For most FCRA-registered organisations, the annual return in Form FC-4 for 2025–26 is due by 31 December 2026, nine months after the financial year ended. Many organisations treat it as a December job for the finance team. This year that is risky.
The FCRA Amendment Rules 2026, notified on 22 June 2026, added new disclosures to FC-4: the organisation’s website and social media, publications, ultimate donors behind intermediaries, and a detailed activity report with locations and amounts. Information that was never collected during the year is hard to rebuild in December.
Here are ten checks to start now, while there is still time to fix what they find.
This article is for educational and governance purposes only and is not legal advice. Check which version of Form FC-4 applies to your return, and the current text of the Rules, on the FCRA portal before filing.
The ten checks
| # | Check | Who owns it |
|---|---|---|
| 1 | Every foreign receipt reached the FCRA account at SBI, New Delhi Main Branch, and the bank statement reconciles to the books | Finance |
| 2 | No foreign contribution was mixed with local funds, and transfers to utilisation accounts are traced | Finance |
| 3 | Administrative expenses stay within 20% of foreign contribution received | Finance, CFO |
| 4 | Each FCRA-funded activity maps to a registered purpose and an approved State/UT | Programmes, Compliance |
| 5 | The activity report (locations, amounts, assets, outputs) agrees with donor reports | Programmes, Finance |
| 6 | Ultimate donor details are on file for money received through donor-advised funds, platforms or other intermediaries | Fundraising, Finance |
| 7 | Website, social media accounts and publications are listed and consistent with FCRA status | Communications |
| 8 | The key functionary register is current: appointments, resignations, changes | Governance, Company Secretary |
| 9 | Assets created from foreign contribution are in a separate register | Finance, Administration |
| 10 | Quarterly receipt disclosures on the website are up to date | Communications, Finance |
Checks 1 to 3: the money
Reconcile the FCRA account first. Every foreign receipt should be traceable from the FCRA account at SBI, New Delhi Main Branch, to the books and on to any utilisation account. Unexplained credits, refunds and interest are the usual loose ends.
Look for mixing. A local payment from the FCRA account, or a foreign grant spent from a local account, is easier to correct before the return than after an inspection.
Test the 20% limit on administrative expenses using actual cost allocations, not the budget. If shared salaries or rent are split between FCRA and local funds, write down the basis and apply it consistently.
Checks 4 and 5: what you did, and where
Under the 2026 Rules, registration specifies purposes and States/UTs. FC-4 now asks for a detailed activity report, with the location and the amount used for each project or activity. Build one table that links:
Grant → Project → Activity → Location → Amount → FCRA purpose → Evidence
Then compare it with what you reported to donors. If the FCRA return and the donor report describe the same year differently, someone will ask why. This table also feeds the FC-6F decision due by 21 June 2027 on which purposes and States/UTs to keep.
Checks 6 to 8: the new disclosures
Ultimate donors. Where money came through a donor-advised fund, an online giving platform or another intermediary, FC-4 asks for the intermediary and the ultimate donor’s name, address, email and amount. Ask intermediaries for this now; replies can take weeks.
Website, social media and publications. List every official account and publication, and read them once with FCRA status in mind. Programme descriptions should match what the organisation is registered to do.
Key functionaries. The wider definition covers trustees, governing-body members and anyone who controls or manages the organisation. Bring the register up to date before you report from it.
Checks 9 and 10: housekeeping that inspectors notice
Keep a separate register of assets bought from foreign contribution, and keep the quarterly disclosure of foreign receipts on your website current. Both are simple, and both are easy to find missing.
Make FC-4 a reviewed document, not a form
With more information to assemble, FC-4 deserves a review chain: Programmes → Finance → Compliance → Statutory Auditor → CFO → CEO → Board. Prepare it offline first. A simple rule helps: the person who prepares FC-4 should not be the only person who validates it.
A suggested timeline for a 31 December deadline:
- October: run the ten checks; request ultimate donor details; update the key functionary register.
- November: close gaps; build the activity table; reconcile with donor reports; auditor’s certification.
- Early December: management and board review; file well before the last week, when portals are busiest.
Which of the ten checks would your organisation find hardest to evidence today?
For the full background on the 2026 changes, see FCRA Amendment Rules 2026: What NGOs Need to Know. For why FCRA risk is also a board issue, see Is Your FCRA Problem Really a Compliance Problem?