Trusts and NGOs receiving funds from outside India operate under the Foreign Contribution (Regulation) Act, 2010 — and the rules under it have been tightened in recent years in ways that are easy to miss if compliance is handled only once a year.
Who this actually applies to
FCRA applicability isn't limited to large international donors. It can be triggered by contributions from NRIs, OCI cardholders, and foreign citizens — including, in some cases, donations from a relative living abroad on a Green Card. Many trusts only realise this when a routine donor list review turns up a contribution that should have been reported and wasn't.
What the amendment rules tightened
The FCRA Amendment Rules brought sharper requirements around how foreign contributions are received, reported, and tracked — including the designated bank account structure and the timelines for intimating changes. The direction has consistently been toward more frequent, more detailed reporting, not less.
Where Rule 17AA fits in
Separately from FCRA itself, Rule 17AA sets out the specific books of account that trusts and institutions claiming exemption must maintain — including project-wise and donor-wise records. A trust that's diligent about FCRA reporting but hasn't aligned its books to Rule 17AA's format is still exposed at the time of an exemption review.
What we'd suggest checking now
Run a donor ledger review at least once a year specifically to flag foreign-sourced contributions — including from NRI or foreign-citizen relatives of resident donors. Confirm the designated FCRA bank account is being used exactly as prescribed, and that Rule 17AA books are being maintained in parallel with FCRA returns, not as a separate afterthought.