FCRA Annual Return (FC-4) and Compliance: Deadlines, Accounts and What to Keep
An FCRA-registered NGO must file the annual return in Form FC-4 within nine months of the financial year end, which means 31 December. FC-4 for FY 2025-26 is therefore due 31 December 2026. A nil return is also required. Keep foreign funds in the designated SBI account and cap administrative spend at 20%. As of September 2026.
What is the FCRA annual return and when is FC-4 due?
The FCRA annual return is Form FC-4, filed on fcraonline.nic.in by every registered association, and it is due within nine months of the financial year end, which is 31 December. For the financial year 2025-26 (1 April 2025 to 31 March 2026), the due date is 31 December 2026.
Say Arvind, treasurer of a trust in Pune, finished March 2026 with foreign receipts and spending across two projects. He assumes 31 March is the deadline because the books close then. It is not. The books close on 31 March, the return is due by 31 December, and the audited FCRA statements need to be ready before that. Planning backwards from 31 December is the safer habit.
Even if you received no foreign contribution in the year, the return is still required as a nil return, per Rule 17(8) as reported. Skipping it because "nothing happened" is a common trap. Missing returns put the registration at risk, and the penalty amounts quoted by different sources conflict, so we do not quote a number here. Your CA can confirm the current position.
The figures on this page come from secondary sources, not the official text, so confirm dates on fcraonline.nic.in.
What does the FC-4 return contain, including the new 2026 asks?
FC-4 contains the association's foreign contribution receipts and utilisation for the year, supported by CA-certified statements, and the 2026 rules reported new content on top of that. As of September 2026, the following is what compliance-firm summaries describe.
The standard package
- A balance sheet, income and expenditure account, and receipts and payments account for foreign contribution.
- The bank statement of the FCRA account.
- Certification by a Chartered Accountant, plus a declaration by the chief functionary.
- Details of fixed assets and their locations, and carry-forward of unspent administrative expenses (added to the form for FY 2024-25, as reported).
Reported additions under the FCR Amendment Rules, 2026 (22 June 2026)
- A detailed activity report.
- Ultimate-donor details where funds come through donor-advised funds or intermediaries.
- Publications by the entity or its key functionaries.
- A UDIN for the FCRA financials.
- Website and social-media accounts.
These additions are drawn from a compliance-firm newsflash and other secondary summaries. Read them as a preparation list, not as a final form specification, and check the current FC-4 on the portal. Our 2026 amendment guide lists the other reported changes.
How must you handle your FCRA bank accounts?
Foreign contribution must first be received in a designated FCRA account at State Bank of India, New Delhi Main Branch (Sansad Marg), and only then moved to any utilisation account. This has been the requirement since the 2020 amendment.
- Designated account. The receiving account at SBI New Delhi Main Branch takes all foreign contribution. Do not let a foreign donor wire funds to your regular current account.
- Utilisation accounts. You may hold additional FCRA utilisation accounts at other scheduled banks, as reported, to which funds are moved from the SBI account. FC-3A also asks about such accounts.
- Keep FCRA money separate. Do not mix foreign contribution with local donations in one account. Mixing makes the FC-4 statements hard to certify.
- Reported 1 January 2025 changes. TDS refunds can reportedly be credited to the FCRA account, and unspent administrative allowance can be carried forward. Single-source; confirm with your CA.
If you are still getting registered, the account is part of the process on the live FCRA registration page. Details of the steps are in our guide to the FCRA registration process.
Get registered with a CA who also guides you on the FC-4 return and renewal timelines.
Start FCRA registration →What are the spending limits and restrictions you must follow?
Administrative expenses from foreign contribution are capped at 20% of the foreign contribution received, and foreign contribution cannot be transferred to other persons. Both limits date from the 2020 amendment.
| Rule | What it means for you | Confidence |
|---|---|---|
| 20% administrative cap | Salaries, rent and overheads paid from foreign money must stay within 20% of the FC received (earlier cap was 50%) | Two or more sources agree |
| Carry-forward | Unspent administrative allowance can be carried forward, as reported from January 2025 | Single source |
| No sub-transfer | You cannot pass foreign contribution on to another organisation | Two or more sources agree |
| Purpose and territory | Spend only on the purposes and in the State(s)/UT(s) named in your registration, as reported for the June 2026 rules | Two or more sources agree, secondary |
| Disclosure of receipts | Disclose receipts as the rules require on the portal or website; we could not verify the current form or deadline | Unverified, general only |
If your NGO worked on the old umbrella model, read our comparison of registration and prior permission, which explains the alternatives.
