12A/80G Registration & 12AB Re-registration: The Process, Start to Finish
The mechanics of 12A/80G Registration & 12AB Re-registration are what clients ask about once they have decided to proceed. The questions below are the ones raised most often in practice; the full scope of the service is on the 12A/80G Registration & 12AB Re-registration page.
Can we apply for 12AB and 80G simultaneously — or must they be done in sequence?
Both can be applied for simultaneously on the Income Tax portal using Form 10A (for provisional registration) or Form 10AB (for regular registration). The form has a single application covering both 12AB and 80G approval. The CIT(E) processes the 12AB registration first and, upon satisfaction, issues the 80G approval in the same order. There is no need for two separate applications or two separate fees.
In practice: The 80G approval is contingent on 12AB — you cannot hold 80G approval without a valid 12AB registration. If the 12AB is cancelled, suspended, or lapses, the 80G approval becomes ineffective simultaneously. This interdependency means that 12AB renewal must be filed well before expiry, not at the last moment.
What is Form 10BD — and what happens if we do not file it?
Form 10BD is the Statement of Donations, filed annually on the Income Tax portal by 31 May for the preceding financial year. It requires the organisation to report details of every donation received during the year for which it issued an 80G certificate — donor name, PAN, donation amount, date, and donation type. Once submitted, the system generates individual Form 10BE certificates for each donor, which the organisation must provide to donors for their tax return. If Form 10BD is not filed, donors cannot claim their 80G deduction — their deduction claim will be rejected because the Income Tax system now verifies donations against the Statement of Donations filed by the organisation.
In practice: This is one of the most consequential post-Finance Act 2020 compliance changes. Previously, organisations issued physical 80G receipts and donors self-declared donations in their tax returns. Now, the verification is done electronically through Form 10BD. An organisation that fails to file Form 10BD by 31 May causes all its donors to lose their 80G deduction for that year — resulting in donor complaints, loss of trust, and potential damage to future funding relationships.
Which ITR form does our organisation file — and what is the deadline?
Organisations registered under Section 12AB file ITR-7 (Income Tax Return for persons including companies required to furnish return under Sections 139(4A), 139(4B), 139(4C), or 139(4D)). Charitable trusts and institutions file under Section 139(4A). Where the accounts are required to be audited, the ITR-7 is generally due by 31 October of the assessment year; for FY 2025-26 (assessment year 2026-27), CBDT Circular 07/2026 of 28 September 2026 extended that date from 31 October to 21 November 2026 for persons covered by Explanation 2 to Section 139(1), so confirm that it applies to your organisation and check for any further extension.
In practice: ITR-7 is more complex than a standard corporate or individual tax return — it requires detailed schedules for income application, accumulation, investments, donations received, and related-party transactions. A significant number of 12AB-registered organisations file ITR-7 late or incorrectly because their bookkeeper is not familiar with the schedule structure. PNPC prepares and files ITR-7 as part of the annual compliance retainer.
What is the 85% application rule — and what happens if we do not spend 85% of income?
Section 11(1) of the Income-tax Act requires that a charitable organisation applies at least 85% of its income to the stated charitable purposes during the financial year (or by the end of the following financial year for amounts accumulated under Section 11(2)) to claim tax exemption on that income. The remaining 15% can be accumulated without time restriction, provided it is invested in Section 11(5) modes. If less than 85% is applied in a year, the unapplied amount (above the 15% accumulation allowance) is treated as taxable income of the organisation for that year.
In practice: The 85% rule is calculated on receipts (income), not donations alone. Grant receipts, fee income, investment income, and all other receipts are included in the denominator. For organisations with large irregular grant receipts, this requires careful cash-flow management — you cannot receive a large grant in March and claim you will spend it in April. We model this for clients annually to avoid year-end surprises.
Our 12A registration was granted in 2005. Is it still valid — or do we need to reapply?
If you have not already re-registered under Section 12AB (the post-Finance Act 2020 framework), your 2005 12A registration is no longer valid. The Finance Act 2020 required all pre-existing registrations to be renewed as fresh 12AB registrations by 30 September 2022 (multiple extensions were granted). If you missed the re-registration window, you are currently operating without a valid income-tax exemption — all income since the lapse date is potentially taxable. The remedy is to apply for fresh registration under Section 12AB immediately, seek regularisation with the Income Tax Department for the lapsed period, and regularise any outstanding ITR-7 obligations.
