12A & 80G Registration — One Engagement, Two Approvals
Almost no organisation wants only one of these. A trust, society, or Section 8 company that intends to raise money needs its own income exempt and its donors able to claim a deduction, and both come from the same authority on the same evidence. Running them as a single engagement is cheaper, faster, and far less error-prone than filing one, waiting, and then starting again.
They are still two applications with two section codes, two orders, two unique registration numbers, and two validity periods that can fall on different dates. The value of a combined engagement is sequencing: getting the instrument right once, building one document pack, filing in the correct order, and leaving with a single compliance calendar instead of two half-remembered ones.
This guide is about running that engagement end to end — readiness checks before you file, the combined document pack, the order of filings, what to do if one approval is refused, and the calendar that starts the day both orders arrive. The substance of each approval is covered separately in 12A registration and 80G registration.
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What is combined 12A and 80G registration?
It is a single engagement that secures both income-tax approvals a non-profit needs: registration that exempts the organisation's own income, and approval that makes donations deductible for the giver. Under the Income-tax Act, 1961 these were Sections 12A/12AB and 80G. From 1 April 2026 the Income-tax Act, 2025 grants the entity registration under Section 332 and the donation approval under Section 354 for the deduction in Section 133.
The same application form serves both, filed twice with different section codes, and the same instrument, governing-body details, activity evidence, and accounts support both. That overlap is the whole reason to combine them — roughly ninety per cent of the work is shared, and the examination of your objects and activities is the same examination.
What is not shared is the outcome. Two orders issue, each with its own validity, and one can be granted while the other is refused. A combined engagement is not a bundled approval; it is a single, sequenced piece of work with two deliverables.
Why apply for 12A and 80G together?
- One instrument review fixes objects, dissolution, and community-neutrality clauses for both applications at once
- One document pack — instrument, registration certificate, PANs, activity note, accounts — serves both filings
- The donor approval is conditional on the entity registration, so filing them apart risks a wasted application
- A single digital signature and portal setup covers both filings
- Queries on objects and activities are answered consistently, instead of two officers reading two versions
- Fundraising can begin once, rather than in two stages with a gap where donations are not deductible
- One compliance calendar is created at handover, covering both renewal dates and the donation-reporting cycle
- Deed amendments, if needed, happen once — before either application rather than between them
The commonest false economy is filing only the entity registration because it is "the important one", then coming back a year later for the donor approval on stale accounts and a deed that needs amending. The second engagement usually costs more than the saving.
Which registration comes first, 12A or 80G?
The entity registration comes first, or at the same time. The donor approval assumes the organisation already qualifies as a registered non-profit, so an application for it that is not backed by a subsisting entity registration is exposed from the start.
In practice for a newly formed organisation both provisional applications are prepared together and filed with the entity application going in first, so that the order reference can be quoted in the donor application. For an organisation that has already commenced activities, both regular applications are prepared together and filed in the same order.
What should never happen is filing the donor application against objects that have not yet been corrected. A clause confining benefits to a single community or caste will not block the entity registration but will block donor approval — so the instrument audit belongs before both filings, not between them.
Where do 12A and 80G sit in the full NGO registration stack?
These two approvals are the middle of a sequence. Each step has a prerequisite, and skipping ahead simply produces a rejection. The order below is the one we work in.
| Step | Registration | Authority | Depends on |
|---|---|---|---|
| 1 | Legal entity — trust, society, or Section 8 company | Sub-registrar / Registrar of Societies / MCA | Founders, objects, registered address |
| 2 | PAN and TAN in the organisation's name | Income Tax Department | Registered instrument |
| 3 | Bank account and books of account | Bank | PAN and registration certificate |
| 4 | Darpan unique ID | NITI Aayog | Entity registration, PAN, office-bearer KYC |
| 5 | Entity tax registration (12A) | CIT / PCIT (Exemptions) | Instrument with compliant objects |
| 6 | Donor approval (80G) | CIT / PCIT (Exemptions) | Entity registration in force |
| 7 | CSR-1 registration | MCA | Both tax registrations, and a track record |
| 8 | FCRA registration or prior permission | Ministry of Home Affairs | Tax registrations plus years of activity |
Step 1 is where the later steps are won or lost — see trust registration and Section 8 company registration for how the choice of form affects everything downstream. Step 4 is quick and worth doing early: Darpan registration is the identifier government schemes and CSR portals ask for.
