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Society / NGO Compliance

Society Annual Compliance in India: Registrar Returns, ITR-7, and 12A/80G for FY 2025-26

By Tradeviser Editorial • Updated October 2026 • 10 min read

A society registered under the Societies Registration Act 1860 (or its state equivalents) operates on two parallel compliance tracks: state-level filings with the Registrar of Societies, and central filings with the Income Tax Department. Unlike a company, there is no single national regulator — the Registrar’s office, deadlines, return formats, and penalties differ from state to state.

This guide brings together both tracks: what to file, when, and where, for societies operating under the central Societies Registration Act 1860 as well as the major state variants (Maharashtra, Karnataka, Delhi/Rajasthan). Income tax obligations under Section 11/12 and the 12A/80G renewal cycle are also covered.

Governing law: Societies Registration Act 1860 (central, applicable in most states) or state-specific Acts (Maharashtra Public Trust Act 1950; Karnataka Societies Registration Act 1960; West Bengal Societies Registration Act 1961). Income tax: Sections 11-13, 12A, 12AB, 80G of the Income Tax Act 1961. FCRA: Foreign Contribution (Regulation) Act 2010.

Key Takeaways

  • Annual Return to the Registrar of Societies is mandatory every year — deadline and format vary by state
  • File ITR-7 by 31 October 2026 (audit required if gross income exceeds Rs. 2.5 lakh)
  • Form 10B (income above Rs. 5 crore or FCRA) or Form 10BB (others) is filed before ITR-7
  • 12A and 80G must be renewed every 5 years using Form 10A — apply 6 months before expiry
  • Form 10BD (donor statement) due 31 May; Form 10BE issued to donors after
  • Governing body elections must be held as per the society’s Memorandum/Bye-laws — lapsing quorum can trigger deregistration

Registrar of Societies: state-wise annual return requirements

Every registered society must file an annual return with the Registrar of Societies in its state. The return typically includes: (a) list of current office bearers and managing committee members, (b) audited accounts for the prior financial year, and (c) a declaration that the society continues to function for its stated purposes.

State / Union Territory Governing Act Annual Return Deadline Key Notes
Maharashtra Maharashtra Public Trust Act 1950 + Societies Registration Act 1860 Within 6 months of FY end (by 30 September) Charity Commissioner (not Registrar); Form Schedule VII; trusts and societies both covered
Karnataka Karnataka Societies Registration Act 1960 Within 3 months of AGM (by 30 September for June AGM) List of committee members + audited accounts; filed at Sub-Registrar’s office
Delhi / UP / Rajasthan / Haryana Societies Registration Act 1860 14 days after AGM; list of members filed annually Simple list of members; accounts filed separately; Registrar of Firms, Societies and Chits
Tamil Nadu Tamil Nadu Societies Registration Act 1975 Within 14 days of AGM Audited accounts within 180 days of FY end
Gujarat Societies Registration Act 1860 (Bombay adaptation) Within 3 months of AGM Registrar of Societies; full accounts and list of office bearers
State variations are significant: The central Societies Registration Act 1860 requires only an annual list of managing committee members (Section 4). But many states have amended this to require audited accounts, annual reports, and Charity Commissioner filings. Always check the specific state Act and the local Registrar’s office circular for the current year’s deadline.

Annual General Meeting and governing body elections

The AGM is the cornerstone of society governance. Most state Acts require the AGM to be held within 6 months of the financial year end (by 30 September for April-March FY). The interval between two consecutive AGMs must not exceed 15 months.

Key business at the AGM:

  • Adoption of audited accounts for FY 2025-26
  • Annual report on activities and expenditure
  • Governing body/managing committee elections as per Memorandum and Rules of the society (typically every 2-3 years, but ratification at each AGM is best practice)
  • Appointment of auditor for the next year
  • Ratification of decisions made by the managing committee in the prior year
Election lapse risk: If the governing body’s term expires and elections are not held, the society’s legal authority to enter contracts, receive grants, or open bank accounts is compromised. Some state Registrars treat such societies as dormant, triggering deregistration proceedings. Hold elections as per the society’s Memorandum — do not allow the term to lapse.

Income tax: ITR-7, Section 11/12 exemption, and audit

A society registered under Section 12A/12AB of the Income Tax Act claims exemption on income applied for charitable purposes under Sections 11 and 12. Income not applied (accumulated beyond permitted limits) or from non-qualifying activities is taxable.

