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FCRA Amendment Rules 2026: What NGOs Must File Before Renewal

Almost every FCRA headline this year has been about the Amendment Bill. That Bill is still sitting in Parliament and binds nobody yet. Meanwhile the Amendment Rules were notified on 22 June 2026, came into force immediately, and started a one-year clock that runs out on 21 June 2027.

If your organisation holds an FCRA certificate, your obligations today flow from the Rules, not from the Bill, and not from whatever happens to the Bill next week. Two of those obligations can cost you your registration at the next renewal. This page covers what changed, what you file, and when.

The one-line version. File Form FC-6F before 21 June 2027 naming the purposes and States you want to keep. Separately, check that you have utilised at least ₹10 lakh of foreign contribution over the last two financial years, because that is now the test for renewal.

First, separate the two documents

People are conflating these constantly, including some professional commentary. They are different instruments at different stages.

Eight days after the Rules were notified, on 30 June 2026, the Union Home Minister launched the rebuilt FCRA 2.0 portal, through which filings now pass. If you have not logged in since the migration, that is a task for this week, not for renewal month.

Change 1: Your certificate now names purposes and States

Under the old regime you could receive foreign contribution for broad categories loosely tethered to your stated objects. That flexibility is gone.

A registration certificate must now name the exact purpose or purposes for which foreign contribution may be received, and the specific States and Union Territories where you may operate — each chosen from a prescribed Schedule, not described in your own words.

Three consequences that bite immediately:

Do existing registrants have to reapply?

No. You do not file a fresh registration application merely because certificates now specify purposes and States.

What you file is an intimation in Form FC-6F, naming the purposes and the States or UTs for which you want to retain your registration, within one year of 22 June 2026 — so by 21 June 2027.

That is the single most actionable item on this page. Organisations that treat a one-year window as a distant problem tend to discover, in month eleven, that Schedule selection needs governing-body approval, that the State list is contested internally, and that nobody is sure who holds the digital signature.

Change 2: The ₹10 lakh utilisation test

This is the provision most likely to strip organisations off the register, and it is buried in a new Rule 14A.

For renewal, an association is now deemed to have undertaken reasonable activity in its chosen field only if it has utilised at least ₹10 lakh of foreign contribution in the preceding two financial years.

The Ministry's rationale is that this keeps dormant entities from holding live registrations while doing nothing. The difficulty is that the test measures utilisation, not need, and not performance.

A worked example. Take a rural library set up with ₹20 lakh of foreign contribution and running since on about ₹4 lakh a year. The capital phase is finished; spending has settled into modest recurring costs. Across two financial years it utilises ₹8 lakh — under the threshold.

On the face of Rule 14A it cannot renew, even though the project is working exactly as designed. *(Illustrative example, not a reported case.)*

If that shape resembles yours, model your two-year figure now, not at renewal. Every remedy for a foreseeable shortfall — accelerating planned capital expenditure, routing programme spend through the FCRA account rather than domestic funds, restructuring the funding cycle with the donor — needs lead time and donor consent. None can be arranged in the month before you apply.

Change 3: Religious purposes are now enumerated

The 2026 Rules explicitly list the permissible religious purposes, and the Ministry's position is that this gives faith-based organisations across all communities clarity about which activities qualify for foreign funding. Faith-based welfare — maintenance of places of worship, religious education, moral instruction, preservation of faith traditions — remains eligible. The Ministry states the Act applies uniformly regardless of religion, community or ideology. The Rules exclude proselytisation from permitted religious activity.

The countervailing reading, pressed by several faith-based bodies and by Opposition members, is that an enumerated list is by construction a closed list, so activity falling between the listed items becomes vulnerable by omission rather than by prohibition.

You do not have to resolve that debate to act on it. The operational point is the same either way: map your actual activities against the enumerated purposes before you file FC-6F, because the Schedule selection you make is what your certificate will say.

Where the numbers actually stand

The scale of the regime gets misdescribed in both directions, so here are figures from the Ministry's own factsheet.

Read those together and the direction is clear: cancelled and lapsed registrations now heavily outnumber the live ones, and a utilisation floor will push that further.

Do not quote precise portal counts. Dashboard figures shifted after the June 2026 migration and numbers circulating in commentary do not reconcile cleanly. If you need a specific count for a board paper or a grant application, pull it from the portal on the day, or from a recent Parliamentary Question reply, and date-stamp it.

What the pending Bill would add

Because the Bill shapes how the Rules will be read, a short account helps.

