Trust Annual Compliance
A charitable trust keeps its tax exemption only if it files on time every year: the donation statement by 31 May, the audit report and ITR-7, and the renewal of its registration before expiry. For FY 2025-26 the audit report is due by 21 October 2026 and ITR-7 by 21 November 2026. We run the full calendar for you.
What it is
Trust annual compliance is the set of yearly filings a registered charitable trust must make to stay tax-exempt and in good standing. Most of it is with the Income Tax Department: the donation statement, the audit report, the return and the accumulation forms. A trust with foreign funds adds the FCRA annual return, and one taking CSR money keeps its CSR-1 registration current.
FY 2025-26 is still governed by the Income-tax Act, 1961, so the old forms apply: Form 10BD, Form 10B/10BB, Form 9A/10 and ITR-7. From tax year 2026-27, under the Income-tax Act, 2025, they become Forms 113, 112, 108/109 and the new return, filed on the same Income Tax e-filing portal. Registrations valid on 1 April 2026 continued under section 332 until their original expiry.
Who it applies to
You run a registered public trust
Charitable and religious trusts registered under section 12A/12AB, now section 332, whether the deed was registered with a Sub-Registrar or a Charity Commissioner.
You give donors 80G receipts
Trusts that give donors a tax deduction under 80G (now section 354) must also file the donation statement and issue donor certificates.
You take FCRA or CSR funds
Trusts holding an FCRA certificate file FC-4 each year. Trusts with a CSR-1 registration number keep their details current for CSR donors.
Why it matters
Protects the exemption
The audit report and return are conditions of exemption. File them late and the year’s income can be taxed at normal rates.
Protects your donors
Donors’ 80G claims are matched with your donation statement. If you miss it, they lose their deduction and you risk their goodwill.
Protects the corpus
Failing to renew registration in time can attract tax on accreted income under section 352, at the maximum marginal rate, broadly on the value of the trust’s net assets.
Documents required
Standing papers
- Registered trust deed and any amendments
- PAN of the trust
- 12A/12AB and 80G orders with expiry dates
- FCRA and CSR-1 certificates, if any
Yearly records
- Books of account and all bank statements
- Donor list with names, addresses and PAN
- Project and grant details
- Fixed asset and investment register
Trustee details
- Current list of trustees
- Resolutions passed during the year
- DSC or Aadhaar for e-verification
Annual compliance calendar
| Filing | FY 2025-26 (old Act) | Tax year 2026-27 (new Act) |
|---|---|---|
| Donation statement and donor certificates | Form 10BD / 10BE by 31 May 2026 | Form 113 / 114 by 31 May 2027 |
| Audit report | Form 10B / 10BB by 21 October 2026 | Form 112 by 30 September 2027 |
| Accumulation forms | Form 9A / Form 10 by the return due date | Form 108 / 109 by the return due date |
| Income-tax return | ITR-7 by 21 November 2026 | New return by 31 October 2027 |
| FCRA annual return | FC-4 by 31 December 2026 | FC-4 by 31 December 2027 |
The 21 October and 21 November 2026 dates follow the CBDT extension of 28 September 2026 for assessees whose accounts must be audited. Renewal of registration is not on a fixed date. It falls due at least six months before your current registration expires, so we diarise it from your own order.
Here is the catch. Say an education trust in Ballabgarh holds registration that expires on 31 March 2027. Its renewal had to be filed by 30 September 2026. If that date slipped, the trust should apply now and ask the Commissioner to condone the delay under section 332(4), rather than wait for expiry.
How it works
Build your trust’s calendar
We read your registration orders and note every expiry date. Then each filing for the year goes on one sheet with its due date.
File the donation statement in May
We prepare Form 10BD from your donor register and download the donor certificates for you to send out.
Close the books and get them audited
Our chartered accountants finalise the accounts, check the 85% application and upload the audit report.
File ITR-7 with the accumulation forms
Form 9A or Form 10 goes in first if income was not fully spent, then ITR-7 on the audited figures.
Handle FCRA, renewals and changes
We file FC-4, apply for renewal in Form 105 on time and report any change in objects within the time allowed.
Timelines
Report donations by 31 May
Donation statement and donor certificates for the previous year.
