCRA Registration
✓
FCRA 2010 specialists
✓
FC-3A & FC-3B expertise
✓
SBI NDMB account setup
✓
FC-4 annual return filing
✓
Rule 17A FC-6 intimations
✓
Sec 16 5-year renewal
✓
Suspension / cancellation defence
✓
FCRA + Sec 12AB + CSR-1 stack
FAQs on FCRA Registration
What is FCRA Registration and who needs it?
FCRA Registration is the regulatory licence issued by the Ministry of Home Affairs (MHA) under the Foreign Contribution (Regulation) Act, 2010 read with the FCRR 2011, authorising an Indian non-profit (society, trust, or Section 8 company) to receive foreign contribution for cultural, economic, educational, religious, or social programmes. Any Indian entity intending to receive funds from a foreign source — foreign individual, foreign company, foreign foundation, multilateral agency, or international NGO — must hold either: (a) FCRA Registration under Sec 11(1) (Form FC-3A, 5-year validity), or (b) Prior Permission under Sec 11(2) (Form FC-3B, project-specific). Receiving foreign funds without FCRA approval is a serious offence under Sec 35 / 37 / 41 with penalties, prosecution, and asset freezing.
What is the difference between FCRA Registration and Prior Permission?
FCRA Registration (Form FC-3A) is the full-scope licence valid for 5 years, available to organisations with at least 3 years of existence, demonstrable charitable activities, and cumulative spend of at least ₹15 lakh on social programs in the preceding 3 years (excluding admin expenses and cost of land / building) — once granted, the entity can receive foreign contribution from any approved foreign donor. Prior Permission (Form FC-3B) is a project-specific, donor-specific approval — typically used by newer organisations that don't yet meet the FC-3A eligibility, where a specific foreign donor has committed funds for a specific activity. Prior Permission is granted for the specific donor and specific amount only.
Is the SBI New Delhi Main Branch FCRA account mandatory?
Yes — under Section 17 of FCRA 2010, as substituted by the FCRA Amendment Act 2020, every FCRA-registered entity must receive foreign contribution only in the FCRA Designated Bank Account opened at the State Bank of India, New Delhi Main Branch (SBI NDMB) — this is a mandatory, single-branch requirement applicable to every FCRA recipient across India. The entity may additionally open a "FCRA Utilisation Account" at any scheduled bank for downstream programme spending after the funds are routed through SBI NDMB. Receiving foreign contribution in any account other than SBI NDMB is a serious violation that can lead to suspension, cancellation, and prosecution.
What is the 20% administrative expense cap under FCRA?
Under Section 8(1) of FCRA 2010, narrowed by the FCRA Amendment Act 2020 from the earlier 50% limit, an FCRA-registered entity cannot spend more than 20% of foreign contribution received in a financial year on administrative expenses. Administrative expenses are defined under Rule 5 of FCRR 2011 and include salaries / wages of administrative staff (not field staff), office rent, electricity, telephone, vehicle running, conveyance, office equipment, audit and legal fees not directly related to programme activity, and similar overheads. Programme expenses directly attributable to the charitable activity (field salaries, beneficiary cost, training cost) are not counted in the 20% — they fall in the 80% mandatory programme spend bucket.
Can FCRA-registered entities transfer foreign contribution to other NGOs?
No — the FCRA Amendment Act 2020 amended Section 7 to expressly prohibit transfer of foreign contribution from one FCRA-registered entity to any other person / NGO, even if the other entity is itself FCRA-registered. This was a major change that ended the prior model of "intermediate / lead NGOs" sub-granting to smaller field organisations. Today, every NGO that wants to use foreign funds for its activities must hold its own FCRA registration and receive funds directly from the foreign donor. The recipient must utilise the funds itself and cannot pass them on. This has materially restructured the Indian non-profit funding ecosystem and increased compliance overhead.
When is FC-4 annual return due and what does it cover?
Form FC-4 is the mandatory annual return for every FCRA-registered entity (whether or not foreign funds were received in the year). It must be filed online on the FCRA portal within 9 months from the end of the financial year — i.e., by 31 December for the financial year ending 31 March. FC-4 covers: (a) donor-wise foreign contribution received; (b) activity-wise / project-wise utilisation; (c) opening and closing balance of FCRA bank accounts; (d) certified receipts & payments account, balance sheet, and statement of expenditure; (e) audit report by a Chartered Accountant. Late filing attracts a fee, and non-filing impacts FCRA renewal eligibility and triggers MHA scrutiny.
What happens when FCRA registration is suspended or cancelled?
Under Section 13, the MHA can suspend an FCRA registration for an initial period of up to 180 days, extendable by another 180 days (total 360 days), pending an inquiry into alleged violations. During suspension, the entity cannot utilise existing funds without specific MHA approval, and cannot receive new foreign contribution. Under Section 14, the MHA can cancel the registration after a reasoned inquiry on grounds such as obtaining registration through fraud, violation of FCRA / FCRR provisions, public-interest concerns, etc. Cancellation forbids the entity from applying afresh for 3 years. Both suspension and cancellation orders are amenable to writ proceedings before the High Court under Article 226. Strong written representation, hearing strategy, and (where needed) writ remedy are critical.
FCRA Approval Secured. Foreign Funding Compliant. Donor Confidence Built.
Partner with our FCRA specialists for end-to-end FC-3A registration, FC-3B prior permission, SBI NDMB account setup, FC-4 annual returns, FC-6 changes, 5-year renewals, and MHA suspension / cancellation defence for FY 2026–27.
Talk to an FCRA Registration Expert