12A/12AB and 80G Registration for NGOs: Tax Registration and Donor Approval

The familiar 12AB/80G terminology now sits inside the current Income-tax Act, 2025 framework. Use this guide to check provisional and regular application routes, existing orders, object changes and donation-reporting obligations.

12A vs 80G: what each registration is for

The short version. “12A” and “80G” are the old names. Since the Income Tax Act, 2025 came in “effective 1st April 2026”, registration of a non-profit organisation is under section 332 and donor approval under section 354. The e-Filing portal describes Form 105 as the “Application for registration of non-profit organisation under section 332 or approval for deduction under section 133(1)(b)(ii)”.

12A (now section 332) – the NGO’s own registration. In the portal’s words, regular registration “enables a non profit organisation to continue availing tax exemptions”.

80G (now section 354) – for your donors. Approval under section 354 is what makes donations “eligible for deduction under section 133(1)(b)(ii)”. The portal adds that regular registration or approval “permits donors to claim deduction for eligible donations”.

In plain words: one is about the NGO’s own income, the other about the donor’s deduction. Donors – a company’s finance team in Mumbai or a family in Guwahati, for example – may ask for your 80G approval before they give (illustrative only).

For the donor’s side, see what donors should check before claiming an 80G deduction.

For your NGO’s own yearly donation reporting, see our guide to Forms 113 and 114 (formerly 10BD and 10BE).

Source: Income Tax e-Filing portal pages for Forms 104–107 and 113–114, checked 21 Oct 2026.

Templates for this work: NGO Tax Compliance Evidence Pack · NGO Donation Receipt & Donor Register Pack (for Form 113/114 records) · NGO Finance Controls & Audit Readiness Pack

Two purposes and the current law

An organisation’s exemption registration and approval connected with donor deductions answer different questions. Section 332 is the NPO registration route for claiming the benefits of the relevant Part of the Act. Section 354 deals with approval for deductions under section 133(1)(b)(ii). Neither a registration application nor an organisation’s legal formation alone establishes that all its income is exempt or every donor can claim a deduction.

The Income-tax Act, 2025 generally commenced on 1 April 2026. The older 12A/12AA/12AB and 80G descriptions remain useful when identifying existing orders and the service people are seeking. Do not discard those documents or automatically start a fresh application because the terminology changed. Valid existing registrations and approvals, earlier-year matters and pending proceedings must be assessed under the applicable saving and transition provisions.

First identify the legal applicant and the purpose of the engagement. Public trusts, registered societies and Section 8 companies are among the structures recognised for the NPO registration route; specified other institutions have their own treatment. The structure’s name does not itself satisfy the purpose, public-benefit and other statutory conditions. An unformed project, uncertain legal identity or special institution needs a preliminary structure and eligibility review.

First applications and existing status

For a first registration, whether activities have started matters, and the exemption route also asks whether registration has been held before. A genuinely first-time applicant that has not commenced activities has a different route from an organisation already operating. An old registration that expired, became inoperative or was cancelled should not be hidden by selecting a fresh-applicant option.

Form 104 is the current provisional application and Form 105 is the current regular application, as applicable to registration, approval or both. Form 106 and Form 107 are the respective outcome orders. They are not forms the customer buys as additional applications, and the form numbers do not divide the work into one form for exemption and another for donor approval. The selected section and application category must match the facts.

The official Form 105 guidance allows a common application seeking both section 332 registration and section 354 approval, with separate Form 107 orders. The two requests can have different outcomes. For donor-approval work, the current manual also accommodates an existing relevant registration, a pending section 332 application or a combined request. That does not justify filing unnecessary exemption work where the organisation already holds the appropriate valid registration.

Validity, renewal and changed objects

Keep a separate record of each registration or approval number, the issuing provision, effective period, expiry and any conditions. Where provisional status is held, activity commencement can trigger a regular-application requirement before the printed provisional period ends. A three-tax-year provisional period should not be read as permission to ignore a conversion trigger after activities start.

The current sections provide a six-month filing trigger after activities commence for the provisional-to-regular cases, and an at-least-six-months-before-expiry requirement for the relevant expiry cases. Section 332 also provides a thirty-day trigger for an object modification that does not conform to the conditions of registration. These are route-specific statutory reference points. Review the actual order, commencement/change date and transition position before fixing an organisation’s deadline.

