Amendments in FCRA Form FC-4 and extension of validity

Vide Notification G.S.R. 683(E) dated 22nd September 2023 Ministry of Home Affairs has amended the Foreign Contribution Regulation Rules, 2011.

Until this amendment, the Annual Return filed in online Form FC-4 under 3(b) only required “details of purchase of fresh assets” for activities/projects for which foreign contribution is received and utilized. Now under the recent amendment two new tables 3(ba) & 3(bb) have been added.

Please see the tables here below:

This most likely is a new data mining exercise so that when an NPO is suspended MHA would have a clear idea regarding assets that need to be frozen or in case FCRA registration is cancelled or even voluntarily surrendered, the assets (movable and immovable) that could potentially vest in the ‘competent authority’.

NPOs that have already filed the Annual Return in FC-4 are wondering if they can revise what has already been submitted? Unfortunately, once any FC form is submitted online there is no provision for revision.

Will NPOs that have already filed the Annual Return in FC-4 be required to file their Annual Returns again? We think not. Maybe we should say, we hope not!

Public Notice Regarding Extension of Validity of FCRA certificates

https://fcraonline.nic.in/Home/PDF_Doc/fc_notice_25092023.pdf

Several NPOs whose FCRA registration has expired on 30th September 2021 and have applied for renewal, are still awaiting disposal of their application after three years. To all such anxious applicants MHA has recently offered relief and granted extension of validity up to 31st March 2024.

All FCRA new registration, prior permission and renewals require report of ‘field visit’ and report of the ‘monitoring unit’. Pan India, all this takes a lot of time.

Interesting statistics

  • 16,666 NGOs and associations with FCRA licence are active as on September 25, 2023;
  • FCRA licences of 13,282 entities are deemed expired;
  • FCRA registration of 20,694 NGOs has been cancelled.
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