Introduction: Why FCRA Registration is Critical for Modern NGOs in India
In the age of global philanthropy, foreign donations and international grants have become a lifeline for many Indian NGOs. Whether it’s a US-based donor, a European foundation, or a UN-funded initiative, foreign funds can supercharge your impact.
But here’s the catch: No NGO in India can legally receive foreign funds without registration under the FCRA – Foreign Contribution (Regulation) Act, 2010.
FCRA compliance is not optional it is mandatory, and stringently monitored by the Ministry of Home Affairs (MHA). Failing to comply can result in freezing of bank accounts, blacklisting, prosecution, and shutdown of operations.
In this detailed guide by RegistrationMART (10+ years NGO legal advisory), we’ll help you understand:
- What is FCRA and why it exists
- Who needs FCRA registration
- Eligibility criteria and process
- Common mistakes and compliance checklist
- Renewal, suspension, and cancellation rules
- How we can help you stay fully compliant
What is FCRA?
The Foreign Contribution (Regulation) Act, 2010 governs the receipt and utilization of foreign funds by individuals, associations, NGOs, and companies in India.
Objective:
To regulate foreign donations and ensure they are not used for activities that harm national interest, internal security, public interest, or sovereignty.
Why Was FCRA Introduced?
India receives billions in foreign aid annually. But unregulated inflow led to:
- Misuse of foreign donations
- Money laundering through fake NGOs
- Threat to national integrity and religious harmony
Thus, the FCRA was made to bring transparency, accountability, and national security safeguards in the process.
Who Needs FCRA Registration?
Any NGO, trust, society, Section 8 company, or institution that wants to:
- Receive donations from foreign individuals or organizations
- Apply for international grants
- Collaborate with foreign embassies, governments, or global nonprofits
Even one dollar from a foreign passport holder is treated as foreign contribution!
Types of FCRA Registration
There are two types of permissions under FCRA:
1. FCRA Registration (Permanent)
- For NGOs with 3+ years of existence
- Should have a proven record of activities
- Must have spent at least ₹15 lakhs in past 3 years for core activities (not admin)
2. FCRA Prior Permission
- For new NGOs who want to receive foreign funds for a specific project or donor
- Valid only for that particular contribution and purpose
Eligibility for FCRA Registration (Permanent)
| Criteria | Requirements |
| NGO Type | Trust / Society / Section 8 Company |
| Age | At least 3 years old |
| Activities | Genuine charitable/social |
| Past Work | ₹15+ lakh spent on projects in last 3 years |
| Bank Account | Dedicated FCRA account in SBI New Delhi Main Branch (NDMB) |
| PAN, Aadhaar | Of key functionaries |
| 12A & 80G | Recommended (for tax compliance) |
Step-by-Step Process of FCRA Registration
Step 1: Open FCRA Bank Account
- Must be in SBI – New Delhi Main Branch (NDMB)
- As per MHA guidelines since 2020
Step 2: Prepare Documents
- NGO registration certificate
- MOA/Deed
- Last 3 years’ audited financials
- Activity Report (3 years)
- Board members’ ID and Aadhaar
- CA Certificate confirming ₹15L+ spent
- NitiAayogDarpan ID
Step 3: File Online Application – Form FC-3A
- Through FCRA Online Portal
Step 4: Upload Digital Signature
- Of Chief Functionary (President/CEO/Secretary)
Step 5: Pay Fees
- ₹5,000 online
Step 6: Review by MHA
- Physical inspection may occur
- Field intelligence may verify ground work
Step 7: Approval or Rejection
- If approved: Registration certificate valid for 5 years
- If rejected: Can reapply after addressing reasons
📌RegistrationMART helps prepare every document and coordinate with the Ministry.
What is Foreign Contribution?
Includes:
- Any donation, currency, article or securities received from a foreign source
- Includes grants, gifts, funding, services in kind, and even software licenses
Sources considered foreign:
- Individuals of foreign nationality or NRI
- Foreign companies or their Indian subsidiaries
- Embassies, foreign governments
- International NGOs, foundations (e.g., Gates Foundation, UN, etc.)
What is Not Allowed Without FCRA?
Without valid FCRA registration or permission:
🚫 Cannot receive foreign donations
🚫 Cannot use foreign currency even for free services
🚫 Cannot use funds via foreign collaborative programs
Violation can lead to:
- Suspension of operations
- Freezing of bank accounts
- Investigation by CBI / Enforcement Directorate
- Criminal prosecution
Renewal of FCRA Registration
- FCRA registration is valid for 5 years
- Must apply for renewal at least 6 months before expiry
- Late renewal can lead to automatic cancellation
Form for Renewal: FC-3C
Fees: ₹5,000
Documents: Fresh financials, activity report, board member details
Changing Details After Registration
You must inform MHA within 15 days if:
- Board members change
- Address of NGO changes
- Bank details change
- New foreign projects are added
Use Form FC-6 for:
- FC-6A: Change in name/address
- FC-6B: Change in nature
- FC-6C: Change in bank
- FC-6D: Change in key persons
- FC-6E: Change in office bearers
Common Mistakes That Lead to Rejection
| Mistake | Impact |
| Incomplete documents | Rejection |
| Mismatch in director details | Delay or rejection |
| Not spending ₹15L in 3 years | Ineligible |
| Fake projects or activities | Permanent blacklisting |
| Receiving foreign funds without FCRA | Criminal charges |
| Late renewal | Cancellation |
Tip: Use experienced consultants like RegistrationMART to avoid these costly mistakes.
FCRA Annual Compliance Requirements
Every NGO with FCRA registration must:
- Maintain separate FCRA books
- File FC-4 (Annual Return) by 31st December every year
- Upload:
- Audited FCRA financials
- Project-wise donor report
- Utilization report
🔹Must also update on NGO-Darpan Portal annually.
Non-compliance = Fines + Suspension
Suspension or Cancellation of FCRA License
Reasons may include:
- Misuse of foreign funds
- Anti-national activities
- Not filing annual returns
- Using funds for personal or political use
🔹Suspended NGOs cannot receive any foreign fund until restored.
FCRA licenses of over 6,000 NGOs were cancelled in India between 2016–2024 due to non-compliance.
Global Donors Prefer FCRA-Compliant NGOs
Top foreign funding agencies such as:
- Bill & Melinda Gates Foundation
- Ford Foundation
- WHO, UNICEF, UNDP
- USAID, DFID, EU programs
- Corporate CSR wings (IBM, Microsoft, Google)
✅Only donate to FCRA-compliant NGOs
✅ Require FC-4 returns for audit
✅ Check registration on FCRA Portal
How RegistrationMART Helps
With 10+ years of experience in NGO compliance, we offer:
✅ End-to-end FCRA registration
✅ Assistance in opening SBI-NDMB account
✅ Drafting and auditing reports
✅ Filing FC-3A, FC-6, FC-4 forms
✅ Renewal reminders
✅ Annual compliance and advisory
✅ FCRA correction and legal reply support
We’ve helped 200+ NGOs secure FCRA status and retain global donors.
Conclusion: Go Global, But Go Legally
Foreign funding can be a game changer for your NGO. But only if you:
- Choose the right legal structure
- Register under FCRA
- Stay compliant every year
Let RegistrationMART be your legal partner in building a compliant, credible, and scalable NGO that not only attracts international support but also withstands the scrutiny of Indian regulatory authorities.