Audit and file for FY 2025-26
Audit report, then ITR-7 with Form 9A/10, for FY 2025-26.
Renew six months before expiry
Renewal of registration in Form 105. Regular registration runs five tax years, or ten where total income without the exemption stayed within ₹5 crore in each of the two preceding tax years.
What happens if a trust misses a filing
A late donation statement costs ₹200 a day
A fee of ₹200 per day under section 234G, a possible penalty of ₹10,000 to ₹1 lakh under section 271K, and donors lose their deduction.
A late audit can cost the exemption
The exemption for the year can be denied. Condonation of delay for Forms 9A, 10, 10B and 10BB is possible under CBDT Circular No. 6/2024, but it is discretionary.
A missed renewal can tax the corpus
Section 352 can tax accreted income at the maximum marginal rate. The Commissioner may condone a delay in applying for reasonable cause under section 332(4).
Frequently asked questions
What are the annual compliances for a charitable trust?
A charitable trust’s main annual compliances are the donation statement by 31 May, the audit report and ITR-7, and the accumulation forms where income was not fully spent. For FY 2025-26 these are Form 10BD, Form 10B/10BB by 21 October 2026 and ITR-7 by 21 November 2026. A trust with foreign funds also files FC-4 by 31 December. We put all of these on one calendar, so nothing slips.
Does a trust registered with the Sub-Registrar file anything with that office every year?
No, a trust whose deed is registered with the Sub-Registrar under the Registration Act, 1908 does not file annual returns there. That is the usual route in Haryana and Delhi, which have no separate public trusts law. Its yearly filings are with the Income Tax Department, plus FCRA and CSR filings if they apply. A deed amendment is itself registered with the Sub-Registrar. We keep the tax side in order and guide you on any deed change.
Is ITR-7 compulsory if the trust’s income is fully exempt?
Yes, a registered trust must file ITR-7 even when its entire income is exempt. The exemption is claimed in the return itself, along with the audit report and any accumulation forms. For FY 2025-26, ITR-7 for audited trusts is due by 21 November 2026, and the belated return deadline is 31 December 2026. We file it on the audited figures well before the date.
When must our trust renew its 12A registration?
Renewal must be applied for in Form 105 at least six months before the current registration expires. Regular registration usually lasts five tax years, and ten where total income without the exemption stayed within ₹5 crore in each of the two preceding tax years. Old 12AB registrations valid on 1 April 2026 run to their original expiry under section 332. We check your order today and diarise the date, so renewal is never a last-minute job.
What if the trust could not spend 85% of its income?
File Form 10 to accumulate the unspent amount for a stated purpose for up to five years, or Form 9A if the income simply was not received during the year. Both go in before the return due date, which is 21 November 2026 for FY 2025-26. Without them, the shortfall below 85% is taxed. Picture a trust that received a large donation on 28 March: Form 9A or 10 protects it. We work this out at year end.
Do trustees need DIR-3 KYC or ROC filings?
No, trustees of a trust do not need DIN, DIR-3 KYC or any ROC filing, because a trust is not a company. Those apply only to Section 8 companies and their directors. A trust’s annual compliance is mainly income-tax, plus FCRA and CSR filings where relevant. If your organisation is a Section 8 company, the ROC calendar applies on top. We tell you at the start exactly which list is yours.
Does a trust need to update NGO Darpan every year?
A trust does not file an annual return on NGO Darpan, but it should update its profile whenever details change, such as trustees, address or registrations. The Darpan Unique ID is needed for grants from Government of India ministries and is asked for in FCRA and CSR-1 applications. An out-of-date NGO Darpan profile can hold up a grant. We update it alongside your yearly filings.
Can you take over compliance for a trust that is already behind?
Yes, we regularly take over trusts with pending filings. We first list what is overdue, then file what can still be filed and apply for condonation where the law allows, such as under CBDT Circular No. 6/2024 for Forms 9A, 10, 10B and 10BB. Say a Faridabad temple trust has not filed returns since 2023: we rebuild the books first. Most backlogs can be cleared with a clear plan.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
Ready to begin?
Send us your trust deed and registration orders, and we will map every filing your trust owes this year.