FCRA Amendment Bill 2026: What NGOs Must Do Before 30 Sept 2026
The JPC on the FCRA Amendment Bill 2026 began scrutiny this week, and its Designated Authority clause could let the government take control of an NGO's foreign-funded assets if its certificate lapses. Two unrelated deadlines — FCRA renewal and Form 10B/10BB — converge on 30 September 2026, making this the week every FCRA-registered organisation must check its status.
CA Harun Raaj
Chartered Accountant · Harun Raaj & Associates
Legal basis: Foreign Contribution (Regulation) Act, 2010, Section 12 — as proposed to be amended by the Foreign Contribution (Regulation) Amendment Bill, 2026 (pending Parliamentary approval; currently under Joint Parliamentary Committee examination). Effective: ongoing (FCRA 2010 remains in force; the Amendment Bill is not yet enacted). Source: https://prsindia.org/billtrack/the-foreign-contribution-regulation-amendment-bill-2026. Last reviewed by CA Harun Raaj: September 2026.
The Joint Parliamentary Committee (JPC) on the Foreign Contribution (Regulation) Amendment Bill, 2026 held its first sitting on September 17–18, 2026. The Ministry of Home Affairs briefed the 31-member committee, chaired by BJP MP Sanjay Jaiswal, and the JPC must submit its report by the first week of the Winter Session — likely late November 2026.
This matters to every organisation registered under FCRA 2010, because the Bill proposes that a government-appointed Designated Authority will take control of an organisation's foreign-funded assets the moment its FCRA certificate lapses, is cancelled, or is not renewed. And separately, two unrelated compliance deadlines for FCRA-registered organisations both fall on 30 September 2026 — nine days from today.
What the FCRA Amendment Bill 2026 Proposes
The Bill was introduced in Lok Sabha on March 25, 2026, and amends FCRA 2010 as follows.
Designated Authority for asset control. A government-appointed Designated Authority would vest, supervise, manage and dispose of the foreign contributions and assets of any organisation that ceases to hold an FCRA certificate — whether the certificate is cancelled by government, surrendered voluntarily, or lapses because renewal was not applied for or was denied. An NGO that simply allows its registration to lapse could lose assets built from foreign contributions, without a prior judicial hearing.
No statutory appeal. The Bill provides no appeal mechanism when the central government denies FCRA renewal, and no hearing is guaranteed before denial.
No clean exit. An organisation that has accepted foreign contribution under FCRA cannot surrender its registration without losing its foreign-funded assets to the Designated Authority — it must keep renewing to retain them.
Religious character preserved. Where vested assets include a place of worship, the Designated Authority must maintain its religious character.
Penalty reduced. Maximum imprisonment for FCRA violations drops from 5 years to 1 year.
The Bill is not yet law. Every provision above is subject to JPC recommendations and Parliamentary approval — refer to the official Bill text and PRS India's tracker for the exact clause language before relying on it.
Key point: Under the pending FCRA Amendment Bill, 2026, an FCRA-registered organisation that lets its certificate lapse — even inadvertently — risks losing control of its foreign-funded assets to a government-appointed Designated Authority, with no statutory appeal against a renewal denial.
Two Deadlines Converge on 30 September 2026
FCRA registration renewal — pending FC-3C applications
MHA has been extending FCRA registration validity for organisations that filed Form FC-3C before their certificate expired and whose renewal is still pending processing. That extension expires on 30 September 2026. After this date, organisations without a valid renewed certificate will be barred from receiving or utilising foreign contributions under Section 12 of FCRA 2010. The extension applies only to organisations with a pending FC-3C application — organisations whose certificate expired without an FC-3C on file have already lost FCRA validity. As of the publication date, no MHA circular extending the 30 September 2026 deadline has been found.
Check your registration status now on the FCRA 2.0 portal at fcraonline.nic.in. If renewal is pending, confirm all outstanding documents are filed and track the application.
Form 10B/10BB audit report — AY 2026-27
Trusts and institutions registered under Section 12AB of the Income Tax Act, 1961 must file Form 10B (income exceeding ₹5 crore) or Form 10BB (income ₹5 crore or below) for AY 2026-27 by 30 September 2026. No CBDT extension circular had been issued as of September 21, 2026, despite representations from professional bodies including the Bikaner Tax Consultants Association and the Tax Bar Association, Jhalawar, seeking an extension to October 31, 2026. Without an official CBDT circular, the deadline stands. Late filing attracts a penalty of ₹200 per day under Section 234G of the Income Tax Act, 1961, capped at the total income of the trust.
