RNPO Under Income Tax Act 2025: What 12A/12AB Holders Must Know
Charitable trusts, NGOs, and Section 8 companies registered under Section 12A/12AB now fall under the Registered Non-Profit Organisation (RNPO) framework in Chapter XVII of the Income-tax Act, 2025. Existing certificates stay valid and exemption continues uninterrupted, but audit report forms and filing deadlines differ between AY 2026-27 and Tax Year 2026-27.
CA Harun Raaj
Chartered Accountant · Harun Raaj & Associates
Legal basis: Income-tax Act, 2025, Chapter XVII (Sections 332–355) — Registered Non-Profit Organisations — Effective: 1 April 2026. Source: incometaxindia.gov.in. Last reviewed by CA Harun Raaj: September 2026.
What changed: Section 12AB gives way to Chapter XVII
The Income-tax Act, 2025 came into force on 1 April 2026, replacing the Income-tax Act, 1961 for Tax Year 2026-27 (Financial Year 2026-27) onward. Charitable trusts, NGOs, Section 8 companies, and educational institutions that held registration under Sections 12A, 12AA, or 12AB of the 1961 Act now operate under a new label — Registered Non-Profit Organisation (RNPO) — defined in Chapter XVII, Sections 332 to 355 of the new Act.
The provisions that used to sit under Section 12A/12AB (registration), Section 11 (85% application of income), Section 13 (denial of exemption), and Section 10(23C) (education and hospitals) are now consolidated into this single chapter. Here is how the old and new provisions map:
For Assessment Year 2026-27 (Financial Year 2025-26), you still file under the 1961 Act's forms — Form 10B or Form 10BB, ITR-7, Form 10BD, Form 10BE. The Form 112 audit report and other new RNPO forms apply only from Tax Year 2026-27 onward.
Who counts as a Registered Non-Profit Organisation
Under Section 332 of the ITA 2025, an RNPO is any trust, institution, society, or body of persons established for charitable purposes as defined under the new Act — the equivalent of Section 2(15) of the 1961 Act, including its proviso on trade and commerce activities — and either registered afresh under Section 332 or automatically carried over from a valid 1961 Act registration. The core exemption tests are unchanged: 85% application of income to charitable purposes, corpus donation treatment, restrictions on private benefit (the old Section 13 territory), and anonymous donation provisions (the old Section 115BBC territory).
Your existing registration: what happens automatically
If your organisation held a valid, uncancelled registration under Section 12A, 12AA, or 12AB as of 31 March 2026, you are treated as an RNPO from 1 April 2026 without any action on your part:
- No fresh application is required immediately — your certificate continues for the balance of its originally granted validity period.
- A certificate that still references "Section 12AB" is not invalid — the section number simply predates the relabeling.
- CBDT has not yet notified the migration or revalidation form for RNPO status — do not file anything new until it does.
- Your exemption on charitable income continues without interruption, subject to the Chapter XVII conditions.
Validity periods under the new framework carry over the same structure as before, with one addition for smaller organisations:
Key point: A trust with a valid, uncancelled 12A/12AB registration as of 31 March 2026 becomes an RNPO automatically on 1 April 2026, with its exemption continuing uninterrupted and no fresh filing required until CBDT notifies the migration form.
Illustrative example
A Pune-based charitable trust registered under Section 12AB in October 2022 for a 5-year period (expiring October 2027) runs free coaching classes for Class 10 and 12 students, with annual receipts of ₹35 lakh. From 1 April 2026, it is automatically treated as an RNPO under Section 332 of the ITA 2025, and its certificate stays valid until October 2027 with no new form required now. For AY 2026-27 (FY 2025-26), it still files ITR-7 and Form 10BB under the 1961 Act — due 30 September 2026 (audit) and 31 October 2026 (return). From Tax Year 2026-27, it moves to Form 112, the new NPO audit report under Section 348 of the ITA 2025. When its registration nears expiry in 2027, it will renew using the new RNPO renewal form once CBDT notifies it.
