FCRA Annual Return FC-4: 31 December Deadline Guide

Every association holding an FCRA registration or prior permission has to report, once a year, how much foreign contribution it received and how it was spent. That report is the annual return in Form FC-4, filed online with the Ministry of Home Affairs (MHA). For the financial year 2025-26 (1 April 2025 to 31 March 2026), the due date is 31 December 2026.

This year's return is not a copy-paste of last year's. The FCRA Amendment Rules, 2026 (notified on 22 June 2026) expanded the form with new disclosures on donors, activities, publications and digital presence. This guide explains who must file, what goes into the return, what has changed, and the mistakes that most often cause trouble.

The Legal Basis and the Due Date

Section 18 of the Foreign Contribution (Regulation) Act, 2010 requires every person who receives foreign contribution to report it to the Central Government. Rule 17 of the FCRA Rules, 2011 prescribes how: an annual return in Form FC-4, filed electronically within nine months of the close of the financial year.

The return is filed only on the FCRA portal. Since the launch of the FCRA 2.0 portal in June 2026, login and signing are Aadhaar-based, so the chief functionary who will sign should check in advance that their Aadhaar-linked mobile number works.

Who Must File

• Every registered association, whether or not it received any foreign contribution during the year.
• Associations holding prior permission, for the years in which they received or used the permitted contribution.

The nil return

If an association received no foreign contribution and spent none during the year, it still has to file FC-4, marked as a nil return. For a nil return, the CA certificate and the accounting statements need not be attached. Skipping a nil return because "nothing happened" is one of the most common defaults. It still counts as a failure to file.

What Goes Into Form FC-4

For a year in which foreign contribution was received or used, the return broadly covers:

1. Association details: FCRA registration number, PAN, NGO Darpan ID, address and key functionaries.
2. Receipts: opening balance, foreign contribution received during the year, and interest and other income earned on it, with a donor-wise list (name, country, amount, purpose).
3. Utilisation: amounts spent on programme activities, on creating assets, and on administrative expenses, plus any closing balance.
4. Assets: movable and immovable assets acquired from foreign contribution. This disclosure has applied since the 2023 amendment to the rules.
5. Bank accounts: the designated FCRA Account at SBI, New Delhi Main Branch, and any utilisation accounts, with balances.
6. Attachments: a Chartered Accountant's certificate and the audited receipts and payments account, income and expenditure account and balance sheet for foreign contribution, maintained separately from the association's domestic accounts.

The return is then signed by the chief functionary and submitted.

What Changed for the FY 2025-26 Return

The FCRA Amendment Rules, 2026 (S.O. 3272(E), 22 June 2026) added the following to Form FC-4:

• Website and social media. The association must disclose its official website and its social media accounts.
• Ultimate donors. Where money arrives through a donor-advised fund or another intermediary, the return must now name the ultimate donor behind it, with address, email and amount. Naming only the intermediary is no longer enough.
• Detailed activity report. A detailed activity report must be attached. A new table maps each project or activity, and its location, to the foreign contribution used on it, split into programme spending, fresh assets and administrative expenses.
• Publications (new serial 8A). Publications brought out during the year by the association or its key functionaries must be listed, with the date, nature, title, place of publication and a short description. The form also reminds associations that they may not produce or broadcast news or current-affairs content.
• UDIN. The CA certificate must carry a UDIN, and the separately audited FCRA financial statements need their own UDIN.

These changes add work at the reporting stage, but most of it is information an association should already have. The project-wise table is the part that needs the most preparation, because it has to tie to the audited accounts.

Worked Example: Checking the Numbers Before Filing

Suppose a society in Kalahandi, registered under FCRA, shows the following in its foreign contribution accounts for FY 2025-26:

Before filing, the society should check three things:

1. The arithmetic ties. 2,10,000 + 20,00,000 + 30,000 − 14,50,000 − 3,20,000 − 3,60,000 = 1,10,000, which matches the closing bank balance.
2. The administrative cap. Section 8(1)(b) limits administrative expenses to 20% of the foreign contribution received in the year. Here, 3,60,000 is 18% of 20,00,000, so the society is within the limit, with not much room to spare.
3. The project table matches. The ₹14,50,000 programme spend must be broken down by project and location in the new table, and the ambulance has to appear both in the asset disclosure and under "fresh assets".

Linked Obligations Worth Checking at the Same Time

• Website disclosure. Rule 13 of the FCRA Rules expects an association with an official website to place its annual FCRA accounts on that website within nine months of the year end. Failing to do so is a compoundable offence in its own right.
• FC-6F intimation. Associations registered before 22 June 2026 must file Form FC-6F by 21 June 2027, stating the purposes and States/UTs for which they want to keep their registration. The purposes and locations reported in FC-4 should be consistent with what is chosen there.
• Renewal and "reasonable activity". Under the new Rule 14A, an association is treated as having carried out reasonable activity only if it used at least ₹10 lakh of foreign contribution in the preceding two financial years. FC-4 is where the MHA sees that utilisation, so the returns filed now feed directly into the next renewal.

Consequences of Late or Non-Filing

Failing to file FC-4, or filing it late, is a contravention of the Act. It can be compounded on payment of an amount set by the MHA under Section 41, and the amount is linked to the foreign contribution involved. Repeated or prolonged default can lead to suspension or cancellation of registration. A pending default can also hold up renewal or other applications on the portal. Filing a few weeks early is far cheaper than any of these outcomes.

Common Mistakes

• Not filing a nil return in a year with no foreign receipts.
• Mixing domestic and foreign funds: taking foreign contribution into a local account, or paying FCRA expenses from domestic funds and "adjusting" later.
• Administrative costs hidden under programme heads to stay within the 20% cap. The new project-wise table makes this easier to spot.
• Naming the intermediary instead of the ultimate donor for funds routed through donor-advised funds or pass-through organisations.
• Interest not reported as foreign contribution. Interest earned on the FCRA Account is itself foreign contribution.
• Assets missing from the asset disclosure, especially vehicles and equipment bought late in the year.
• Mismatched records: different addresses, key functionaries or figures across FC-4, the audited accounts, PAN, NGO Darpan and the website.
• Leaving it to the last week, when the portal is busy and Aadhaar or e-Sign issues have no time to be resolved.

A Practical Timeline for December 2026

• By mid-November: close the FCRA books for FY 2025-26, complete the audit and obtain the CA certificate with UDINs.
• By end-November: prepare the activity report, the project-wise table, the donor list (with ultimate donors), the publications list and the website/social media details.
• First half of December: fill in and review the return, have the chief functionary sign it, and file.
• After filing: save the acknowledgment and put the annual FCRA accounts on the website if the association has one.

This guide reflects the FCRA, 2010 and the FCRA Rules, 2011 as amended up to the FCRA Amendment Rules, 2026 (22 June 2026). The MHA revises forms, due dates and compounding amounts from time to time, and the FCRA Amendment Bill, 2026 is still pending. Confirm the current position on the FCRA portal before filing.

Related Advisory Services & Practice Guides

• Assistance with FCRA registration, renewal and annual returns for NGOs, trusts and Section 8 companies in Chhattisgarh and Odisha.
• Audits of foreign contribution accounts: trust, society and NGO audit.
• Getting into the framework: FCRA registration in 2026: eligibility, FC-3A and process.
• Income tax side of the same organisation: 12A and 80G registration and Form 10B/10BB audit reports.