The ten-year registration provision is narrower than a general small-NGO benefit. Section 332(5) applies to specified conversion, renewal, reactivation and object-change cases, with total income calculated without the relevant Part’s benefits not exceeding ₹5 crore in each of the two preceding tax years. It is not a gross-receipts test or an automatic ten-year term for every first regular application. Regular donor approval under section 354 remains five tax years; an extended registration period does not extend that separate approval.

Conditional records and activity evidence

Prepare the governing instrument or other creation evidence, applicable legal-registration certificate, PAN and the relevant existing orders. Copies described as self-certified in the prescribed form should be checked by the applicant before submission. Keep rejection, cancellation, withdrawal or pending-application records visible where relevant; leaving out an adverse history can send the preparation down the wrong route.

For an operating organisation, connect its activity note with the actual programmes and accounts. The Form 105 notes call for annual accounts for the relevant available preceding period, up to three years where applicable. They do not require a new organisation to manufacture three years of history. Identify missing records and periods clearly. A not-yet-operating applicant should provide an honest proposed-activity position rather than describe planned work as completed.

Use the conditional evidence that fits the case. FCRA registration evidence is relevant where held; it does not mean that every applicant must obtain FCRA first. A qualifying object-change case needs its actual amendment evidence. Business-related accounts or audit material apply to the relevant business branch. Bank, institution, property and office-bearer information fields do not turn every cancelled cheque, landlord NOC or Aadhaar copy into a universal attachment.

Donor conditions and adverse cases

Donor approval needs its own substantive review. Section 354 addresses charitable establishment in India, beneficiary restrictions, the destination of assets, accounts, religious expenditure and donation reporting. A public religious-purpose registration under the NPO framework does not automatically establish eligibility for donor approval. Explain the actual activities and spending to the reviewer; do not rely on a single description such as charitable or religious to settle every condition.

Where records show commercial activity, restricted beneficiaries, a change in objects, inconsistent accounts or an adverse order, agree the professional work needed before submission. NGOGrant can organise records and coordinate the response, but an unsupported declaration cannot be repaired by filling more fields. A registration or approval order is also not a certificate that every later receipt, expenditure or donor claim will receive the intended tax treatment.

Late filing, rejection, cancellation, withdrawal and restoration require individual review. Section 332 has a discretionary delay-condonation provision, and the current operational manual limits its condonation option to that section. Do not assume the same remedy is available for section 354 donor approval. Do not withdraw an appeal, surrender an order or make a repeat application simply because a checklist suggests another route; the legal consequences and current portal availability must be checked.

Verification, orders and annual handover

Rule 181 provides electronic filing and verification by the person authorised to verify the applicant’s income return. The DSC/EVC route depends on the applicable requirement; a DSC is not universally required for every applicant. Separate audit reports, professional opinions and representation retain their own responsibilities. The applicant approves factual records and declarations, and passwords, OTPs, donor identifiers and signing credentials stay out of the public enquiry.

Before submission, review the applicant, selected section, application category, activity dates, order history and attachments together. Retain the filed copy and acknowledgement and assign responsibility for notices and queries. The Department’s examination can require further information and can result in a different decision for each request. No government approval period or successful outcome is promised by NGOGrant.

After the decision, read each actual order and record what was granted, its period and any outstanding matter. A Form 105 acknowledgement is not a Form 107 approval. Plan accounts, audit, income-tax returns and donation reporting separately. The current donation statement/certificate forms are 113 and 114; those are later reporting work, not registration applications or approval orders, and are included only if expressly engaged.

Form 104 — provisional application

Used for the applicable provisional registration/approval route. Existing history and activity facts must support the selected category.

Form 105 — regular application

Used for applicable regular registration or approval work, including relevant conversion and renewal cases. One request can cover both purposes.

Form 106 — provisional order

An outcome record issued through the statutory process. It is distinct from the application and filing acknowledgement.

Form 107 — regular order

The outcome of regular-application work. A combined request has separate registration and approval orders to review.

How our 12A/12AB and 80G registration support works

• 1 Identify the requested benefit Choose exemption registration, donor approval or both. Confirm that the work is an application rather than annual reporting or an appeal.

• 2 Read the existing history Review orders, pending filings, commencement, expiry and changed objects. Determine the applicable current or legacy treatment.

