A clearer path through FCRA prior permission.
A practical guide for Indian organisations, foreign donors and their advisers to assess the route, build a consistent FC-3B pack, and protect receipt and reporting controls.
Is this an FCRA matter?
Use the substance of the arrangement, not the label on the email or agreement.
Is value coming from a foreign source?
If no, document why and route through the normal domestic process. If yes or uncertain, continue.
Grant/donation or genuine services?
Consider obligations, pricing, IP, deliverables, commercial substance and who benefits. Do not treat a payment as outside FCRA only because it is called a fee.
Specific donor, amount and project?
For an organisation without general registration, a defined donor, exact amount and specific activity may point to the FC-3B Prior Permission route.
Pause the money movement
Open the intake, get finance and FCRA/legal review, secure approval, then authorise receipt. Escalate mixed or novel structures.
One controlled path from lead to closure
Checklist progress is saved only in this browser; it is a working aid, not the official file.
- Project lead
- Legal / FCRA
- Secretarial
- Board secretariat
- Finance
- Project lead
- Finance + legal
- Authorised filer
- Matter owner
- Finance
- Finance + project
What belongs in the working file
Entity & governance
- Self-certified registration / incorporation certificate
- Full Memorandum, Articles or charter
- Darpan ID and PAN evidence
- Board resolution and signatory authority
- Key-functionary list, ID evidence and Proforma AA
Donor & project
- Exact donor commitment on letterhead
- Donor incorporation and signatory proof
- DPR with activity, geography and timeline
- Detailed budget and utilisation plan
- Related-party and conflict disclosures
Application & declarations
- FC-3B working copy
- Chief functionary point-wise letter
- FATF undertaking
- Administrative-expense declaration
- Publication / RNI material, if applicable
- Fee receipt and submission acknowledgement
After filing
- Portal notices and responses
- Permission order and condition matrix
- Bank advice and receipt authorisation
- Separate books and supporting vouchers
- FC-4 returns and utilisation record
- Six-year retention and closure index
One file, clear owners, no premature receipt
Use the same matter name and core facts across every document. A draft, request, proposal or meeting is not an approval.
Project team
Owns the intake, donor coordination, project design, delivery facts and evidence of activity.
Output: complete project briefGovernance
Checks objects, key functionaries, conflicts, Board authority and eligible signatories.
Output: verified authority packFinance
Owns the budget, FCRA bank route, fee record, books, receipt control and annual reporting.
Output: reconciled financial packFCRA / legal
Confirms classification, eligibility, filing readiness, conditions and responses to portal notices.
Output: written clearanceAuthorised filer
Files only the approved final set, saves the acknowledgement and preserves every submitted version.
Output: filing recordForeign donor
Provides the commitment, legal identity and signatory evidence, and waits for written receipt clearance.
Output: donor evidence packUse a clean copy for every donor and project
Remove placeholders, tracked changes and comments. Amount, currency, purpose, geography, duration and instalments must match everywhere.
Recipient request letter
A clean request for the donor commitment and supporting donor records. Replace every bracketed field.
Download templateForeign donor commitment letter
Donor-letterhead form with exact amount, project, duration, instalments and prior-permission condition.
Download templateProject intake
Capture the counterparty, transaction, project and control facts before advice or drafting begins.
Download template ↓DPR outline
A consistent detailed-project-report skeleton built around the FC-3B pack.
Download outline ↓Budget and utilisation plan
Line-by-line cost plan with activity, evidence, timing and administrative-expense classification.
Download CSV ↓Review-pack index
Folder and evidence index from entity records through final reporting and closure.
Download index ↓Copy-ready email to a prospective foreign donorOpen
Subject: Documents needed for FCRA prior permission — [Project] Dear [Name], Thank you for discussing support for [Project]. As [Recipient organisation] must obtain project-specific FCRA Prior Permission before receiving the proposed foreign contribution, please share: 1. A signed commitment letter on [Donor] letterhead using the attached master; 2. Donor legal name, form, registration number, country and registered address; 3. Registration/incorporation evidence; 4. Authorised-signatory name, title and authority evidence; 5. Exact amount, currency, purpose, project locations, duration and payment schedule; and 6. Any grant conditions, reporting terms, conflicts or links with the recipient's governing body. Please do not transfer funds until [Recipient organisation] confirms in writing that Prior Permission and the required banking arrangements are in place. Regards, [Name] [Recipient organisation]
Copy-ready internal review requestOpen
Subject: FCRA review required — [Donor] / [Project] / [Amount and currency] Please review the attached pack for route, eligibility and consistency before FC-3B filing. Key facts - Donor and country: [ ] - Amount and currency: [ ] - Project, locations and duration: [ ] - Proposed instalments / receipt date: [ ] - Related parties, partners or conflicts: [ ] Please confirm or mark issues on: 1. Foreign-source and transaction classification; 2. Section 12(4), governance and signatory eligibility; 3. Darpan and SBI FCRA Account prerequisites; 4. Donor commitment, DPR, budget and FC-3B consistency; 5. Administrative-expense classification; 6. Transfer/partner, procurement, IP or service-payment risks; and 7. Filing readiness and any conditions to reflect in approvals. Status requested: Cleared / Cleared with conditions / Not ready.
Copy-ready portal clarification cover noteOpen
Subject: FC-3B clarification response — [Application number] — [Notice date] This response addresses each point in the notice in the same order. Point 1 — [Restate issue briefly] Response: [Direct answer] Evidence: [Annexure and page] Point 2 — [Restate issue briefly] Response: [Direct answer] Evidence: [Annexure and page] We confirm that any updated amount, purpose, location, duration, instalment or party detail has been reconciled across the commitment letter, DPR, budget, utilisation plan and FC-3B materials. Submitted by: [Authorised person] Reviewed by Finance: [ ] Reviewed by FCRA/legal: [ ] Submission date: [ ]
Controls that stay live after permission
Use only for the approved donor, amount, purpose, activities, locations, period and conditions.
Do not transfer foreign contribution to another association. Distinguish legitimate payment for services from prohibited transfer, and obtain advice for partner structures.
Keep administrative expenditure within 20% of foreign contribution received in the financial year unless prior approval is obtained. Classify costs carefully.
File by 31 December following each financial year, including Nil returns where required, until the contribution is fully utilised.
For permission above ₹1 crore, MHA may stage receipt. The portal currently shows FC-3BB for later instalments as “Coming Soon”; confirm the live route.
Maintain separate books, bank trail, vouchers, approvals and project evidence. Treat interest and other income from foreign contribution as foreign contribution.
Primary sources first
Last checked against the linked primary sources on 29 September 2026. Portal services, fees, forms and filing practice can change; verify the live position before acting.