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Annual RTI Return to CIC or SIC: What Data Public Authorities Must Maintain

Direct answer. Section 25 of the RTI Act 2005 makes the Central Information Commission (and each State Information Commission) responsible for the annual report on the Act's working. Every public authority must furnish quarterly and annual returns to the Commission with statistics on RTIs received, disposed, refused, fees collected, appeals filed, and Section 8 exemptions invoked. The Commission then aggregates the returns and lays an annual report before Parliament or the State legislature. The data points and formats are below; missing the return is the single biggest cause of CAG audit observations on RTI compliance.

The Section 25 annual return is the spine of the RTI accountability system. It is how Parliament learns whether the Act is working; it is how researchers benchmark public authorities against each other; it is how public authorities themselves spot internal patterns of refusal. Many departments file the return mechanically with zeros and dashes, missing the value of the exercise.

When the return is due

  • Quarterly — most Commissions ask for quarterly progress reports (April-June, July-September, October-December, January-March).
  • Annual — by 30 April for the financial year that ended on 31 March.
  • Immediately on a major change — e.g. a notified change in the list of authorities under the Commission's jurisdiction.
  • Section 25(1) — Central Information Commission to prepare an annual report on implementation of the Act and lay it before Parliament. The same applies to each SIC for the State legislature.
  • Section 25(2) — every Ministry / Department in respect of public authorities under it shall collect and provide such information as required by the Commission.
  • Section 25(3) — list of items the report must contain.
  • Section 25(5) — Commission may recommend reform measures.

What Section 25(3) requires

For every public authority, in respect of the financial year, the report must contain:

  1. Number of requests received.
  2. Number of decisions where applicants were not entitled to access the documents pursuant to the requests, the provisions of the Act under which the decisions were made, and the number of times such provisions were invoked.
  3. Number of appeals referred to the Central / State Information Commission for review, the nature of the appeals, and the outcome of the appeals.
  4. Particulars of any disciplinary action taken against any officer in respect of the administration of the Act.
  5. Amount of charges collected by each public authority under the Act.
  6. Any facts which indicate efforts by public authorities to administer and implement the spirit and intention of the Act.
  7. Recommendations for reform — including general or specific recommendations.

Return format used by most Commissions

The CIC's standard quarterly return template (followed by most SICs with minor variation) covers:

Section Field Notes
A Public authority code (Ministry / Department / PSU) Allotted by Commission
B Period of return YYYY-Q1 / Q2 / Q3 / Q4 / Annual
C Number of RTI applications received Online + offline + transferred-in
D Number disposed (full + partial + rejected) Closed in the period
E Number pending at end of period Within / beyond statutory time
F Section 6(3) transfers out Where records were elsewhere
G Section 7(2) deemed refusals Beyond 30 days
H Section 7(3) additional fee demanded Total amount + count
I Section 8(1) exemptions invoked, clause-wise (a) to (j) sub-totals
J Section 9 copyright objections Count
K Section 11 third-party hearings Count
L First appeals received
M First appeals disposed Allowed / partly allowed / rejected
N First appeals pending
O Second appeals before Commission Count
P Section 18 complaints Count
Q Section 20 penalty proceedings Count + outcome
R Fees collected Application fee + additional fee
S Section 4(1)(b) compliance score Self-rating + last-updated date
T Disciplinary action against officers Count + nature
U Officers' training in the period Number of officers trained
V Awareness activities Citizen camps, brochures
W Recommendations for reform Free text
X Signature of nodal officer Name + designation + date

Step by step: how to compile a clean return

  1. Step 1. Maintain the master RTI register through the year — date of receipt, applicant, subject, PIO, status, disposal date, fee, exemption invoked.
  2. Step 2. Maintain a separate appeals register — first appeal received, FAA, hearing date, disposal date, disposition.
  3. Step 3. Maintain a Section 4 compliance file — page versions, update dates, signed sign-off for each clause.
  4. Step 4. At the end of every quarter, the nodal officer pulls counts from the registers.
  5. Step 5. Cross-verify against the receipts register at the cash counter (for fees) — fee collected must reconcile with applications received.
  6. Step 6. Reconcile against the despatch register — every reply to an applicant must have a despatch reference.
  7. Step 7. Send the return through the official portal of the Commission (CIC has an online return module; many SICs use email or post).
  8. Step 8. Save a signed PDF for the office record.
  9. Step 9. After CAG / Commission feedback, mark the open observations and close them in the next quarter.

Format expected for items I and J (exemptions)

The Commission needs clause-wise data. Suggested internal table:

Exemption clause Number of times invoked Number upheld in first appeal Number upheld in second appeal
8(1)(a) sovereignty
8(1)(b) court / contempt
8(1)© breach of privilege
8(1)(d) commercial confidence
8(1)(e) fiduciary
8(1)(f) foreign government
8(1)(g) life and physical safety
8(1)(h) investigation
8(1)(i) Cabinet papers
8(1)(j) personal information
Section 9 copyright
Section 11 third party
Section 24 excluded body

Common mistakes

  • Filing a “nil” return when the office actually received RTIs — happens when sub-offices forget to upload their data.
  • Counting transferred-in and original applications twice.
  • Counting first appeals as “second appeals” in column O. They are different.
  • Missing the Section 4 self-rating in column S — many authorities skip this and the Commission flags it.
  • No reconciliation with the cash register — fee figures often do not match the cashier's report.
  • Not closing previous observations before submitting the next return.

If a public authority defaults

  • The Commission can issue a Section 19(8)(a) direction to comply, in any second appeal where the authority is a respondent.
  • The Commission's annual report names defaulting public authorities — a reputational consequence.
  • The CAG, in its compliance audit, treats non-filing as a “lacuna in internal control”.

Frequently asked questions

Is the annual return mandatory?

Yes. Section 25(2) uses “shall”. The Commission has the statutory duty to ask, and the public authority has the statutory duty to provide.

What if my public authority received no RTIs in the period?

File a nil return — but only if the registers are also nil. Do not file nil to avoid the work of compilation.

Are PSUs required to file separately or through the parent ministry?

Through the parent ministry, with the PSU as a separate row. Some Commissions accept direct submissions; check your jurisdictional Commission's rules.

Does the return include both online and offline applications?

Yes. Online RTIs through the RTI Online portal must be added to offline counts.

What happens if the return is wrong?

The Commission may seek clarification. Repeated errors can be pulled up in the annual report.

Where can citizens read these returns?

Aggregated annual reports are published by the Commission. The CIC's reports are at cic.gov.in; SIC reports vary.

Who signs the return?

The nodal RTI officer of the public authority, counter-signed by the head of office in many states.

Sources

  • The Right to Information Act, 2005 — Section 25.
  • Department of Personnel and Training, rti.gov.in — guidelines on quarterly returns.
  • Central Information Commission annual reports, cic.gov.in.
  • Comptroller and Auditor General compliance audits, cag.gov.in.

See also

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