Transfer of Funds between registered organisations – Dept. to clarify

As many of the readers of these posts would be aware that new Rule 24 alongwith Form FC10 of FCRA provisions, has made it mandatory for all registered organizations to obtain permission of the FCRA department before transferring funds to other registered organizations. This caused genuine concern and anxiety.

The matter was immediately taken up by Socio Research & Reform Foundation (SRRF) with Shri GVV Sarma, Joint Secretary, incharge of the Department alongwith representatives of a few of such organizations.  They explained their problems particularly that most of them were having almost 100 or more partners and many of them transfer these funds on a regular basis (even monthly) to other registered NGOs.

Shri Sarma heard the delegation patiently and stated in clear terms that the intention of the Act is not to cause any unnecessary inconvenience. He understood the problem and suggested that such organizations could give the details through a letter indicating the organizations and amounts to be transferred even for a whole year. He indicated that the department was already in the process of developing a suitable system for online application for the same. However the organizations further explained that if the permissions were not given within a time bound manner, than the funds down the line for various activities would dry up and would hamper the development activities of various NGOs. It was also pointed out that the Rule is inconsistent with Section 7 of the FCRA Act 2010.

SRRF also submitted a written representation offering several alternative solutions. (See attached letter submitted to the Dept.)

The Joint secretary promised to immediately look into the issue to find solution and if required the dept. would issue necessary clarification through its web-site.

SRRF and all the representatives of donor agencies thanked Mr Sarma, the Joint secretary for his promptness in meeting the delegation.

Socio Research Reform Foundation
(A Non Government Organisation)
512 A, Deepshikha, 8 Rajendra Place, New Delhi – 110008
Tele/Fax: +91-11-25821088, 25817157, 25722044

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21 Responses to Transfer of Funds between registered organisations – Dept. to clarify

  1. As a Newbie, I am continuously browsing online for articles that can benefit me. Thank you

  2. Jayesh Joshi says:

    Dear Mr. Subhash Ji,

    Greetings from VAAGDHARA!!

    I would like to appreciate & express sincere gratitude, for putting your efforts in the context of new rule 24 along with FORM FC-10 provision. It’s a matter of happiness for all of us that MHA have considered this important initiative at correct time.

    Kindly provide update regarding releasing of the official communication from MHA.

    With best wishes.

    Jayesh Joshi

  3. T Balasubramanian says:

    Dear ALL,

    As there is no official communication as yet I only hope it is not too early to enjoy the relief given by MHA.

    Best wishes,

  4. Subhash Mittal says:

    Dear Bharat,

    You have raised some important issues and hence I am sharing this with other members of SRRF Dialogue. Hope this will be OK with you.

    Regarding your very pertinent observations, all I can say is that these are now a fact of life. As you have seen we all are now struggling to have some of the more perverse after-effects of Rule 24(2) be mitigated. I am sure change will not come by efforts of anyone individual / group, it will come because the Govt. realizes that sector is strong and unwanted provisions cannot be imposed. That is why efforts have to be made by all (whether individuals, organizations or Groups).

    I would like to leave the other points raised by you for the group members to respond and discuss.

    warm regds
    subhash mittal

  5. Pinto says:

    Dear All,

    Any clarifications received from MHA,


  6. narendra chand says:

    Dear Mr. Mittal,

    It is great news for all of us.

    Narendra Chand

  7. Harsh Jaitli says:

    Dear all

    We are taking up the case with ministry to get official commitment from them. So just wait for few days.


  8. L N Sharma says:

    Dear Sir,

    Great news, thank you so much.

    Best regards,
    L N Sharma
    Finance & Administration
    Consumer Unity & Trust Society (CUTS)

  9. T Balasubramanian says:

    Dear Subhash,

    I have forwarded this mail to India Finance team for them to participate in the discussion.

    Best wishes,

  10. T Balasubramanian says:

    Dear Subhash,

    As we go through the rules and find that each transfer transaction to local NGO who have FC registration have to be routed through Ministry after due permission we hereby feel that this will cause considerable hardship. Our organisation works with at least 90 NGOS in India and the implementation of the projects in India is done by these NGO’s who have valid registration with FC authorities. For this we need to transfer the funds to these NGO’s on regular basis @ at least once in 2 months. This would mean 180 such transfers which would require prior permission before the transfer. Many of these transfers are for Cataract surgeries done on reimbursement basis which means those NGO’s to whom we intend transferring funds have already incurred expense and they are waiting for our transfer for reimbursement. This means there would be delay in transfer if the permission does not come in.