Are you ready to apply for 12A and 80G?
Run this check before any filing. Every item that fails here becomes a notice, a hearing, or a refusal later.
- 1.The instrument is registered with the correct authority and you hold the certificate
- 2.Objects are charitable, specific, and do not permit unrelated commercial activity
- 3.The instrument prohibits distribution of income or property to trustees, members, or their relatives
- 4.A dissolution clause directs assets to an organisation with similar objects
- 5.No clause confines benefits to a particular religious community or caste
- 6.The organisation holds its own PAN, bank account, and a verifiable registered address
- 7.Governing-body members have PANs, and none is disqualified
- 8.You can state clearly whether activities have commenced, and evidence it either way
- 9.Accounts exist for every year since formation, audited where the threshold was crossed
- 10.Programme evidence is collected — reports, beneficiary records, photographs, minutes, utilisation statements
- 11.A donation receipt format is drafted with space for the approval number and donor identifier
- 12.An authorised signatory holds a valid digital signature certificate
Where an item fails on the instrument, amend before filing. A deed or bye-law amendment attracts state stamp duty and takes time, but it is the cheapest point in the whole process at which to fix the problem.
What is the combined document pack?
- Self-certified instrument — trust deed, society memorandum and bye-laws, or MOA and AOA
- Registration certificate from the charity commissioner, sub-registrar, Registrar of Societies, or MCA
- PAN of the organisation, plus PAN of every trustee, governing-body member, or director
- Certificate of incorporation and CIN where the applicant is a Section 8 company
- Activity note — proposed activities for a provisional filing, evidenced actual activities for a regular one
- Financial statements for every year of existence, with the audit report where applicable
- Bank statement in the organisation's name showing receipts through banking channels
- Existing provisional or regular orders, for conversion and renewal filings
- Details of any FCRA registration, CSR-1 number, or other approval held
- Sample donation receipt format, needed specifically for the donor approval
- Proof of the registered address and, for a Section 8 company, its registered office documents
Only the last two lines are specific to the donor approval. Everything above is shared, which is why assembling it once, to a standard both applications can carry, is the core of the engagement.
How does a combined 12A and 80G engagement run end to end?
- 1.Discovery — confirm the entity form, funding plan, and whether activities have commenced
- 2.Instrument audit against the conditions for both approvals; flag any amendment needed
- 3.Amend the deed or bye-laws where required, and register the amendment
- 4.Assemble the shared document pack and reconstruct accounts where records are incomplete
- 5.Complete audit for any earlier year where the threshold was crossed but no audit was done
- 6.Build the activity note and evidence file, tied line by line to the accounts
- 7.Set up portal access and the authorised signatory's digital signature
- 8.Select the correct form and section code for each application
- 9.File the entity registration application and note the acknowledgement
- 10.File the donor approval application, quoting the entity application or order
- 11.Respond to notices and attend any hearing, keeping both answers consistent
- 12.Collect both orders, record the unique registration numbers and validity periods
- 13.Issue a compliance calendar covering renewals, the donation statement, audit, and the return
- 14.Update the receipt format, website, and donor communications with the approval particulars
Steps 4 and 5 are where timelines usually go. Organisations that ran for two or three years on informal records need their accounts rebuilt before anything can be filed — which is an argument for starting proper bookkeeping from the first receipt rather than the first grant application.
Which orders and validity periods will you end up holding?
By the end of the engagement you hold two orders. Their terms differ, and the difference is the thing most often missed at handover.
| Approval | If activities not commenced | After conversion / on regular grant | Renewal application due |
|---|---|---|---|
| Entity registration (12A) | Provisional, three tax years | Five tax years, or ten where the income test is met | At least six months before expiry |
| Donor approval (80G) | Provisional, three tax years | Five tax years | At least six months before expiry |
A smaller organisation can therefore end up with a ten-year entity registration and a five-year donor approval, which means one renewal falls due while the other is years away. Keep both dates on one calendar and treat the shorter one as the trigger to review everything.
Where provisional registration is granted, the conversion deadline is the earlier of six months before expiry or six months from commencing activities — so beginning work in year one shortens the runway considerably.
How long does combined 12A and 80G registration take?
For a newly formed organisation with a clean instrument and no activity history, provisional approvals are the faster path because the examination is largely documentary and the Act sets an outer limit for the order measured from the end of the month of application. Both can commonly be filed within days of each other.
