FCRA Registration vs Prior Permission: FC-3A or FC-3B, and Which Route Fits Your NGO

Last updated 26 September 2026

FCRA registration vs prior permission: which route does your NGO need?

Your route depends on how old your organisation is, what it has spent, and whether the foreign money is ongoing or for one project. Registration (Form FC-3A) is the long-term licence to receive foreign contributions. Prior permission (Form FC-3B) is a one-off approval for a specific donor and a specific purpose.

Say Meera runs a trust in Jaipur that has been running a school-support programme for 18 months. A foundation abroad has offered a grant of a fixed amount for that programme. Meera's trust is under the 3-year mark, so Normal registration is unlikely to be open to it yet. Prior permission for that one grant is the route to discuss. A different trust, five years old with ₹40 lakh spent on its core work over three years, would look at registration instead, because it expects several foreign donors over the years.

Both routes are filed online on fcraonline.nic.in with the Ministry of Home Affairs (MHA). Both need you to be an existing society, trust or Section 8 company. FCRA is a follow-on registration, not a substitute for forming the entity.

The figures on this page are drawn from secondary sources (law-firm and compliance-firm summaries), not from a read of the official rules. Treat them as a starting point and let your CA confirm them against the current text before you file.

What is the difference between FC-3A registration and FC-3B prior permission?

FC-3A registration lets an association receive foreign contributions repeatedly for its stated purposes for five years, while FC-3B prior permission lets it receive a specific amount from a specific donor for a specific project. The table below sets the two side by side, as of September 2026.

Where the eligibility test sits at the margin, for example if your three-year spend is close to but below ₹15 lakh, ask your CA before choosing. Recent rule changes, as reported, ask for extra details such as an affidavit or capital-investment details when spend on stated aims is below the benchmark.

When should you choose registration instead of prior permission?

Choose registration when your organisation meets the age and spending test and expects foreign funding to continue beyond one grant. It saves you from repeating an application every time a donor comes along.

• You have more than one foreign donor, or expect to. Prior permission is tied to one donor and one project.
• You meet the eligibility test. Roughly 3 years of existence with reasonable activity, and about ₹15 lakh spent on core work over those years (excluding administrative expenses), per MHA guidelines as reported. The live FCRA registration page states the same benchmark.
• You want a five-year runway. The registration certificate is valid for five years, with renewal through FC-3C at least six months before expiry.
• Your donors ask for it. Many foreign funders ask for the certificate number before committing multi-year grants.

Registration carries ongoing duties: a designated account at State Bank of India, New Delhi Main Branch, an annual FC-4 return, and utilisation limits. Our guide to FCRA annual return and compliance covers them. Do not treat registration as a one-time task.

When does prior permission make more sense?

Prior permission makes sense when your organisation is too new or too small for Normal registration but has a specific foreign donor and a defined project. It lets you receive that funding lawfully instead of waiting.

Take Imran, who founded a society in Kochi two years ago. A partner charity overseas has committed a grant for a coastal health camp series. Imran's society has not reached the 3-year mark. If the donor's commitment letter is in hand, prior permission for that project is the discussion to have with a CA. Waiting to reach the age test could mean losing the grant.

Points to know before you choose this route

• It is not a shortcut to registration. Approval covers one donor and one purpose. You still need to build the record for Normal registration over time.
• Validity windows are limited. A notice dated 7 April 2025 is reported to have changed the windows to about 3 years to receive the funds and 4 years to use them from the date of approval. This rests on a single secondary source, so confirm the current figures before you rely on them.
• Money must not move before approval. Accepting foreign contribution without registration or prior permission is a violation under the FCRA, 2010, as the live Shunya page also notes.
• Fees and forms. We have not confirmed the FC-3B fee from a primary source, so ask your CA for the current figure instead of relying on one you have read online.

What is the new FC-3BB form and does it matter to you?

FC-3BB is a new form reported under the FCR Amendment Rules, 2026 for release of second and later instalments in prior-permission cases. It matters only if your approved foreign grant is large enough to be released in instalments.

As reported by a compliance-firm newsflash on the 22 June 2026 notification, where the approved amount is above ₹1 crore, funds may come in instalments under Rule 9A. To get the next instalment on FC-3BB, you would show about 75% utilisation of the previous instalment, with a CA certificate, bank statements and a utilisation report with photographs, and a field inquiry may follow. These details come from a secondary source, so treat them as indicative and ask your CA to check the notified text.

The practical lesson is simple. If you take prior permission, keep clean project-wise books from day one. The same records you would need anyway are what a later instalment request will draw on. Our 2026 amendment guide explains the other changes reported in the same notification.

Can an FCRA-registered NGO pass funds to other NGOs?

No. The 2020 amendment to the FCRA removed the ability to transfer foreign contribution to other persons, so the old "umbrella" model, where one registered NGO passed funds on to smaller partners, is no longer available.

This matters for small organisations that used to rely on a bigger registered partner. Their options now are to apply for their own prior permission for a specific project, qualify for their own registration, or work with the larger NGO in ways that do not involve passing on foreign funds. Ask your CA which arrangements are still allowed before you sign any partnership document, as the rules on what counts as a transfer are technical.

"Umbrella registration" is also not a formal category we could verify, so be cautious if a provider offers it as a product.

How does Shunya help you pick the route and file?

On the FCRA registration page, a practising Chartered Accountant assesses whether Normal registration or prior permission suits your history and funding, and every filing is reviewed by a CA before it goes onto fcraonline.nic.in. The process on that page also covers opening your FCRA account at State Bank of India, New Delhi Main Branch, and filing the application. The annual FC-4 return is a separate service.

Shunya's professional fee is ₹1,999. It does not include the DSC issuer's charge, government fees or other third-party and statutory costs, which are billed separately; your CA walks you through them on your callback. You can request a free callback with your name and phone number, or pay the professional fee online, or message +91 80809 18797 on WhatsApp.

Come with your entity's registration certificate, three years of financials and an activity report if you think Normal registration applies. For prior permission, bring the donor's commitment letter. If you are not yet incorporated, start with Section 8 company registration. The related guides on FCRA eligibility and documents required help you prepare.

This article is for general information only. For your specific situation, consult a practicing CA.