FCRA Registration in 2026: Eligibility, FC-3A & Process

An NGO that wants to accept a grant from an overseas foundation, a donation from a foreign well-wisher, or funding routed from a foreign source through an Indian intermediary cannot simply open its bank account to the money. Under the Foreign Contribution (Regulation) Act, 2010 (FCRA), an association must first hold either a certificate of registration or prior permission from the Ministry of Home Affairs (MHA). Receiving foreign contribution without one is an offence, whatever the purpose of the funds.

This guide covers getting into the FCRA framework: who can apply, which route fits, what the application now asks for after the FCRA Amendment Rules, 2026 (notified on 22 June 2026), and why applications commonly get rejected. What happens after registration (fund utilisation, the 20% administrative expense cap, the bar on transferring funds, annual returns) is covered in our separate guide on NGO and trust financial management and FCRA compliance.

Who Needs FCRA Registration

Any association with a definite cultural, economic, educational, religious or social programme that wants to receive foreign contribution needs FCRA clearance. In practice this means:

• Societies registered under the state Societies Registration Act (including the Chhattisgarh Societies Registration Act, 1973 and the Odisha equivalent)
• Public charitable trusts
• Section 8 companies

"Foreign contribution" is defined widely. It covers money, articles (beyond gift-value limits) and securities from a "foreign source". A foreign source includes foreign governments, foreign companies, foreign trusts and foundations, and citizens of other countries. Funds that started from a foreign source stay foreign contribution even after they pass through an Indian entity. Some persons, such as political parties, election candidates and certain media organisations, cannot accept foreign contribution at all.

Two Routes: Registration vs Prior Permission

Many organisations start with prior permission for one grant and apply for full registration once they have three years of activity behind them.

Eligibility for Registration (FC-3A)

The MHA's published FAQs set out the two core tests for registration:

1. Existence of at least three years. The association must have been registered under the relevant statute for at least three years.
2. Reasonable activity: at least ₹15 lakh spent on core objectives in the last three financial years. Administrative expenditure, as defined in Rule 5 of the FCRA Rules, 2011, does not count towards this figure. Only spending on the association's programme activities counts.

Some other conditions also apply. The association must not be a front for proselytisation or for diverting funds to political or prohibited purposes. Its key functionaries must not have been convicted or prosecuted for specified offences. Under Section 12A of the Act, the Aadhaar (or passport/OCI card for foreigners) of every office bearer, director or key functionary has to be furnished.

Worked example: checking the ₹15 lakh test

Suppose a rural education society registered in 2021 shows the following in its audited accounts:

The society meets the test, but only just. If even ₹1 lakh of salary for office staff had been booked under "programme" heads, it would fall short once the MHA reclassifies it. This is why the activity-wise split in the audited accounts matters so much.

What Changed in 2025 and 2026

The application forms have been amended twice in quick succession. Applications filed now must meet both sets of changes.

FCRA Amendment Rules, 2025 (effective 26 May 2025):

• Audited financial statements for the last three years, with activity-wise expenditure certified by a Chartered Accountant
• Year-wise activity reports for the same period
• Additional affidavits from key functionaries

FCRA Amendment Rules, 2026 (effective 22 June 2026):

• Purpose-wise registration. The applicant must choose its purposes from a new Schedule, which groups activities under five heads: Religious, Cultural, Economic, Educational and Social. Proselytisation is expressly excluded.
• State-wise area of operation. The registration certificate will name the States/UTs where the association may work.
• Fee linked to scope. The ₹10,000 registration fee now covers one purpose and one State/UT. Each additional purpose costs ₹300, and so does each additional State/UT. An NGO working on education and health in both Chhattisgarh and Odisha would pay ₹10,000 + ₹300 (second purpose) + ₹300 (second State).
• "Key functionary" defined. The term now covers trustees, directors, office bearers, governing body members, and anyone else who controls or manages the association, whatever their title.
• Foreign nationals on the board. Associations with foreign nationals (other than persons of Indian origin) as key functionaries will ordinarily not be considered for registration or prior permission.
• More disclosure in FC-3A. This includes social media accounts, FCRA utilisation account details, activities over the preceding three years, and whether the entity is government-controlled or subject to CAG audit.

Associations already registered must file an intimation in the new Form FC-6F by 21 June 2027, stating the purposes and States/UTs they want to keep.

Alongside the rules, the MHA launched the FCRA 2.0 portal on 30 June 2026. It uses Aadhaar-based login and e-Sign and is linked with PAN, NGO Darpan and ICAI's UDIN system, so mismatches between these records now surface quickly.