What you need to do right now
- Check your certificate's expiry date — if it falls within the next 12 months, start preparing for renewal under the RNPO framework.
- File Form 10B or Form 10BB for AY 2026-27 by 30 September 2026 — a delay attracts a penalty of ₹200 per day under Section 234G of the IT Act 1961, and no CBDT extension has been announced as of 22 September 2026.
- File ITR-7 for AY 2026-27 by 31 October 2026 in audit cases.
- File Form 10BD (donor statement) by 31 May each year — check incometaxindia.gov.in for any notified extension for FY 2025-26.
- If your Form 10AB (80G renewal) fell between 1 October 2025 and 31 March 2026, it qualifies for delay condonation under CBDT Circular No. 06/2026 (F.No. 300176/3/2026-ITA-I, dated 2 July 2026, issued under Section 119(2)(b) of the IT Act 1961) — track disposal by 31 December 2026.
- Keep applying at least 85% of income to charitable purposes each year — this remains the core condition for exemption under Chapter XVII.
I'm CA Harun Raaj, Visakhapatnam. If your trust's registration or audit filings are affected by this transition, reach out to my office for a review before your next deadline.
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See Also
Frequently Asked Questions
Does my existing 12A/12AB certificate become invalid on 1 April 2026?
No. If your registration under Section 12A, 12AA, or 12AB was valid and uncancelled as of 31 March 2026, you are automatically treated as a Registered Non-Profit Organisation under Section 332 of the Income-tax Act, 2025, from 1 April 2026. The certificate continues for the balance of its originally granted validity period.
My 12AB registration expires in 2027 — what form do I use for renewal under the new Act?
Renewal will run through the RNPO registration process under Section 332 of the ITA 2025 using new forms that CBDT has not yet notified. Your certificate remains valid through its original expiry, so monitor incometaxindia.gov.in for the notification before that date.
Does my 80G approval automatically carry forward under ITA 2025?
Section 80G approvals issued under the 1961 Act continue for their remaining validity period, and the new Act reorganises donor deduction provisions within Chapter XVII. No fresh filing is required immediately, but check your 80G approval's own expiry date separately from your 12A/12AB status.
Can a newly formed trust get provisional RNPO registration?
Yes, provisional registration is available for 3 years under Section 332 of the ITA 2025. For applications filed now, Form 10A on the e-filing portal is still used, and CBDT Circular 01/2026 (dated 23 March 2026, F.No. 300173/26/2026-ITA-I) clarifies that the PCIT/CIT can condone delays in Form 10A filings where reasonable cause is shown.
Do I file ITR-7 for Tax Year 2026-27 or a new return form?
For Assessment Year 2026-27 (FY 2025-26), you file ITR-7 under the 1961 Act as usual. CBDT is expected to notify a separate return form applicable to Tax Year 2026-27 under the ITA 2025 — watch for that notification before your next filing cycle.
Which audit report form applies for my trust's AY 2026-27 filing — Form 10BB or Form 112?
AY 2026-27 (FY 2025-26) is still governed by the Income-tax Act, 1961, so you file Form 10B or Form 10BB, not Form 112. Form 112, the new NPO audit report under Section 348 of the ITA 2025, applies only from Tax Year 2026-27 onward.
What happens if I miss the 30 September 2026 audit report deadline?
A delay in filing Form 10B or Form 10BB for AY 2026-27 attracts a penalty of ₹200 per day of default under Section 234G of the IT Act 1961. As of 22 September 2026, no CBDT extension had been announced, so the original deadline applies.
What is the new validity period for a small trust under ITA 2025?
Trusts with income of ₹5 crore or less in each of the two preceding Tax Years may be eligible for up to 10-year validity on regular registration under the ITA 2025, compared to the standard 5-year period. The specific eligibility form and process are still awaited from CBDT.
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