Compliance Item Requirement
ITR form ITR-7 (for entities claiming exemption under Sections 139(4A), 139(4C))
Due date (FY 2025-26) 31 October 2026 (audit applicable); 31 July 2026 (if no audit)
Statutory audit requirement Mandatory if total income before exemption exceeds Rs. 2.5 lakh; in practice, nearly all active societies require audit
Audit form Form 10B if: income exceeds Rs. 5 crore, or FCRA applicable, or receipt from foreign sources; Form 10BB for all others
Verification Signed using DSC (Digital Signature Certificate) of the secretary or principal officer
85% application rule At least 85% of income must be applied towards charitable purposes each year for full Section 11 exemption
Accumulation (Form 10) Remaining up to 15% may be accumulated; more can be accumulated up to 5 years using Form 10 (set aside notice)

12A and 80G renewal: 5-year cycle and Form 10A

From April 2021, the old permanent 12A/80G registrations were converted to provisional 3-year registrations, which were then renewed for 5 years. All societies now operate on a 5-year renewal cycle. Failure to renew causes loss of tax exemption and donor deduction benefits mid-cycle.

Renewal Step Action
1 Check the 5-year expiry date on the 12A/80G certificate (usually printed on the certificate from CBDT/AO)
2 Apply using Form 10A on the income tax portal (incometax.gov.in) at least 6 months before the expiry date
3 Upload required documents: registration certificate, Memorandum/Bye-laws, audited accounts for the last 3 years, activity report, PAN
4 Processing by Jurisdictional Commissioner of Income Tax (Exemptions); may request additional documents or interview
5 Fresh 5-year certificate issued; update 80G number with regular donors
Apply early: The 6-month window is a minimum. Applications filed close to the expiry date can leave the society without a valid 12A/80G for a period if processing is delayed. Donors who contributed during a lapsed 80G period cannot claim deductions on those contributions.

Form 10BD donor reporting and Form 10BE

Societies with 80G registration must submit a statement of all donations received during the year that were claimed under 80G by donors. This is Form 10BD, due annually by 31 May.

  • Form 10BD (due 31 May 2026 for FY 2025-26): Report each donor’s name, PAN, address, amount, and mode of donation
  • Form 10BE: After filing 10BD, generate and issue Form 10BE certificates to each donor; this certificate is what the donor uses to claim their 80G deduction in their own ITR
  • Form 10BE must be issued by 31 May (same deadline as 10BD)
  • Donors cannot claim 80G deductions without a valid Form 10BE from the society

Annual compliance checklist for societies

Task Due Date (FY 2025-26) Authority
Form 10BD (donor statement) 31 May 2026 Income Tax
Form 10BE issued to donors 31 May 2026 Income Tax
Annual General Meeting By 30 September 2026 (most states) Registrar of Societies
Annual Return to Registrar of Societies Within 14-90 days of AGM (state-specific) Registrar of Societies
Charity Commissioner return (MH/GJ/RJ) By 30 September 2026 Charity Commissioner
Form 10B or 10BB (audit report) Before ITR-7 filing Income Tax
ITR-7 (income tax return) 31 October 2026 Income Tax
FCRA FC-4 (if FCRA registered) 31 December 2026 MHA / FCRA portal
12A/80G renewal (Form 10A) 6 months before certificate expiry Income Tax

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Frequently Asked Questions

Does a registered society need to file annual returns with the Registrar of Societies?

Yes. Every registered society must file an annual return with the Registrar — typically the list of current managing committee members plus audited accounts. The format and deadline vary by state (14 days post-AGM in Delhi; 6 months after FY end in Maharashtra via Charity Commissioner).

Which ITR form does a society file?

ITR-7. Due 31 October 2026 if the society’s gross income exceeds Rs. 2.5 lakh (audit required). Form 10B or 10BB (audit report) must be filed before ITR-7 is submitted.

Is AGM mandatory for a society?

Yes. AGM must be held annually (within 15 months of the previous AGM). The AGM elects/ratifies the governing body, approves accounts, and is the basis for the annual return filed with the Registrar.

What happens if a society does not file its annual return?

The Registrar may issue a show-cause notice, impose penalties, or cancel the society’s registration. Cancelled registration invalidates 12A/80G status. In most states, once cancelled, re-registration (not restoration) is the only remedy.

What is the difference between 12A and 80G registration?

12A exempts the society’s own income from tax. 80G allows donors to claim a deduction (50% or 100%) on their contributions. Both must be renewed every 5 years using Form 10A; 80G requires 12A as a prerequisite.