Every FCRA-NGO has to submit an Annual Return to the Ministry of Home Affairs (MHA), online before 31st December for its foreign fund receipts for the previous financial year. Until 2015, this format was called the FC6; later, with a few modifications, it was called the FC4 form. These annual returns are available online for anyone to read or download at the website of FCRA, year-wise, since 2006.

Very recently, MHA has revised the FC4 form which demands the FCRA-NGOs to provide a lot more information, not just about the ‘donations’ they received from abroad, but also how much of it they have deposited in Fixed Deposits, etc. Here, we summarize a few of the key features of this revised FC4 form.

We will do this through the means of an example. For this purpose, let us consider the FC4 return filed by the FCRA-NGO, ‘Reaching The Unreached (RTU)’, G. Kallupatti, Theni district, Tamil Nadu, for the year 2018-19 and whose FCRA registration number is: TN/075940008. [For the uninitiated, the word ‘Unreached’ means a group of people who have not heard the Gospel — the revelation of Jesus Christ].

Each FCRA-NGO was mandated (relaxed a few months ago by FCRA wing) to obtain a Unique ID from the Darpan portal of Niti Aayog. Many, out of the 24340 FCRA-NGOs currently having FCRA registration, have obtained the same. The Darpan ID is now part of the FC4 return. This means one can find more information about the NGO, its mandates, its Board of Trustees, etc., from the Darpan portal, in a relatively easier manner.

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The date on which the NGO received the FCRA registration is also part of the revised FC4. In the case of Reaching The Unreached, it is 7th January 1985. An unwelcome revision is the removal of the name of the FCRA-NGO from the FC4 return. The MHA should consider including it again.

Under foreign fund receipts, a new subsection is ‘Other receipts from projects/activities’. In the case of RTU, it reports Rs. 82, 000 as its receipts from running a ‘Children’s Village’ (Authors’ Note: Running Orphanages is a standard work of several FCRA-NGOs, particularly ones which pursue Evangelism. For more knowledge on this matter, google 4/14 window).

One may wonder how this Rs. 82000 was obtained by RTU and why it is classified under ‘foreign contribution (FC)’. The reason is simple. The ‘Children’s Village’ was established by RTU in 2007-08 using foreign funds received via FCRA. All receipts accrued out of running facilities that were established with FCRA funds are classified as FC, per FCRA-2010.

RTU’s total FC in 2018-19 was Rs. 18.85 Crore, of which it received Rs. 6.04 Crore directly from abroad while Rs. 11.84 Crore was ‘brought forward’ into this year, as money lying unspent from its past receipts. These data were part of the FC4 format before its revision as well, so let us not spend too much time on these.

In the section on ‘donor-wise details of FC received’, the specific activity for which the ‘donation’ was received by the FCRA-NGO has been added. This feature used to be present in the older FC6 form, and it is a positive development that it has been revived in the revised FC4. However, in the erstwhile FC6, the NGO had to pick from a set of specific categories (which were quite obscure and unimaginative), while in the revised FC4, the NGO is asked to describe the activity by itself.

In the FC4 before revision, it was not mandatory to report ‘donations’ less than Rs. 20000. In the case of RTU, we notice several ‘donations’ which are below Rs. 20000. It is unclear if there has been a revision on this aspect or if RTU filed this information suo moto. (Authors’ note: Since the Bank account of the FCRA-NGO where the FC is received is part of core banking, and since Banks have to inform regularly the FC received in such accounts to MHA, the MHA would be aware, almost in real-time, every ‘donation’, however small, received by a FCRA-NGO. So, as far as MHA is concerned, it does not need the FC4 return of the NGO to learn of the donations. The return is more for the consumption of the public).

The next big change is in the section on ‘Details of utilization’. This section too has borrowed from the erstwhile FC6 format but is a lot more comprehensive than that. Here, the FCRA-NGO is asked to submit item-wise details of how much money was spent on which activity, where was it spent and other such details.

The biggest change is subsection c here, which presents details of the purchase of fresh movable and immovable assets. In the case of RTU, we learn that it had used FC to purchase movable assets such as DVD, Audio systems, Tractor, Water Tanker, School Bus, TV, Physio Equipment, Vehicles, and other such things. We also learn that it spent Rs. 38 lakh towards the construction of a new Boys hostel building.

In sub-section (d), the revised FC4 seeks information on recipients of FC from the FCRA-NGO to other FCRA-NGOs. (Authors’ Note: One of the idiosyncrasies of FCRA-2010 is what is called the second recipient. An FCRA-NGO receives FC from abroad and in turn distributes the same/part to other FCRA-NGOs. This is permitted). RTU has not used this feature, so it reports nothing here.

Furthermore, under Details of Unutilised FC, there is a new subsection where the FCRA-NGO is asked to provide complete details of Fixed Deposits it has. These include past fixed deposit amounts, ones newly made in the current year, any FD closed, etc. This is a very good source of information for ordinary people who wish to learn more about such NGOs.

A strange new sub-section asks for details of unutilized land and building (established with FC funds) for over two years. We cannot claim to know the purpose of this question, nor do we know of any FCRA-NGO which has provided non-null details for this sub-section.

A very significant change in the revised FC4 is that the name of the Chief Functionary of the FCRA-NGO whose digital signature uploaded in the return has to be filled in block letters. During the period 2015-2017, one had to minutely examine the signatures (which did not have the name), to figure out the person(s) running any FCRA-NGO and compare the same with the information provided (if any) on the Darpan portal for that NGO. Not any longer.

The FC4 itself carries the name of the Chief Functionary which is, by far, the best thing to have happened in the FCRA domain (even bigger than putting Compassion International on Prior Approval). For instance, RTU’s FC4 has been signed by J. Antony Paulsamy. Darpan lists RTU’s Secretary as Antony Paulsamy and Mary Ramasamy and G. Shanmugalatha as its Board Members. While data on Darpan is static, that on the FCRA will be dynamic (Authors’ Note: One has not seen it getting updated, even if functionaries change for instance, which is not surprising given that it is run by Niti Aayog, more as a vestige of its Planning Commission days). So, this makes the public better informed.

In summary, these revisions in the FC4 form are highly welcome. It will increase public limelight and hopefully, scrutiny of deviant FCRA-NGOs, since commoners will now be able to relate a publicly visible asset (say an orphanage or a school in one’s street or neighbourhood) with the FCRA-NGO readily. Thus, the FCRA Wing of the Ministry of Home Affairs must be applauded for these bold revisions.

(Note: The author has chosen to stay anonymous due to personal reasons)