Renewal of 12A and 80G Registrations: Clarity, Timelines, and Best Practices for NPOs

Most Non-Profit Organisations (NPOs) in India were granted their 12A and 80G registrations under the revamped registration system in FY 2021-22, covering AY 2022-23. These registrations were issued with a validity of 5 years under the Income Tax Act, and renewal is now due for most entities before the end of FY 2025-26.

When Does the 5-Year Period Expire?

For most NPOs registered in FY 2021-22, the five-year registration under Section 12AB will expire on 31st March 2026. Accordingly, under Section 12A, renewal must be initiated at least 6 months prior to expiry.
That means: Organisations must apply for renewal before 30th September 2025.

Is It Now 10 Years Instead of 5?

There has been confusion due to the amendments in Section 12A, which now states that renewal is to be done after 10 years. However, based on current interpretation and administrative practice:

• The 10-year validity is prospective, and will apply after the current 5-year period ends.

• Until a formal order granting 10-year approval is received, the prudent approach is to treat the current registration as expiring on 31st March 2026 and apply accordingly.

Important: Do not assume your registration is valid for 10 years unless explicitly stated in the order received from the Income Tax Department.

80G Renewal Still on 5-Year Basis

Unlike Section 12A, no changes have been made to the renewal timeline for Section 80G. As per the Finance Act, 2025, 80G will continue to operate on a 5-year cycle. Hence, NPOs must apply for both 12AB and 80G renewal before 30th September 2025 to maintain continuity.

The Renewal Process: How It Works

Step-by-Step Timeline:

1. Application Filing:
   Submit Form 10AB for 12AB and 80G renewal on the Income Tax e-filing portal.
   For those registered in FY 2021-22, the recommended date is before 30th September 2025.

2. Processing Commencement:
   Though the application is submitted immediately, the processing typically begins after the end of that quarter.
   For example, if you apply on 14th July 2025, the processing will start after 30th September 2025.

3. Documentary Verification:
   The Commissioner of Income Tax (Exemptions) will initiate verification and request supporting documents such as:

   • MOA / Trust Deed

   • Audited Financials

   • Activity Reports

   • Details of Donations

   • Bank Statements

   • FCRA Registration (if applicable)

   This verification generally occurs within 6 months after the quarter-end, ensuring that approvals are processed before 31st March 2026. This approach allows uninterrupted continuity of registration.

Role of the CIT (Exemptions) – Prepare Diligently

The application for 12AB and 80G renewal is made before the Commissioner of Income Tax (Exemptions), who functions as the last fact-finding authority under the Income Tax Act.

There is no explicit procedure in the Act detailing how the CIT conducts documentary verification or hearings, but it is standard practice that the CIT office will seek evidence of charitable activity and compliance.

Best Practice:

Submit complete and accurate documents during the renewal process. If your application is rejected or disputed at a later stage, your record before the CIT (Exemptions) becomes key evidence before appellate forums like the Income Tax Appellate Tribunal (ITAT).

Final Thoughts – Do Not Delay

The consequences of missed or rejected renewal applications can be severe—loss of exemption status, taxation of donations, and potential damage to donor trust.

Therefore:

• Treat 30th September 2025 as the deadline.

• Do not assume automatic 10-year validity; apply as per the current 5-year expiration.

• Prepare documents well in advance.

• Treat your submission to the CIT (Exemptions) as a critical compliance milestone.