In practice: This situation is more common than it should be — we receive enquiries from organisations every month who discover their pre-2021 registration has lapsed. The income-tax consequences depend on the specific circumstances: whether the organisation filed ITR-7 during the lapsed period, whether it claimed exemption incorrectly, and whether any assessments are pending. We advise on the correct remediation approach for each case.
What is CSR funding under Schedule VII of the Companies Act — and how does it relate to 80G?
These activities include education, eradicating poverty, healthcare, environmental sustainability, and other charitable purposes. Companies making CSR contributions directly to eligible implementing agencies (which include registered Section 8 companies, trusts, societies, and similar entities with a 3-year track record) require that the recipient hold a valid 12A/12AB registration and 80G approval, plus a CSR-1 registration number. The company's CSR committee will typically ask for registration certificates before releasing funds.
In practice: CSR funding and 80G deductibility are separate — CSR spend is not deductible as business expenditure under Section 37(1) (Explanation 2 to Section 37(1), inserted by the Finance (No.2) Act 2014). Separately, a company may claim a Section 80G deduction for donations to 80G-approved recipients where the conditions of that section are met, and some Tribunal benches have allowed 80G on CSR contributions, but the position has been litigated, so confirm the current position before relying on it. Not every CSR contribution qualifies for an 80G deduction; that depends on the recipient holding a valid 80G approval and the conditions of that section being met.
Can we change our charitable objects after 12AB registration — without losing the exemption?
A change in charitable objects requires: an amendment to the governing document (trust deed amendment, society memorandum amendment, or MCA filing for Section 8 companies), intimation to the CIT(E), and in many cases a fresh or amended registration approval. If the amended objects fall within the definition of 'charitable purpose' under Section 2(15) of the Income-tax Act, the registration should remain valid. , shifting from education to religious activities, or from rural development to general public utility with commercial elements), the CIT(E) may require a fresh review. In all cases, changing objects without intimation to the CIT(E) is a compliance risk.
In practice: We advise against drafting overly narrow objects in the governing document precisely for this reason — narrow objects that require frequent amendment create administrative and compliance burden. Objects should be specific enough to establish charitable character but broad enough to cover the organisation's evolving programme portfolio.
Our organisation received a rejection from CIT(E) for our 12A application. What are the most common grounds — and can we reapply?
The most common grounds for rejection of 12A/12AB applications include: governing document lacking a non-distribution clause or dissolution clause, objects clause too vague or insufficiently charitable, evidence of private benefit to trustees or founders, majority of trustees from a single family without independent representation, activities appearing commercial rather than charitable, insufficient documentation of actual charitable activities, corpus fund invested in non-Section 11(5) modes, and incomplete or incorrect Form 10A/10AB submissions. After rejection, you can appeal to the Income Tax Appellate Tribunal (ITAT) or correct the deficiency and file a fresh application. PNPC advises on the specific ground of rejection and the most efficient remediation path.
In practice: Rejections can turn on document deficiencies — incorrect or incomplete governing documents — rather than on substantive grounds. A thorough pre-filing review of all documents by a CA specialising in this area dramatically reduces rejection probability. We conduct a formal pre-filing review as a standard step in every 12A/80G engagement.
Does PNPC handle both the initial registration and annual ongoing compliance for NGOs?
Yes. PNPC offers a complete NGO compliance service that covers: initial 12AB and 80G registration (provisional and regular), Form 10BD and Form 10BE donor certificate management, ITR-7 filing, Section 12AB audit (Form 10B/10BB), TDS compliance and returns, FCRA annual return (FC-4) if applicable, annual filings with Registrar of Societies or MCA for Section 8 companies, Charity Commissioner filings (Maharashtra, Gujarat), and the regular registration renewal (5-year cycle for 80G always, and for 12AB unless the organisation qualifies for the Finance Act 2025 ten-year concession). Clients under our retainer have one point of contact for all compliance — PNPC manages every filing and deadline proactively.
In practice: The annual compliance obligations for a 12AB/80G-registered organisation span at least 6 different filings across multiple authorities with separate deadlines. Managing these on an ad-hoc basis — engaging different consultants for each filing — creates gaps, miscommunication, and missed deadlines. A single CA firm that understands the full picture is significantly more effective.
Where this sits in the wider engagement
12A/80G Registration & 12AB Re-registration rarely arrives on its own. The statutory basis and the current requirements are set out on the 12A/80G Registration & 12AB Re-registration service page, and the related services are grouped under Business Setup.
What PNPC does
PNPC Global has practised since 1986 across India and the UAE. On 12A/80G Registration & 12AB Re-registration we take the work end to end — reviewing the facts, preparing and filing what is required, and dealing with the authority through to closure.