FCRA Bank Account Advisory

• Receipt Account: Must be opened at SBI Main Branch, New Delhi — IFSC SBIN0000691. This is the only account into which foreign contributions can be received. NGOs cannot change this requirement
• Utilisation Account: Can be at any scheduled bank in India. Foreign contributions transferred from the receipt account can be used from this account for programmatic expenses
• Domestic Account: Completely separate from FCRA accounts — used exclusively for domestic income (Indian donations, government grants, fee income)
• Strict separation: Domestic funds cannot be credited to FCRA accounts. FCRA funds cannot be used to replenish domestic accounts
• Sub-granting restrictions: After the 2020 amendment, organisations can transfer FCRA funds to other FCRA-registered sub-grantees but cannot sub-grant to non-FCRA organisations

• Application to SBI Main Branch, New Delhi — can be submitted by post or in person
• FCRA registration certificate (current and valid)
• Board resolution authorising account opening and naming authorised signatories
• KYC documents of the organisation: PAN, address proof, registration certificate
• KYC of all authorised signatories: PAN, Aadhaar, photographs
• Trust Deed / MOA (certified copy)
• Existing SBI account number (if the organisation already has SBI accounts — conversion of existing account is also an option)
• Timeline: 15–30 working days from complete application submission to SBI
• MFiling Advisory: Document preparation, SBI correspondence, and FC-6 filing on MHA Seva Portal to update bank account details

• Continuing to receive foreign funds in old non-SBI account after the 2020 deadline — violation of FCRA
• Mixing domestic and foreign contribution funds in the same account
• Transferring FCRA funds to non-FCRA registered sub-grantees
• Not updating MHA with new bank account details via FC-6 within 15 days of account change
• Administrative expenses exceeding 20% of total FCRA receipts in a financial year
• Using FCRA account for non-FCRA activities

Each of these violations is a ground for FCRA suspension or cancellation under Section 12(4) of FCRA 2010. MFiling's FCRA advisory service ensures these common compliance gaps are identified and corrected proactively.

Q: Can an NGO use its FCRA utilisation account for domestic expenses too?
No. The FCRA utilisation account must be used exclusively for expenses related to foreign contribution-funded activities. Mixing domestic and foreign contribution expenses in the same account is a violation of FCRA regulations and can trigger MHA inquiry.

Q: What if an NGO already received foreign funds in a non-SBI account after September 2020?
This is a serious FCRA violation. MFiling advises such NGOs to immediately open the SBI FCRA account, stop all future foreign receipts in non-SBI accounts, make full and accurate disclosure in the FC-4 annual return, and consider a voluntary compliance approach to regularise the position before MHA detects the violation.