Your NGO Partner Just Got a New FCRA Calendar. So Did You.

By SCORE CSR Advisory Desk · Oct 1, 2026 · From SCORE CSR Compass, Issue 03

Every CSR rupee has two ends: the Board that approves it, and the organisation that spends it. For two issues, boardrooms have watched a proposed Bill. Meanwhile, a change that is already law quietly rewrote the other end.

On 22 June 2026, the Ministry of Home Affairs notified the Foreign Contribution (Regulation) Amendment Rules, 2026, with immediate effect. They were written for NGOs. But for any company whose implementing partner blends CSR grants with foreign contribution, they are now a CSR continuity question.

What changed for FCRA-registered NGOs

• “Reasonable activity” now has a number. An NGO must have utilised at least ₹10 lakh of foreign contribution across the last two financial years (new Rule 14A). Only FC-funded work counts.
• Purpose- and geography-specific registration. Existing registrants must file Form FC-6F, declaring their purposes and States/UTs, by 21 June 2027.
• “Key functionary” widened to include office-bearers, governing-body members and anyone with control or responsibility.
• Foreign nationals in key roles (other than persons of Indian origin) now ordinarily make an organisation ineligible.
• 75% utilisation before the next tranche for prior-permission funding released in instalments.
• A richer annual return: Form FC-4 must now carry a detailed activity report.

Why a CSR Committee should care

To be clear: CSR funds are domestic money and are not governed by FCRA. Nothing here makes a CSR grant non-compliant on its own.

The exposure is operational and reputational. Under Section 135 and the CSR Policy Rules, the Committee monitors the annual action plan, and the Board must satisfy itself that funds were used as approved. Both assume a functioning partner at the other end. The June Rules add a new, measurable way for that partner to fail — for instance:

• The mid-project lapse: your partner fails the ₹10 lakh test in year two of a three-year project. Your grant stays lawful; the team delivering it may not survive the funding shock.
• The scope mismatch: your project runs in Odisha, but your partner’s FC-6F declares only other States. Its funded capacity in your geography may quietly shrink.
• The shared asset: the pending FCRA Amendment Bill, 2026, now before a Joint Parliamentary Committee, proposes a Designated Authority to take charge of FC-funded assets when a registration ends. A school block or clinic built with mixed CSR and foreign funds needs documented segregation from day one.

A Committee that asks now is exercising oversight. One that learns at year-end is explaining a lapse.

What to do this quarter

For CSR Committees and CFOs: add one line to every implementing-agency review — “Does this partner also receive foreign contribution, and where does it stand against the June 2026 Rules?” Check that your project’s State and theme sit inside the partner’s planned FC-6F scope, and that your agreement carries utilisation-certificate timelines and a step-in clause.

For NGO leaders: answer the FCRA question before your funder asks it. Keep project-wise ledgers that separate CSR, foreign and other domestic funds; update your key-functionary list to the new definition; and plan your FC-6F well ahead of the deadline.

Also on the October clock

• 30 October: AOC-4 with Form CSR-2 for FY 2025-26, for companies that held their AGM on 30 September.
• 31 October: annual financial disclosures for NPOs on the Social Stock Exchange (or the ITR due date, if later).
• New this year: under Rule 4A, up to 10% of annual CSR spend can now flow through Zero Coupon Zero Principal (ZCZP) instruments on the SSE — measured against actual spend, not the 2% obligation.

A second opinion, from either side of the table

SCORE advises both the companies that fund CSR and the organisations that deliver it. Our Advisory Desk offers a complimentary Partner Health Check: we review one funder–partner relationship against twelve checks, six for each side, and tell you in writing where the gaps are.

To book, email contact@scoreindia.co.in with the subject “Partner Health Check”, or call +91 87966 07005.

Read the full October issue of SCORE CSR Compass, including The Partner Handshake checklist and the worked ZCZP example, on our LinkedIn newsletter.

This article is for general information and does not constitute legal, tax or compliance advice. Confirm applicability and filing dates with your Company Secretary and Chartered Accountant before acting.

Sources: MHA Notification S.O. 3272(E), 22 June 2026; FCRA (Amendment) Bill, 2026 (PRS Legislative Research); Section 135, Companies Act 2013; CSR Policy Rules 2014; Companies (CSR Policy) Amendment Rules, 2026.