FCRA Registration Changes in Association

FCRA Registration Changes in Association (FC-6A,6B,6C,6D,6E)

The FCRA (Foreign Contribution Regulation Act) in India is a significant law governing the acceptance and utilisation of foreign contributions and donations by associations and non-profit organisations. The registration process involves filing FCRA Forms FC-6A, FC-6B, FC-6C, FC-6D, and FC-6E. These forms allow you to make various changes, such as updating your name, address, bank details, and critical members.

Forms

• FC-6A: Intimation of Change of Name and/or Address
• FC-6B: Intimation of Change of Nature, Aims & Objects and Registration
• FC-6C: Intimation of Change of Designated Bank Account details
• FC-6D: Intimation of Opening Additional FC-Utilisation Bank Account
• FC-6E: Intimation of Change in Key Functionaries or Members

Types of Changes Requiring Intimation Under FCRA

The FCRA regulations require you to keep the authorities informed about any significant changes within your organisation. These changes fall under specific categories, each with a designated form for intimation.

• 1. Change of Name or Address (FC-6A)

  This form is used to notify the authorities if your association undergoes a change in its official name or registered address within the same state.

• 2. Change of Nature, Aims & Objects and Registration (FC-6B)

  This form comes into play if your association alters its core purpose and objectives or undergoes registration with a local or relevant authority.

• 3. Change of Designated Bank Account Details (FC-6C)

  Use this form if there's a change in your designated FC receipt-cum-utilization bank account details, including the bank, branch, or account number.

• 4. Opening Additional FC-Utilisation Bank Account (FC-6D)

  If your association needs to open an additional bank account specifically for utilizing foreign contributions, you'll need to file this form.

• 5. Change in Key Functionaries or Members (FC-6E)

  This form is crucial for informing the authorities about any changes in your association's key personnel, including board members or other designated functionaries, especially if there's a shift of more than 50% in the original members.

Specific Forms for Different Changes

The following are specific forms for different changes :

• FC-6A: Change of Name and/or Address

  • Changes Requiring Form FC-6A:
  • Any official alteration to your association's name
  • Any shift in your registered address within the same state
  • Information Required in FC-6A:
  • Existing FCRA registration number.
  • Old name and address of the association (if applicable).
  • A new name and complete address for the association are needed.
  • Date of change.
  • Authorised signatory details.

• FC-6B: Change of Nature, Aims and Objects

  • Changes Requiring Form FC-6B:
  • Any modification to your association's core purpose or objectives as outlined in the registration documents.
  • Any new registration with a local or relevant authority that impacts your association's operations.
  • Information Required in FC-6B:
  • Existing FCRA registration number.
  • Detailed description of the changes made to the nature, aims, and objects.
  • Details of the new registration with a local authority (if applicable).
  • Date of change.
  • Authorised signatory details.

• FC-6C: Change of Designated Bank Account

  • Changes Requiring Form FC-6C:
  • Any alteration to the bank, branch, or account number associated with your designated FC receipt-cum-utilisation bank account.
  • Information Required in FC-6C:
  • Existing FCRA registration number.
  • Details of the old designated bank account (including bank name, branch, and account number).
  • Details of the new designated bank account (including bank name, branch, and account number).
  • Date of change.
  • Authorized signatory details.
  • A confirmation letter from the new bank acknowledging the FC account is needed.

• FC-6D: Opening Additional FC-Utilization Bank Account

  • Scenarios Requiring Form FC-6D:
  • If your association needs to open an additional bank account specifically for utilising foreign contributions. This is separate from the designated FC receipt-cum-utilisation account.
  • Information Required in FC-6D:
  • Existing FCRA registration number.
  • Details of the new FC-utilisation bank account (including bank name, branch, and account number).
  • Justification for opening the additional account.
  • Date of opening the account.
  • Authorised signatory details
  • A confirmation letter from the new bank acknowledging the FC account is needed

• FC-6E: Change in Key Members

  • Who are Considered ‘Key Members’ for FCRA?
  • Board of directors or managing committee members
  • Any other functionary with significant decision-making authority regarding foreign contributions.
  • A change is considered significant if it involves more than 50% of the originally registered key members.

• Information Required in FC-6E:

  • Existing FCRA registration number.
  • Details of outgoing key members (including name, designation, and date of change).
  • Details of incoming key members (including name, designation, and complete contact information).
  • Authorised signatory details

Time Limit

The time limit for filing all the FCRA intimation forms (FC-6A, 6B, 6C, 6D, and 6E) has been revised under the FCRA Amendment Rules of 2022. Previously, you had 15 days to inform the authorities about any changes.

The new time limit is a more relaxed 45 days from the date of change. This extended window provides you with ample time to gather necessary documents, complete the forms, and ensure proper compliance with the FCRA regulations.