• 3 Settle the route and evidence Confirm the relevant section and application category, eligibility questions, supporting copies and any professional work.

• 4 Prepare and obtain applicant approval Reconcile governing documents, activities, accounts and declarations. Agree the authorised DSC/EVC verification arrangements.

• 5 Submit and monitor the agreed work Retain the filing copy and acknowledgement, review communications and handle only the follow-up included in the engagement.

• 6 Check each order and plan ongoing work Record the actual registration and approval decisions separately, including effective periods. Assign later return, audit and donation-reporting responsibilities.

Who prepares, verifies and decides a 12A/80G application

LendLink Tech Private Limited organises information and coordinates the agreed work. Under Rule 181, the application is verified by the person authorised to verify the applicant’s income return, using DSC or EVC as applicable. This is different from an accountant certifying an audit report. The engagement must identify who advises on the route, who verifies the application and who performs any separately required professional act.

NGOGrant does not present itself as the Income Tax Department, a CA firm or a law firm. Appropriately qualified professionals handle reserved opinions, certification or representation within their engagement; the competent authority decides registration and approval. Applicants remain responsible for truthful facts and authorised signing.

12A/12AB and 80G FAQs

They are the familiar names many organisations use for their existing documents and requirements. The current Income-tax Act, 2025 routes concern section 332 registration and section 354 donor approval. The application must use the provision and form appropriate to its facts, while old orders and pending proceedings retain their relevant transition treatment.

No. Registration concerns the organisation’s NPO tax framework; donor approval concerns a separate deduction-related approval. The organisation and each donor must still meet the applicable conditions. Approval of one does not mean the other was granted.

Can we apply for 12A and 80G together?

Yes, at both stages. For provisional registration, the e-Filing portal says Form No. 104 “is a common form for both: the Applicant files a single Form No. 104, and the CIT (CPC) passes separate orders”. For regular registration, it says “Form 105 is a consolidated application form that covers both registration… and approval”.

How do I get 12A and 80G online?

Both are applied for on the Income Tax e-Filing portal. The portal says “Form No. 104 is an online application form available on the e-filing portal” for provisional registration or approval; Form 105 is the regular application. The orders are issued on Form 106 (provisional) and Form 107 (regular).

How long is a provisional 12A/80G registration valid?

Under the Income-tax Act, 2025, provisional registration (section 332(3), Table Sl. 1) and provisional approval (section 354(2), Table Sl. 1) are each valid for three tax years. Once activities start, the Act requires the regular application in Form 105 within six months of commencement (Table Sl. 3 of each section), so do not wait for the three years to run out.

The current regular-application manual accommodates existing relevant registration, a pending section 332 application or a combined request. Rejected, withdrawn or cancelled status needs a separate review. This does not mean that every applicant is eligible or that donor approval is automatic.

Form 104 is the provisional application; Form 105 is the regular application, as applicable. Form 106 and Form 107 are outcome orders. The section and application category must match activities, prior history and the requested work. Do not select a form from the old service name alone.

First review prior registration history and the exact statutory category. A genuinely first-time, not-yet-operating organisation differs from an existing provisional holder nearing expiry or an organisation with an adverse order. The checklist does not turn a not-started answer into automatic eligibility.

No automatic fresh application is recommended solely for the change in law. Keep existing orders and pending-application records and have their validity, conditions and saving provisions reviewed. Transition does not revive an expired deadline or erase a cancellation.

Review activity commencement and the existing order promptly. The current provisions include a filing trigger within six months of commencement for the relevant provisional-to-regular case. Do not wait for the printed provisional expiry if an earlier trigger applies.

The current provisions require filing at least six months before expiry for the relevant renewal/expiry cases. Establish the actual period and which benefit is expiring first. This page does not calculate a personal deadline or assume that registration and donor approval expire together.

No. Section 332’s ten-year provision is limited to specified routes and an income test using each of the two preceding tax years. It is not a blanket gross-receipts rule or an automatic first-registration benefit. Regular section 354 donor approval remains five tax years, so its renewal may still need attention earlier.

Do not invent records for years in which it did not exist. The prescribed regular-application notes refer to available accounts for the relevant preceding period, up to three years where applicable. The actual period, audit requirement and supporting history must be reviewed for the case.

