FCRA Audit Requirements explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
The Foreign Contribution (Regulation) Act, 2010 asks for three different things that are all called "audit" or "accounts" in practice: a separate set of accounts and records for the foreign contribution (section 19 and rule 11), audited statements and a chartered accountant's certificate that go into the filings (rules 13 and 17 and Form FC-4), and an audit of the books by an officer the Central Government authorises (section 20). This article keeps them apart.
It is written as per the Foreign Contribution (Regulation) Act, 2010 read with the Amendment Act, 2020, and the Foreign Contribution (Regulation) Rules, 2011 as amended by the notifications named in this article (latest consulted: S.O. 3272(E) dated 22 June 2026). Later amendments, notifications and Ministry of Home Affairs orders should be checked. Rules 13(a) and 17 rest on the third-party consolidation of 17 September 2019; confirm them against the official text.
Accounts: section 19 and rule 11 require a separate set of accounts and records, exclusively for foreign contribution received and utilised. Filings: Form FC-4 carries a chartered accountant's certificate and the audited statements are placed on the website within nine months. Open point: the sub-rule on that certificate, rule 17(5), was omitted in 2026, while Form FC-4 still refers to it. Audit under section 20: an authorised officer may audit the books if an intimation is missing, wrong or doubtful.
Separate accounts: section 19 and rule 11
Section 19 requires every person granted a certificate or given prior approval to maintain, in the form and manner prescribed, (a) an account of any foreign contribution received and (b) a record of the manner in which it has been utilised. Rule 11 prescribes the manner in one line: every person granted registration or prior permission shall maintain "a separate set of accounts and records, exclusively, for the foreign contribution received and utilised". The rule does not specify a ledger design, a software, or an auditor. It prints no time limit, since it is a standing duty. See sections 18 to 20 and rules 10 and 11.
The word "exclusively" matters because the same organisation may hold domestic funds. The FCRA Account under section 17 is a receiving account into which no other funds may be received or deposited, and rule 17(2) says the annual return reflects the foreign contribution received in that account and the transfers to utilisation accounts. Our books of accounts and compliance service sets up that separation in the ledger.
The register of investments
Rule 4(3) requires every association to maintain a separate register of investments, and rule 4(4) says every register so maintained shall be submitted for audit. The rule does not say who audits it. It sits beside the bar on speculative activities in section 8; see rule 4.
What is audited, and by whom, in the filings
| Item | Provision | What is printed |
|---|---|---|
| Audited statement of accounts on receipts and utilisation, with the income and expenditure statement, receipt and payment account and balance sheet | Rule 13(a) | Placed on the person's website, or the website specified by the Central Government, within nine months of the closure of the financial year; the rule does not name the auditor |
| Scanned copies of the detailed activity report, income and expenditure statement, receipt and payment account and balance sheet | Rule 17(1) | Go with Form FC-4 within nine months |
| Chartered accountant's certificate | Form FC-4 | The accountant certifies after audit the brought-forward and received amounts, interest and other income, unutilised balance, that accounts and records are maintained under section 19 read with rule 17, that the information is correct and that the contribution was used for registered purposes |
| Statement of violation | Form FC-4 (2024) | The accountant states, so far as he knows and believes, whether the Act, Rules or notifications have been violated, and the details |
| Activity-wise, project-wise and location-wise details | Form FC-4 (2025) | Certified by the accountant in a table |
| Accountant's identity | Form FC-4 serial 9 | Name, address, membership number, e-mail, date of issue and UDIN of the certificate (2026); UDIN of the separate audited financial statements maintained for foreign contribution |
| Activity-wise expenditure for registration | Form FC-3A Note (2025) | A chartered accountant's certificate where the audit reports and statements do not show it |
| Utilisation before a later instalment | Form FC-3BB | A chartered accountant's utilisation statement and certificate |
If foreign contribution has neither been received nor utilised in a financial year, the proviso to rule 17(8) says the chartered accountant's certificate and the statements need not be enclosed with Form FC-4, though a NIL report is still due. See rule 17 and rule 13.
The open point about rule 17(5)
Before 2026, rule 17(5) read: "Every report submitted under sub-rules (2) to (4) shall be duly certified by a chartered accountant" (as the copy consulted prints it). S.O. 3272(E) of 22 June 2026 omitted sub-rules (3), (4) and (5). Form FC-4, as amended by G.S.R. 790(E) of 31 December 2024, still speaks at serial 9 of "the certificate under sub-rule (5) of rule 17", and the 2026 notification itself adds the UDIN of that certificate. The sources print both and do not reconcile them, and nothing here says which governs. The Form's certificate is a printed part of Form FC-4, and the rule 17(8) proviso still mentions the certificate. Confirm the position against the official text and current instructions before the return is signed. For the Form, see the Forms article.
Audit by an authorised officer: section 20
Section 20 is not the organisation's own audit. It applies where a person granted a certificate or prior permission (a) fails to furnish any intimation within the time specified, (b) furnishes an intimation not in accordance with law, or (c) after inspection of the intimation, the Central Government has reasonable cause to believe that a provision of the Act has been or is being contravened. The Central Government may then, by general or special order, authorise a gazetted officer holding a Group A post, or any other officer, authority or organisation it thinks fit, to audit any books of account kept or maintained by the person. The officer may enter premises at any reasonable hour, before sunset and after sunrise, for the purpose. Information obtained from the audit is kept confidential and is not disclosed except for the purposes of the Act.
Section 20 is distinct from inspection under section 23, which needs reasons recorded in writing to suspect a contravention and extends to political parties, persons, organisations and associations, and from seizure of accounts or records under section 24. See sections 23 and 24.
What a failure costs
A knowingly false intimation under section 18 is punishable under section 33(a) with imprisonment up to six months, or fine, or both. Failure to maintain the account and records under section 19 is listed in the compounding table at serial 7: one lakh rupees or five per cent. of the foreign contribution for which accounts and records are not maintained, whichever is higher; a late website statement is serial 12, ten thousand rupees for each violation. See section 41.
Need help with separate accounts or an audit notice?
If your ledger mixes funds, or an intimation is overdue, a short review comes before the notice does. Our books of accounts and compliance team can separate and reconcile the foreign contribution, and our legal consultation team can advise on an audit order.
Key takeaways
- Section 19 and rule 11 require a separate set of accounts and records, exclusively for foreign contribution.
- Form FC-4 carries a chartered accountant's certificate; rule 13(a) requires the audited statement on the website within nine months.
- Rule 17(5) was omitted in 2026, yet Form FC-4 still refers to it; both are stated as printed.
- Section 20 audit is by an authorised officer, not by the organisation's auditor.
Read next
- Sections 18 to 20: intimation, accounts and audit
- Rule 4: speculative activities
- Rule 17: annual return in Form FC-4
- Sections 23 and 24: inspection and seizure of accounts or records
Disclaimer: Based on the Foreign Contribution (Regulation) Act, 2010 as enacted, read with the Amendment Act, 2020 and the other amendments named in this article, and on the Foreign Contribution (Regulation) Rules, 2011 as amended by the notifications named (latest consulted: S.O. 3272(E) dated 22 June 2026), as consulted on 2 October 2026. No consolidated official text was available; some provisions rest on a third-party copy and are identified as such. Later amendments, notifications and Ministry of Home Affairs orders should be checked. This article is general information, not legal advice; check the official text before acting.