Despite increased awareness, we continue to see the same compliance errors year after year in our audit and advisory work.
1. Delayed FC-4 Filing
The annual return in Form FC-4 must be filed by 31 December every year. Late filing attracts penalties and can trigger enhanced scrutiny.
2. Incorrect Utilisation of Foreign Funds
Foreign contributions must be used only for the purposes stated in the organisation's registration. Using FCRA funds for activities not covered — even if aligned with the general mission — is a compliance violation.
3. Maintaining Separate Books
The FCRA account at the designated SBI branch must be kept strictly separate from domestic accounts. Commingling of funds is a serious offence.
4. Sub-granting Without Prior Permission
Transferring foreign funds to another organisation requires prior permission from the Ministry of Home Affairs unless the recipient is also FCRA-registered.
A proactive compliance approach — quarterly reviews, timely reconciliations, and annual audits well before the December deadline — is always preferable to reactive crisis management.
How SMA Can Help
Our firm has over two decades of specialised experience in FCRA compliance, registration, and renewal.