What is the reasonable-activity test under Rule 14A?
Rule 14A, reported as new in the 22 June 2026 amendment, deems an association to have shown "reasonable activity" if it utilised at least ₹10 lakh of foreign contribution in the preceding two financial years. Only activity funded by FCRA money counts, according to the reported summaries.
The test matters because it feeds into renewal and cancellation. An association that shows no reasonable activity for two consecutive years, or that looks defunct, risks non-renewal or cancellation, as reported. If your foreign receipts are modest, discuss with your CA how the test applies to you and how your utilisation records will be read. Again, this is from a compliance-firm summary, so confirm against the notified rules.
The broader point is that FCRA rewards documentation. Keep utilisation statements, invoices and project reports organised by year so that the FC-4 and any later renewal application draw on the same facts. See renewal and the 2026 amendment rules for how this connects to FC-3C.
What is a practical FCRA compliance calendar?
A workable calendar for a registered NGO runs from monthly bookkeeping to the 31 December return, plus the renewal and change filings that arrive on their own clocks. Dates below are as of September 2026.
| When | What to do |
|---|---|
| Every receipt | Credit foreign contribution to the SBI New Delhi Main Branch FCRA account; record donor and purpose |
| Monthly | Book FCRA receipts and spend separately from local funds; track the 20% administrative share |
| 31 March | Financial year closes; freeze FCRA books |
| April to September | Get FCRA financials audited and certified; assemble activity report, UDIN and other 2026 asks |
| By 31 December | File FC-4 for the year just ended (nil return if no receipts) |
| At least 6 months before expiry | File FC-3C for renewal |
| By 22 June 2027 | Existing registrants to file FC-6F, as reported for the 2026 rules |
| On any change | Report name, address, aims or key functionary changes on the relevant FC-6 form |
If your organisation is a trust or society that also claims tax exemption, the annual compliance runs alongside 12A and 80G obligations. It helps to plan both together.
Does Shunya handle FC-4 and ongoing compliance?
The FCRA registration page covers the FCRA registration application. Filing the annual FC-4 return and renewal are separate services, so ask your CA on the free callback if you want them handled.
Shunya's professional fee is ₹1,999 for FCRA registration; it excludes the DSC issuer's charge, government fees and other third-party or statutory costs, which are billed separately and explained on your callback. A practising CA reviews every filing before it goes on the portal. Read the package guide for what is and is not covered, or WhatsApp +91 80809 18797.
When is the FCRA annual return FC-4 due?
FC-4 is due within nine months of the financial year end, which falls on 31 December. For FY 2025-26 the due date is 31 December 2026, as reported. A nil return is also required in years with no foreign receipts. Confirm the date on fcraonline.nic.in.
Do I need to file FC-4 if I received no foreign contribution?
Yes, a nil return is reported as mandatory under Rule 17(8). Skipping it because nothing was received can put your registration at risk. Ask your CA to confirm the current requirement and file on time.
What is the 20% administrative expense cap in FCRA?
Since the 2020 amendment, administrative expenses paid from foreign contribution are capped at 20% of the foreign contribution received, down from 50%. Unspent allowance can reportedly be carried forward from January 2025. Confirm the current position with your CA.
Can I keep foreign donations in my regular bank account?
No. Foreign contribution must first be received in the designated FCRA account at State Bank of India, New Delhi Main Branch. You can then move funds to an FCRA utilisation account at another scheduled bank. Mixing FCRA money with local funds complicates certification.
What new information does FC-4 ask for after 2026?
As reported for the 22 June 2026 amendment, FC-4 asks for a detailed activity report, ultimate-donor details for intermediary funds, publications, a UDIN on the FCRA financials, and website and social-media accounts. This is from secondary summaries, so check the current form on the portal.
What happens if I file the FCRA return late?
Late or missing returns put your registration at risk and can attract penalties. Sources quote different penalty amounts, so we do not state one. Treat the deadline as firm and ask your CA about the current position before filing late.
This article is for general information only. For your specific situation, consult a practicing CA.
Ready to register your FCRA?
Request a free callback or pay the ₹1,999 professional fee online and a CA starts your filing. Government fees and other statutory costs are billed separately at actual cost.
Professional fee ₹1,999. Government fees, statutory costs and any third-party charges are billed separately; your CA walks you through them on your callback.