Annual Compliance Calendar for NGOs and Trusts in India

Trusts and NGOs in India sit at the intersection of three separate compliance regimes: income tax exemption compliance, FCRA (if foreign funds are received), and the registration cycle under 12A/80G that makes the exemption possible in the first place. Each regime has its own filing, its own form, and its own deadline, and none of them defer to each other. Missing one does not just mean a penalty; in the case of the audit report, it can mean losing the exemption for the entire year. This calendar walks through what falls due, and when, for a typical trust claiming exemption under Sections 11 and 12.

The Core Deadline Chain: Audit Report, Then ITR-7

Two forms carry the exemption claim each year, and they are sequenced, not independent:

• Form 10B or Form 10BB (audit report): Every trust or institution claiming exemption under Sections 11-12, or approved under Section 10(23C)(iv)/(v)/(vi)/(via), must get its accounts audited and the audit report filed electronically. Form 10B applies where total income before claiming exemption exceeds Rs 5 crore in the previous year, or the trust has received foreign contribution during the year, or applied income outside India during the year. Form 10BB applies in all other cases. Both must be filed at least one month before the due date for filing the return of income.
• ITR-7: The income tax return for entities claiming exemption under Sections 11-12 or Section 10(23C), among other categories covered by Sections 139(4A) to 139(4D). For a trust subject to audit, the ITR-7 due date is typically 31 October following the close of the financial year, which places the audit report deadline at 30 September in the ordinary course. The CBDT has in some recent years extended these dates administratively (for example, the Form 10B/10BB deadline for AY 2025-26 was extended to 31 October 2025), so always confirm the current-year date on the income tax e-filing portal rather than assuming the standard date holds; do not treat an extension in one year as a precedent for the next.

The practical sequencing point trusts miss most often: the audit report is not a formality that can be filed alongside or after the ITR-7. It must be filed first, with the return referencing the audit report's acknowledgment number. Leaving both to the last week of October regularly causes trusts to miss the audit report's own one-month-earlier cutoff.

FCRA Annual Return: Form FC-4, Due 31 December

If the trust is registered under FCRA, 2010, or holds prior permission to receive foreign contribution, a separate annual return in Form FC-4 is due to the Ministry of Home Affairs by 31 December for the financial year that closed on the preceding 31 March, roughly nine months after year-end. This is entirely independent of the income tax filings above and uses the trust's FCRA-designated bank account records rather than its general books.

A trust with FCRA registration but no foreign contribution actually received during the year still has to file a nil return; the obligation is tied to holding the registration, not to activity in a given year. Persistent non-filing, or filing well past the deadline, exposes the trust to penalty and, in serious or repeated cases, cancellation of FCRA registration itself, which is a far more disruptive outcome than a late fee.

The 12A/80G Renewal Cycle

Registration under Sections 12A and 80G is what makes Section 11-12 exemption and donor deductions possible at all, and since the 2020 overhaul it is not a one-time, permanent grant. The cycle runs as follows:

• Provisional registration is typically granted for about 3 years to a new trust. The trust must apply for regular (final) registration in Form 10AB within six months of the commencement of its activities, or at least six months before the provisional registration expires, whichever is earlier.
• Regular registration then runs for 5 years for most trusts, extended to 10 years for trusts whose total income (before claiming exemption) did not exceed Rs 5 crore in each of the preceding two years, applicable to applications made after 31 March 2025.
• Renewal at the end of each validity period again uses Form 10AB and must be filed at least six months before expiry of the current registration, not after.

Trusts that let a 12A or 80G registration lapse do not just lose the renewal paperwork battle; they lose the exemption and donor-deduction eligibility from the date of lapse forward, and re-registration does not retroactively fix the gap year. Calendaring the expiry date the moment a registration or renewal is granted, rather than waiting for a reminder closer to expiry, is the only reliable way to avoid this.

Putting It Together: A Year-Round View

For a trust with an FCRA registration and a financial year ending 31 March, the recurring annual deadlines line up roughly as follows, though the exact dates should always be reconfirmed each year against the income tax portal and MHA notifications:

• Through the year: maintain books eligible for audit, track application of income (85% application / accumulation rules), and monitor the 12A/80G registration expiry date on a standing calendar entry, not a last-minute check.
• By 30 September (typical, confirm annually): Form 10B or 10BB audit report filed.
• By 31 October (typical, confirm annually): ITR-7 filed, referencing the audit report.
• By 31 December: Form FC-4 annual return, if FCRA-registered, nil or otherwise.
• At least 6 months before expiry: Form 10AB filed for 12A/80G renewal (a one-time-per-cycle deadline, not annual, but the single most consequential one to miss).

Trusts that also receive corporate CSR funding carry a further, separate set of obligations around CSR-1 registration and fund utilisation reporting, covered in our companion guide on CSR fund utilisation compliance for receiving trusts. Between income tax exemption compliance, FCRA, and registration renewal, a trust's compliance calendar is genuinely denser than most private companies' — the cost of getting it wrong is not a fine but the exemption itself.