Assets bought with foreign contribution already vest in a State authority on cancellation or cessation under Section 15 of the Act, in force since 2010 — but the Act gave no procedure for taking custody of or managing them. The Bill supplies that, through a Designated Authority, with:

  1. Provisional vesting when registration ends, and full return of assets and unused funds if registration is restored.
  2. Permanent vesting only if registration is not restored within the prescribed period, with sale proceeds credited to the Consolidated Fund of India.
  3. Protection of religious sites — the Authority must preserve the religious character of a place of worship.
  4. Revision within 90 days, and a further right of appeal to the court of the District Judge.
  5. A proposed Section 14B, making cessation automatic where a certificate is not renewed before expiry.
  6. Maximum imprisonment for FCRA violations reduced from five years to one.

The link between the two instruments is what makes the utilisation floor consequential. Under the Rules, falling below ₹10 lakh over two years puts renewal at risk. Under the Bill as introduced, a certificate that ceases for want of renewal engages the asset machinery. Read together, an organisation that quietly under-spends could face consequences reaching its assets, not just its licence.

Your compliance checklist

  1. Compute two-year utilisation first. Compare against ₹10 lakh. This determines whether anything else matters.
  2. Confirm your certificate's expiry date. Registration runs five years. The renewal application is made in the six months before expiry under Section 16 read with Rule 12, in Form FC-3C; MHA has urged associations to apply about four months ahead, because late filing routinely means the certificate lapses before clearance comes through.
  3. Map current activities to the Schedule and get governing-body approval for the selection.
  4. Finalise your States and UTs list, including anywhere you work through a partner or field office.
  5. File Form FC-6F well inside the window — the deadline is 21 June 2027, not a date to meet in June 2027.
  6. Reconcile donor agreements against your scheduled purposes and States, and flag mismatches to donors early.
  7. Verify FCRA 2.0 portal access — authorised signatories, digital signatures and registered contact details all had to survive the migration.
  8. Check your reporting fields. Annual returns in Form FC-4 now capture project-wise and activity-wise utilisation, your website and social media handles, and identification of the ultimate foreign donor even where funds arrive through intermediaries.

When the portal goes quiet, use the RTI Act

FCRA applications and renewals stall, and the portal will rarely tell you why. The Ministry of Home Affairs is a public authority under the Right to Information Act, 2005, so where a renewal or registration has been pending without explanation you can ask for:

A public information officer has 30 days to reply under Section 7(1). This is the same escalation route citizens use across departments, and it works here — a pending FCRA file is an administrative record like any other. Our AI RTI Drafter will put the application into the correct form, and the PIO Reply Checker will tell you whether the reply you get is actually compliant or a brush-off.

If you are verifying a counterparty rather than chasing your own file, the NGO registration verification guide covers checking a registration before you transact, and RTI for grant-in-aid disbursement covers tracing public money already sanctioned.

Frequently asked questions

Are the FCRA Amendment Rules 2026 in force?

Yes. They were notified on 22 June 2026 vide S.O. 3272(E) and are operative now. The separate Amendment Bill, 2026 was introduced in the Lok Sabha on 25 March 2026 and is still before Parliament — it is not law.

Do I need fresh registration because of the new rules?

No. Existing registered associations furnish the prescribed particulars through Form FC-6F within one year of 22 June 2026, that is by 21 June 2027. A fresh registration application is not required merely because certificates now specify purposes and States.

What happens if we utilised less than ₹10 lakh over two years?

Renewal is at risk, because Rule 14A makes that threshold the test for having undertaken reasonable activity. Address a foreseeable shortfall with your donor and your auditor well before the renewal window opens, not during it.

Does FCRA prohibit NGOs from receiving foreign donations?

No. It operates as a registration and disclosure regime. Eligible organisations may receive foreign contribution after registration or prior permission, through a designated SBI New Delhi Main Branch account, subject to reporting requirements and a 20 percent cap on administrative expenses.

Does FCRA target a particular religion or community?

The Ministry's stated position is that the Act applies uniformly regardless of religion, community or ideology, and that faith-based welfare, religious education and maintenance of places of worship remain eligible across all faiths. Several faith-based bodies have contested how the enumerated-purposes approach will work in practice. The Rules exclude proselytisation from permitted religious activity.

When is the FCRA renewal application due?

Registration is valid for five years. The renewal application is filed in the six months before expiry, in Form FC-3C, under Section 16 read with Rule 12 of the 2011 Rules. Section 16(3) provides that renewal is ordinarily decided within 90 days.

This is a general explainer, not legal advice. Confirm your own registration and renewal position with qualified counsel or your statutory auditor, and check the current text on the portal before filing.

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