Photo of Sreetama Sen

Sreetama Sen

Partner in the General Corporate Practice at the Delhi NCR office of Cyril Amarchand Mangaldas. Sreetama’s practice area covers areas of corporate commercial laws including acquisitions, private equity, joint ventures and business transfers. She has also worked on advising clients on day to day compliance for business operations, regulatory issues, FCRA matters and undertakes drafting and review of operational contracts. She works extensively in the hospitality sector and has undertaken acquisition deals across varied sectors of education, technology, and energy. She can be reached at sreetama.sen@cyrilshroff.com

Regulator’s Gaze over Unutilised Foreign Contributions of NGOs

Summary: As per the recent reports, the Ministry of Home Affairs has issued show cause notices to several NGOs registered under the Foreign Contribution (Regulation) Act, 2010, asking why their registrations should not be cancelled in cases where foreign contributions have neither been received nor utilised for three consecutive financial years. While prolonged non-utilisation may, in the regulator’s view, raise questions on an organisation’s bona fide intent, the development has sparked debate on whether non-utilisation of foreign funds alone can justify cancellation, particularly where NGOs continue to pursue their objectives through other lawful means.Continue Reading Regulator’s Gaze over Unutilised Foreign Contributions of NGOs

FCRA Renewals: Evolving Realities and Key Takeaways

The process of renewing registrations under the Foreign Contribution (Regulation) Act, 2010 (“FCRA”), has been subject to heightened regulatory scrutiny, as the Ministry of Home Affairs focuses on stricter compliance and oversight. While aimed at enhancing transparency and accountability in the receipt and utilisation of foreign contributions, recent trends reveal recurring practical challenges, from procedural delays and unclear transitional guidance to discretionary refusals and non-speaking rejection orders. Some High Courts and the Supreme Court have also weighted in recently on this matter, highlighting the need for a balanced regulatory approach that safeguards national interest while facilitating FCRA registered entities to operate with continuity and confidence within a structured and reasonable compliance framework.Continue Reading FCRA Renewals: Evolving Realities and Key Takeaways

Introduction

The Foreign Contribution (Regulation) Act, 2010 (“FCRA”)[i], regulates the flow and use of foreign funds by individuals, associations, and organisations in India. Over time, the regulatory framework under FCRA has evolved, introducing several compliance obligations for entities receiving foreign contributions. In April 2025[ii], a key amendment was introduced concerning the validity of prior permissions. To strengthen the FCRA regime further, the Ministry of Home Affairs (“MHA”) notified amendments to the Foreign Contribution (Regulation) Rules, 2011 (“FCR Rules”)[iii], on May 26, 2025 (“May 2025 Amendments”)[iv]. These amendments bring important changes to the registration, prior permission, renewal processes, and other post-registration compliances.Continue Reading FCRA Compliance Tightened-Understanding the May 2025 Amendments to FCR Rules