Step-by-Step: Applying for Registration

1. Register on NGO Darpan (NITI Aayog) and obtain a Darpan ID. The FCRA forms ask for it.
2. Align your objects with the Schedule. Check that the trust deed, memorandum or articles support the purposes you intend to select. A purpose not covered by your constitution invites a query.
3. Get the accounts in order. You need audited financial statements for three years, a CA certificate of activity-wise expenditure, and activity reports for each year.
4. Collect key functionary KYC. For every key functionary, gather Aadhaar, PAN, photographs and the prescribed affidavits and declarations.
5. Pass a governing body resolution authorising the application and the chief functionary to sign.
6. Open the FCRA Account at SBI, New Delhi Main Branch. Under Section 17, all foreign contribution must first be received only in the designated "FCRA Account" at the State Bank of India, New Delhi Main Branch (11, Sansad Marg). Separate "utilisation" accounts may be opened at other banks for spending.
7. File Form FC-3A on the FCRA portal, upload documents and pay the fee online. Check everything before submitting, because the application cannot be edited afterwards.
8. Respond to queries. The MHA will usually seek inputs from the Intelligence Bureau and the local administration, and may raise queries online. Answer them within the time allowed.

The Act expects the government to decide ordinarily within 90 days. In practice, field verification often takes longer, so plan funding timelines with a margin.

Validity and Renewal

A certificate of registration is valid for five years. Renewal is sought in Form FC-3C, which should be filed at least six months before expiry. The MHA has repeatedly warned that late filers risk a gap in validity.

The 2026 rules add Rule 14A. An association is now deemed to have carried out "reasonable activity" only if it has utilised at least ₹10 lakh of foreign contribution in the preceding two financial years. Only activity funded by foreign contribution counts. An association that falls below this level risks cancellation, so a registration held "just in case" with no foreign funding used is now exposed.

A separate FCRA Amendment Bill, 2026 proposes, among other things, that registration should cease automatically if renewal is not completed before expiry. As of this writing it is with a Joint Parliamentary Committee and is not yet law.

Prior Permission: When FC-3B Is the Better Fit

If your organisation is less than three years old, or a single foreign donor has offered a single grant, prior permission is the practical route. The application needs:

• A commitment letter from the foreign donor stating the amount and purpose
• A project report with a detailed breakup of proposed expenditure
• Details of any common members between the donor and your organisation

Prior permission is granted for that specific donor, amount and purpose only. Where the approved grant exceeds ₹1 crore and is released in instalments, each later instalment now needs a separate application in the new Form FC-3BB. Release requires at least 75% of the previous instalment to be utilised, backed by a CA certificate and a field inquiry.

Common Reasons Applications Are Rejected

• Applying before the track record exists: less than three full years of existence, or programme spending under ₹15 lakh once administrative costs are removed.
• Administrative costs shown as programme expenditure: salaries, rent and office costs booked under project heads.
• Objects that don't match the purposes chosen: for example, a trust deed limited to education with an application covering health and livelihood.
• Incomplete key functionary KYC: a missing Aadhaar or affidavit for even one trustee or governing body member.
• Foreign nationals (other than persons of Indian origin) among key functionaries, now expressly a ground for ordinarily not considering the application.
• Inconsistencies across records: for example, different addresses, office bearers or financial figures across the trust deed, PAN, NGO Darpan, audited accounts and the application.
• Vague activity reports with no beneficiary numbers, locations or photographs to show that work was actually done.
• Adverse field or intelligence report, often triggered by links to entities whose registration has been cancelled.

Before You Apply

FCRA registration is not a one-time formality. The certificate now names your purposes and your States of operation, your annual return in Form FC-4 asks for activity reports and publications, and renewal depends on actually using foreign funds. Read the application as a five-year commitment. The organisations that move through the process most smoothly usually spend the year before filing tidying their accounts and making sure their governing documents, PAN, Darpan and bank records all match.

The figures, forms and dates in this guide reflect the FCRA, 2010 and the FCRA Rules, 2011 as amended up to the FCRA Amendment Rules, 2026 (22 June 2026). The MHA revises forms, fees and procedures frequently, and the FCRA Amendment Bill, 2026 is pending. Confirm the current position on the FCRA portal before filing.

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Related Advisory Services & Practice Guides

• Assistance with FCRA registration, prior permission and renewal for NGOs, trusts and Section 8 companies in Chhattisgarh and Odisha.
• Post-registration obligations: NGO and trust financial management and FCRA compliance.
• Income tax exemption for the same organisation: 12A and 80G registration.
• Setting up the entity first: society registration, trust registration and Section 8 company registration.