Why the calendar matters
An NGO's tax exemption is conditional every single year. Missing the audit report, filing the return late, or failing to apply enough of the year's income can mean the income for that year is taxed — and repeated lapses can put the registration itself at risk.
The filings also depend on each other. The audit report comes before the return; the donor statement feeds donors' own returns; the FCRA return needs its own audited accounts. Running them as one calendar is simpler than chasing each deadline separately.
From 1 April 2026 the Income-tax Act, 2025 governs the registration of charitable trusts and institutions — Section 332 in place of Sections 12A/12AB, and Section 354 in place of Section 80G. Existing registrations continue for the rest of their validity.
The yearly compliance calendar
| When | What | Applies to |
|---|---|---|
| By the 7th of the following month (30 April for March) | TDS deposit on salaries and other payments | NGOs that deduct tax |
| Quarterly | TDS returns | NGOs that deduct tax |
| 31 May | Statement of donations and donor certificates (Form 10BD/10BE for FY 2025-26; Forms 113/114 from tax year 2026-27) | 80G-approved organisations |
| One month before the return due date | Audit report from a Chartered Accountant | Organisations whose income before exemption exceeds the basic exemption limit |
| 31 October (21 November 2026 for AY 2026-27 audit cases) | Income-tax return in ITR-7 | All registered organisations |
| 31 December | FCRA annual return, FC-4 | FCRA-registered organisations |
| As the state's Act and rules require | Annual list of the governing body, and under most state laws the annual return and accounts, with the Registrar of Societies | Societies |
| Every year | AOC-4, MGT-7 and other ROC filings | Section 8 companies |
Dates for the audit report and return can move when CBDT extends them; we check the current notification each year before filing.
The conditions behind the filings
- Application of income: at least 85% of the year's income spent on the objects. Where that isn't possible, income can be accumulated for up to five years or treated as applied in the following year — but only by filing the prescribed forms on time.
- Investments: surplus funds held only in the permitted modes.
- No personal benefit: no income or property used for the benefit of the founder, trustees or related persons.
- Books and audit: proper books, with an audit once income before exemption crosses the basic exemption limit.
- Anonymous and corpus donations: recorded and treated as the rules require.
What we need from you each year
- Bank statements for every account, including FCRA accounts.
- Receipts and donor details — name, address, and PAN or Aadhaar — for all donations.
- Vouchers for expenses, with project or activity tagging.
- Details of fixed assets bought or sold, and investments made.
- Minutes of trustee, governing body or board meetings approving budgets, accumulation and major decisions.
- Any grant agreements and the reports already sent to donors.
Practical notes from our engagements
- Donor PAN collected at year end. Chasing donors in May for PANs is the most common cause of a late donor statement. Collect it on the receipt.
- 85% test failed without a plan. If a large grant arrives late in the year, the accumulation forms have to be filed in time. We look at the numbers before the year closes.
- Registration renewal forgotten. Validity is stated in the order as a block of tax years, and renewal is due at least six months before the last of those years ends — which rarely lines up with when the order was issued. We track each organisation's renewal date separately.
- FCRA and domestic funds mixed in the books. Separate books make both audits cleaner, and the FC-4 accounts easier to defend.
How we handle NGO compliance
We set up the organisation's calendar at the start of the engagement, keep the books or review them through the year, carry out the audit, and file the audit report, return, donor statement and FCRA return on time. Before the year closes, we check the 85% test so there's time to act if it's short.
Related services
Frequently asked questions
Which ITR form does a trust file?
ITR-7, for trusts, societies and institutions claiming exemption. Section 8 companies claiming exemption also file ITR-7.
When is a trust's audit report due?
One month before the due date for the return. For AY 2026-27 the return date for audit cases was extended to 21 November 2026; the extension order speaks of the tax audit report, so confirm the Form 10B/10BB date before relying on a later date.
What if we couldn't spend 85% of our income this year?
Income can be accumulated for up to five years, or treated as applied in the next year, by filing the prescribed forms in time — for FY 2025-26, Forms 9A and 10 were due at least two months before the return due date; from tax year 2026-27 the accumulation statement is Form 109. Without them, the shortfall can be taxed.
When is the donor statement due?
By 31 May after the year ends — Form 10BD for FY 2025-26 donations, and Form 113 for donations from tax year 2026-27.
Does a small trust with little income need an audit?
An audit is required once income before exemption exceeds the basic exemption limit. Below that, it's still good practice, and donors often ask for audited accounts anyway.
Do we need to file anything with the Registrar?
Societies file with the Registrar of Societies — the annual list of the governing body and, under most state laws, the annual return and accounts — and Section 8 companies file with the ROC. Trusts generally don't have annual Registrar filings.