1. The term ‘key functionary’ is now broader: it covers directors, partners, trustees, ‘Kartas’ of Hindu undivided families, office bearers, governing/management committee members, and anyone else exercising control over the organisation. Foreign nationals not of Indian origin will ordinarily not be eligible to hold this role unless specifically approved by the competent authority. Organisations should review their governing body and authorised signatories against this wider definition.
2. State/UT-specific registration FCRA applications must now specify the purpose from five broad heads — social, economic, educational, cultural, religious — each with its own list of permissible sub-activities in the Schedule, as well as the States/UTs where the contribution will be utilised. A general label like ‘social’ or ‘educational’ is no longer sufficient on its own.
3. An association is deemed to have undertaken ‘reasonable activity’ required for renewal only if it has utilised at least ₹10 lakh of foreign contribution over the preceding two financial years for the stated purpose. Organisations with low or no utilisation should review their renewal position early.
4. Where funds are released in instalments under prior permission, the second and subsequent instalments are released only after 75% of the previous instalment has been utilised and verified through field inquiry.
5. The annual return now requires:
6. Auditor certification, including for the separate FCRA-specific financials, must now carry a Unique Document Identification Number (UDIN).
Here’s a checklist for immediate action:
Important note: Don’t confuse this with the pending Bill
A separate Foreign Contribution (Regulation) Amendment Bill, 2026, introduced in the Lok Sabha on 25 March 2026, deals with vesting and disposal of assets when an FCRA certificate is cancelled, surrendered, or lapses without renewal. That Bill is still under consideration in Parliament and is not yet operational. Rules above, however, are currently in force.
This note is for internal awareness and planning. Verify final filing requirements against the official Gazette notification, prescribed forms, and your FCRA consultant or legal adviser before submission.
Shanthi Lakshmanan is a results-oriented leader with over three decades of experience in finance, operations, compliance, and social impact. Transitioning to the social sector a decade ago, she founded ExempServ, which supports boards, trustees, and leadership teams in this sector with financial reporting, compliance, and allied services to enhance their effectiveness and impact.
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