The Income Tax Act, 2025, effective from 1 April 2026, introduced new section numbers and forms for NGO tax registration. The old Section 12A/12AB system is now covered under Section 332, while Section 80G is covered under Section 354, with donor deductions linked to Section 133(1)(b)(ii). NGOs with these approvals are referred to as Registered Non-Profit Organizations (RNPOs), with new forms including Form 104, Form 105, Form 106, and Form 107 replacing the earlier forms. NGOs with valid Ngo registration before 31 March 2026 continue under the applicable transitional provisions, while the new system mainly applies when an NGO applies afresh, renews, or reapplies after rejection.
Confused About the New Income Tax Act 2025?
Understand how the new NGO tax provisions, including Sections 332 and 354, affect your 12A/80G status, tax exemptions, and compliance requirements.
What Is the Income Tax Act 2025?
The Income Tax Act, 2025 is India's new tax law, replacing the older Income Tax Act, 1961, and it became fully effective from 1 April 2026. For NGOs, it didn't change the basic idea behind tax exemption or donor deductions; it renumbered sections, renamed the registration category, and digitized the forms. If you've heard terms like "12A and 80G," or "RNPO" recently and wondered which one applies now, this guide explains exactly what changed.
Why Did the Government Rename These NGO Tax Sections?
This is not the first major change NGOs have seen. Section 12AA, introduced for registration in 1997, was replaced by Section 12AB in 2021 under the Finance Act, 2020. The Income Tax Act, 2025 takes this change further by renumbering the tax law, including the provisions that apply to NGOs. The basic idea remains the same: registration for the NGO's tax exemption and separate approval for donor tax deductions. The section numbers, form numbers, and official terminology for tax-exempt NGOs have changed.
What Is an RNPO?
RNPO stands for Registered Non-Profit Organization. It's the new, official term for any Trust, Society, or Section 8 Company that holds valid registration under Section 332 (the old 12A) and, where applicable, approval under Section 354 (the old 80G). The term itself doesn't create any new eligibility rules; it's simply the umbrella name the new law uses for what people previously called a "12A-registered NGO" or an "80G NGO."
What Changed: Old Sections vs New Sections
Here's a simple side-by-side comparison of the old and new section numbers:
| What It Covers | Old Reference | New Reference (from 1 April 2026) |
| NGO's own tax exemption | Section 12A / 12AB | Section 332 |
| Donor's tax deduction | Section 80G | Section 354, linked with Section 133(1)(b)(ii) |
| Donation statement (annual) | Form 10BD | Form 113 |
| Donor certificate | Form 10BE | Form 114 |
| Provisional registration form | Form 10A | Form 104 |
| Regular registration form | Form 10AB | Form 105 |
What Are the New Forms, and When Do You Use Them?
Each form now has one clear, specific job:
- Form 104 — for provisional registration or approval, used by NGOs that haven't started activities yet
- Form 105 — for regular registration, renewal, or converting from provisional to regular status
- Form 106 — used by the department for orders related to provisional registration or approval
- Form 107 — used by the department for regular grant, rejection, or cancellation orders
Is Your NGO Ready for the New Tax Rules?
Get help reviewing your NGO's registration, tax exemptions, forms, renewals, and annual compliance under the Income Tax Act 2025.
If your NGO is applying for a new registration or renewing after 1 April 2026, you'll use Form 104 or Form 105 directly. You won't need to know Form 106 or 107 by name; the tax department issues those to you, not your NGO.
How Long Does Registration Last Now: Timeline
This part hasn't changed from the 2021 reform; it just carries forward under the new section numbers:
| Registration Type | Validity |
| Provisional (new NGOs) | 3 years |
| Regular, income above ₹5 crore a year | 5 years |
| Regular, income ₹5 crore or below | 10 years |
| Section 354 (80G) approval | 5 years, regardless of NGO size |
If a registration lapsed or was canceled before 1 April 2026, or a renewal is missed under the new law, the NGO is treated as a fresh applicant and must apply again under Section 332.
What Other Rules Should NGOs Know About?
A few compliance rules carry real financial weight and are worth understanding clearly:
- The 85% income-application rule. Under Section 11(1) of the earlier law, and carried forward under the new Act, a registered NGO must apply at least 85% of its income toward its charitable objects each year, or risk losing part of its exemption.
- Accreted income tax (exit tax). If an NGO's registration is canceled, rather than simply left to lapse, it can face a one-time tax on its accumulated net assets, a much bigger financial hit than a routine missed renewal.
- Annual donation reporting. Form 113 (the new name for Form 10BD) must be filed every year, even as a nil return if there were no qualifying donations, or a penalty of ₹200 per day can apply under Section 234G.
- One-time reapplication after rejection. Under Rule 181(12), an NGO whose Form 105 application is rejected via Form 107 may reapply within one month in specified cases, such as missing documents or a corrected trust deed issue.
See our guide on common mistakes that lead to 12A or 80G rejection to avoid this in the first place.
What Should NGOs Do Right Now?
Instead of panicking over the new law, focus on these practical steps:
- Check your current registration's expiry date, since that date, not the new law's start date, determines when you need to act
- Update internal references gradually, from "12A" and "80G" to Section 332 and Section 354, especially on donor-facing documents
- Keep filing Form 113 annually, regardless of which section your registration technically falls under
- Plan renewals using Form 105, at least 6 months before your registration expires
- Don't refile early out of confusion, since a valid, unexpired registration continues without needing fresh action
Need Help With NGO Tax Registration or Compliance?
Our NGO compliance experts can help you with 12A, 80G, income-tax compliance, renewals, and related NGO registrations.
Frequently Asked Questions
Does the Income Tax Act 2025 cancel my NGO's existing registration?
No. If your registration was valid before 31 March 2026, it continues under its original validity period. The new law only applies when you apply fresh, renew, or reapply after rejection.
What is Section 332 under the new Income Tax Act?
It's the new reference for what was previously Section 12A and Section 12AB, covering an NGO's own income-tax exemption.
What is Section 354 under the new Income Tax Act?
It's the new reference for the old Section 80G, covering donor tax deductions for approved NGOs.
What does RNPO stand for?
Registered Non-Profit Organization, the new official term for a Trust, Society, or Section 8 Company holding valid Section 332 or Section 354 approval.
Which form replaced Form 10A and Form 10AB?
Form 104 replaced Form 10A for provisional registration, and Form 105 replaced Form 10AB for regular registration and renewal.
Do I need to refile if my registration is still valid?
No. A currently valid registration continues as-is until its original expiry date, without needing any fresh filing.
What happens if I miss filing Form 113 in a year with no donations?
You still need to file it as a nil return; skipping it entirely can trigger a ₹200-per-day penalty under Section 234G.
Author
Aabha Garg
A Content Strategist at NGOExperts, who focuses on NGO registration, 12A and 80G registration, FCRA compliance, income tax filing for non-profits, and CSR funding guidelines in India. I research and write our compliance guides in collaboration with our in-house Chartered Accountants and Company Secretaries, so every article reflects current tax and regulatory requirements for the NGO and non-profit sector.
Written by Aabha Garg. Last updated on September 12, 2026