Who Is Affected
The Amendment Bill, once enacted, will apply to every organisation currently holding an FCRA certificate — registered NGOs, charitable trusts and societies under the Societies Registration Act, 1860, Section 8 companies under the Companies Act, 2013 that receive foreign contributions, religious trusts and educational institutions with FCRA certificates, and research institutions and hospitals receiving foreign grants. As of July 15, 2026, India had 14,449 active FCRA certificates, alongside 22,498 cancelled and 15,212 deemed-expired registrations.
FCRA 2026 Rules Already in Force
Separate from the pending Bill, the Foreign Contribution (Regulation) Amendment Rules 2026 — notified via S.O. 3272(E) dated 22 June 2026 — are already operative:
- Rule 14A requires organisations to utilise at least ₹10 lakh in foreign contribution every six-month period, or record reasons for non-utilisation.
- Rule 9A proviso requires 75% of existing FC funds to be utilised before the next instalment of foreign contribution can be received.
- Form FC-6F (Rule 17B) must be filed by all existing FCRA-registered organisations to align their registration with the new purpose-specific activity lists, by 21 June 2027.
- The FCRA 2.0 portal at fcraonline.nic.in, launched June 30, 2026, now handles all FCRA filings.
If your organisation holds an FCRA certificate, confirm your renewal status on fcraonline.nic.in before 30 September 2026, and confirm your Form 10B/10BB filing is on track before the same date. Both are independent of the Amendment Bill and enforceable under current law today.
I'm CA Harun Raaj, Visakhapatnam. If your NGO's FCRA renewal is pending or your Form 10B/10BB filing needs review before 30 September, reach out to our team this week.
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See Also
Frequently Asked Questions
My NGO's FCRA certificate expires in December 2026. Does the Amendment Bill affect us now?
No, the FCRA Amendment Bill, 2026 is not yet law and is currently under JPC examination. Under current FCRA 2010, Form FC-3C renewal must be filed before your certificate expires; if you have not filed yet, do so promptly and track it on fcraonline.nic.in.
What happens to our foreign-funded assets if we don't renew our FCRA registration?
Under FCRA 2010 as it stands today, you cannot receive or use foreign contributions without a valid certificate, but the law does not currently set out government seizure of past assets. Under the pending Amendment Bill, foreign-funded assets would vest in a government-appointed Designated Authority if the certificate lapses, is cancelled, or renewal is denied.
Can we surrender our FCRA certificate voluntarily without losing our assets?
Yes, under current FCRA 2010 voluntary surrender does not trigger any asset-vesting consequence. Under the pending Amendment Bill, voluntary surrender would trigger vesting of foreign-funded assets in the Designated Authority, effectively locking organisations into the FCRA framework to protect their assets.
What is Form FC-6F and when must we file it?
Form FC-6F, introduced under Rule 17B of the FCRA Amendment Rules 2026, requires all existing FCRA-registered organisations to align their registration with the new purpose-specific activity lists. The deadline to file is 21 June 2027.
What is the deadline for Form 10B/10BB audit reports for AY 2026-27, and what is the penalty for missing it?
Trusts and institutions registered under Section 12AB of the Income Tax Act, 1961 must file Form 10B (income above ₹5 crore) or Form 10BB (income ₹5 crore or below) by 30 September 2026. Late filing attracts a penalty of ₹200 per day under Section 234G of the Income Tax Act, 1961, capped at the trust's total income.
Has MHA extended the 30 September 2026 FCRA renewal deadline?
As of the date this article was researched, no MHA circular extending the 30 September 2026 deadline for pending FC-3C renewal applications has been issued. Organisations should verify current status directly on the FCRA 2.0 portal at fcraonline.nic.in.
What are Rule 14A and the Rule 9A proviso under the FCRA Amendment Rules 2026?
Rule 14A requires organisations to utilise at least ₹10 lakh in foreign contribution every six-month period, or record reasons for non-utilisation. The Rule 9A proviso requires 75% of existing FC funds to be utilised before the next instalment of foreign contribution can be received. Both are notified under S.O. 3272(E) dated 22 June 2026 and are already in force.
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