Reform in charitable trust reporting: from Forms 10B and 10BB to Form 112 from 2026

India’s non-profit reporting system shifts from a dual-form framework to a unified Form 112 from April 2026, marking a significant overhaul in how charitable organisations fulfil audit and compliance requirements.

For charitable and religious trusts, the key compliance question has long been which audit report applies: Form 10B or Form 10BB. According to the Income Tax Department’s guidance, the answer under the Income-tax Act, 1961 depended on whether a trust or institution crossed the ₹5 crore income threshold, received any foreign contribution, or applied any part of its income outside India. From Assessment Year 2023-24 onwards, those tests were used to separate the two forms, with Form 10B covering the prescribed trigger cases and Form 10BB applying where none of them was met.

That framework matters because it is not just a matter of size. Even a relatively small trust could fall into Form 10B if it received any foreign contribution or spent income abroad, which meant organisations had to review bank records, donation receipts and overseas expenditure before deciding on the correct filing. The department’s user manual also makes clear that Form 10B was an online audit report, required before the income-tax return deadline and filed through the e-filing portal with the accountant’s digital signature.

The bigger change is the new regime from 1 April 2026. Under the Income-tax Act, 2025, the earlier two-form system has been replaced by Form 112, which the department describes as a common audit form for registered non-profit organisations. EaseValue’s summary of the new framework notes that the change applies from Tax Year 2026-27 onwards, and that the relevant test is the tax year to which the compliance relates, not simply the date the form is filed.

This is not just a cosmetic renumbering. Form 112 is governed by Section 348 of the new Act and is meant to consolidate reporting for registered non-profits, with schedules that can vary depending on the organisation’s classification. Under the updated guidance, a small registered non-profit organisation is one that meets all three thresholds in the relevant tax year: regular income not exceeding ₹5 crore, foreign contribution not exceeding ₹10 lakh, and income applied outside India not exceeding ₹10 lakh. That is a material shift from the old rule, where any foreign contribution or any overseas application of income could push an organisation into Form 10B.

For trusts working through the transition year, the distinction between financial year, assessment year and tax year is crucial. Income earned from 1 April 2025 to 31 March 2026 continues to fall under the Income-tax Act, 1961 and is assessed as Assessment Year 2026-27, so the old Form 10B and Form 10BB rules still apply there. Income earned from 1 April 2026 onwards is covered by the Income-tax Act, 2025 and must be reviewed under the Form 112 framework instead. In practice, that means the compliance test changes according to when the income arose, not merely when the accounts are finalised.

The filing process also remains document-heavy. Before submitting the relevant report, organisations should reconcile audited accounts, bank statements, donation records, foreign contribution records, overseas expenditure, registration papers and, where applicable, FCRA documents and AIS and TDS information. The department’s Form 10B manual shows how much depends on accurate portal access and proper authorisation, while the new Form 112 guidance says the report is filed electronically and, once acknowledged, cannot be edited. For non-profits, that makes advance review and classification just as important as the filing itself.