    In view of this hardship we strongly feel that the rule 24 should be amended as the transfer of funds takes place only to those NGO’s which are having valid FC registration and are filing regular returns with Ministry of Home Affairs.

    We hope our views would be put up with FCRA authorities. Also let me know which is the best way to address separately this issue?

    Best wishes,
    Regional Finance Manager
    Sightsavers- India Region

  11. Jagdeep Kakkar says:

    Dear Mittalji,

    Thank you very much for providing information on FCRA, which is really helpful and hope you would continue to send us more information on the above subject.

    With kind regards
    Jagdeep Kakkar

  12. Lourdes Baptista says:

    Great job and thanks for the update. We look forward to some more clarification and understanding as to how to take things forward.


  13. Surat Sandhu says:

    Hi All,

    Lest it be mistaken, we intend to thank the entire team. It is only bcoz of your joint efforts that the sector has reached where it has. There is no doubt a long way yet to traverse but it is such actions that will bond us all and assist in taking the THIRD SECTOR to where it belongs.
    Congratulations once again.

    Surat Sandhu

  14. Shubhro Roy says:

    Thanks! Subhash Ji. Point well taken.


    Shubhro Roy
    Programme Manager (Administration)
    National Social Watch Coalition
    New Delhi

  15. Virendra Chaubisha says:

    Re: Re: [srrf-dialogue] Fw: FCRA : Transfer of Funds between registered organisations – Dept. to clarify

    Thanks to inform for FCRA act.

    virendra choubisa
    Program Manager

  16. Harsh Jaitli says:

    Re: [srrf-dialogue] Fw: FCRA : Transfer of Funds between registered organisations – Dept. to clarify

    Dear all,

    Greetings from VANI!

    It is to inform you that transfer from FCRA holding organization to FCRA organization does not require any permission from MHA. VANI and FMSF will post detail of this on Monday. And also MHA will put its clarification on its website shortly.

    In case you have any specific question please write to me.
    Harsh Jaitli

  17. Subhash Mittal says:

    Dear Freinds,

    Thankyou so much, but I must share the credit with some other e-group freinds who actively participated in the process. Namely

    Ashok Seth, Plan India
    KRP Kosala, CASA
    Pallavi Chaturvedi, Save the Children Fund
    Geetha Nair, Charities aid Foundation
    Deepak Bansal, Chartered Accountant

    In addition to the representation made by SRRF, I would request that each one of us should write independently to the Dept., since our representation is just one and only if more representations go to the Dept. they will realise the severity of the problem.

    As one of the group member, Martin Pinto, just mentioned that the matter was brought to the Joint Secretary’s attention at the Vani’s meet, still the rule went unchanged. SRRF also brought the illegality aspect of the said rule both through our written Representation letter as well as in person (even the Joint Secretary acknowledged the same), however the problem persists. So once again I request that all of us who are affected by the rule (both NGOs & funding agencies) should write to the Dept. on how it is impacting them.



  18. Ahmad Ali says:

    RE: [srrf-dialogue] Fw: FCRA : Transfer of Funds between registered organisations – Dept. to clarify

    Thanks u so much.


    Ahmad Ali
    Finance officer

  19. nilam sompura says:

    Re: [srrf-dialogue] Fw: FCRA : Transfer of Funds between registered organisations – Dept. to clarify

    Great job- update time to time

    Nilam Sompura

  20. Surat Sandhu says:

    Re: [srrf-dialogue] Fw: FCRA : Transfer of Funds between registered organisations – Dept. to clarify

    Great job-Needs urgent clarification.

    Surat Sandhu

  21. Amita Puri says:

    RE: [srrf-dialogue] Fw: FCRA : Transfer of Funds between registered organisations – Dept. to clarify

    Thank you. This was a really needed intervention.


    Amita Puri
    CEO, CAF India

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