No universal combined attachment list is prescribed by this page. The current Form 105 treats several records as conditional; FCRA evidence is relevant where held, and office-bearer identity fields have alternatives. Confirm the exact application requirements instead of copying a general checklist from another service.

The purposes and conditions of NPO registration and donor approval differ. Section 354 has its own beneficiary and religious-expenditure conditions. Describe the actual objects, activities and spending for review rather than assuming that either all religious organisations qualify or all are excluded from every route.

Arrange prompt case review using the actual filing, communication and order history. Section 332 permits discretionary condonation in the stated circumstances; the current manual does not extend that option generally to section 354. Appeals, withdrawal, repeat applications and cancellation remedies must not be chosen from a generic checklist.

Rule 181 assigns verification to the person authorised to verify the applicant’s income return and provides DSC/EVC according to the applicable requirement. It does not make every application a universally CA-certified filing. Separate audit or professional work must be identified on its own basis.

Preparation depends on records, route review and applicant verification. Departmental examination and queries are separate from NGOGrant’s work schedule. No approval date or success guarantee is offered; the quotation should identify the follow-up responsibility.

No. The approval, donation, reporting and donor’s applicable tax conditions must all be considered. This service does not promise a deduction percentage or calculate a donor’s claim. Confirm the applicable status and records before making statements to donors.

Only if expressly agreed. Registration applications and orders are different from annual income-tax, accounts, audit and donation-reporting work. The current donation statement and certificate are Forms 113 and 114; their preparation belongs in a separate recurring scope such as NGO Annual Compliance.

Official sources for 12A/12AB and 80G

Read the actual order and applicable law alongside the current instructions. The statute controls where an explanatory FAQ compresses a condition or contains an editing error. Documentary guidance does not establish that every portal option is operational or that a particular applicant meets the conditions.

Income Tax Department — section 332, current 2026 text

Registration categories, commencement and expiry triggers, and the limited ten-year provision. The threshold uses total income without the relevant Part’s benefits in each of two preceding tax years, for the specified routes.

Income Tax Department — section 354, current 2026 text

Separate donor-approval conditions, provisional and regular routes, and five-tax-year regular approval. Registration and approval do not automatically share a validity period.

Income-tax Act, 2025, as amended by Finance Act 2026

Sections 1, 332, 355 and 536 support the commencement, registration and legacy-transition discussion. Existing orders and pending proceedings require their own review.

Income-tax Rules, 2026 — Rule 181

Controls the application/order mapping, electronic verification and conditional correction or repeat-application provisions. A provision does not establish that every portal feature is currently operational.

Prescribed Form 105 and application notes

The current regular application, category selection and conditional supporting records. Available accounts, prior orders, business records, FCRA and object-change evidence must fit the actual case.

CBDT — Form 104 guidance

Supports provisional-route preparation. The complete prescribed attachment form was not retrieved for this build; exact current attachments remain subject to review. The statutory conversion trigger controls over compressed guidance wording.

CBDT — Form 105 FAQs

Confirms a common regular application can seek both purposes with two separate Form 107 orders. The statute controls validity conditions where explanatory wording is broader.

Official e-Filing — Form 105 and 107 user manual

Explains existing, pending and combined registration context for donor approval, section 332-only condonation and applicable DSC/EVC. Taxpayer-specific options and repeat-application availability have not been tested.

CBDT — Form 113 and 114 FAQs

Distinguishes donation statements/corrections and donor certificates from registration applications and approval orders. This reference does not establish a complete annual compliance calendar.

Not every grant asks for 12A or 80G. Two government schemes whose rules do not list them as conditions: the Mizoram grant-in-aid for voluntary organisations and the NCPUL seminar grant for Urdu events. Always check each scheme’s own rules.

2026 verification note

The Income Tax Department currently identifies Form 104 for provisional registration/approval routes and Form 105 for regular registration/approval under sections 332 and 354, with Forms 106/107 as corresponding orders. Form 113 is the donation statement and Form 114 the donation certificate under the current framework. Preserve valid historical orders and transitions rather than implying that every older approval automatically expired.

Last verified: 22 October 2026 for the practical answers; other legal content last checked 9 October 2026.

Official guidelines and sources

• Form 104 & 106 — Income Tax Department
• Form 105 & 107 User Manual — Income Tax Department
• Form 113 & 114 User Manual — Income Tax Department
• Guide to Income-tax Act 2025 forms