For an organisation applying directly for regular registration, the honest answer is that the filing is the short part. Instrument amendment, reconstructing accounts, completing a missed audit, and assembling credible activity evidence routinely take longer than the department does, and the officer may raise queries or fix a hearing on either application.
We give a realistic window after seeing the instrument and the accounts, and we do not promise an approval date — the outcome is a discretionary order on the evidence, not a processing queue.
What if one approval is granted and the other refused?
This happens, and almost always in one direction: the entity registration is granted and the donor approval is refused. The usual causes are a community or caste restriction in the instrument, objects or activities that read as substantially religious, business receipts not properly separated, or activity evidence too thin to satisfy the additional conditions in the donation provision.
The route back depends on the ground. Where the defect is in the instrument, amend it, register the amendment, report the modification of objects within the prescribed window where required, and apply again on the corrected document. Where the defect is evidential, build the record for a year and re-apply rather than re-filing the same pack.
A refusal order can also be appealed, and there is a statutory appellate route. Whether to appeal or re-apply is a judgement call on the ground cited and the time you can afford; we read the order before recommending either. Meanwhile, do not issue receipts describing donations as deductible — fundraise on the work until the approval is in hand.
What compliance starts once both approvals are in place?
- 1.Maintain books and records in the prescribed form from the date of registration
- 2.Apply the required proportion of income to the objects each year and document it
- 3.Keep any accumulated income in the permitted investment modes only
- 4.Capture donor name, address, identifier, amount, and payment mode at the time of every donation
- 5.Issue numbered receipts quoting the approval number and deduction category
- 6.File the annual statement of donations by the prescribed date — 31 May following the financial year
- 7.Download and issue the donation certificate to every donor, and file corrections promptly
- 8.Get the accounts audited and file the prescribed audit report where receipts cross the threshold
- 9.File the annual ITR-7 return within the due date, every year
- 10.Report any modification of objects within the prescribed window
- 11.File renewal applications at least six months before each expiry date
Two of these carry disproportionate risk. A late return can cost the exemption for the year even where the money was spent correctly, and a missed conversion or renewal can trigger the exit charge on accreted income at the maximum marginal rate. Both are calendar failures, which makes them the cheapest risks to remove.
How much does combined 12A and 80G registration cost?
| Cost head | Who charges it | Indicative position |
|---|---|---|
| Both applications on the e-filing portal | Income Tax Department | No prescribed filing fee for either |
| Deed or bye-law amendment where objects must be corrected | State stamp authority / registrar | Stamp duty and registration charges vary by state |
| Class 3 digital signature for the authorised signatory | Certifying authority | One per signatory, valid one to two years |
| Audit of earlier years where the threshold was crossed | Statutory auditor | Per year, scoped to the accounts |
| Accounts reconstruction where records are incomplete | CA firm | Per year, depends on the state of records |
| Professional fees for the combined engagement | CA / CS firm | Scoped after a short discovery call |
Neither application carries a government filing fee, so the bill is drafting, audit, and professional work. Stamp duty on an amendment differs sharply between states and audit cost depends on your receipts, so we confirm both before starting and quote professional fees separately from statutory charges.
What are the most common sequencing mistakes?
- Filing the donor approval before or without the entity registration
- Filing both on an instrument that still carries a community, caste, or profit-distribution clause
- Filing one application and assuming the single form covered both approvals
- Choosing the provisional route after activities have already begun, or the regular route with no activity evidence
- Letting provisional registration run its full three years when activities started in year one
- Assuming a ten-year entity registration means the donor approval also runs ten years
- Starting to receipt donations as deductible from the application date rather than the approval date
- Issuing donation receipts through the year but never filing the annual donation statement
- Applying for CSR-1 or FCRA before both tax approvals are in force
- Amending objects for a new programme and never reporting the modification
Every item on that list is a scheduling or sequencing error rather than a legal difficulty, which is why a combined engagement with one calendar at handover removes most of the risk. If you are unsure where your organisation currently stands, an online CA consultation is the quickest way to map it.
Why choose Arjun Filings for 12A & 80G registration?
Arjun Filings runs 12A & 80G registration as a checklist-first engagement: a qualified CA or CS scopes the work, tells you exactly which documents are needed, and reviews every form before it is signed and submitted. You get a named specialist, a status update at each stage, and a compliance calendar for whatever comes next.
- End-to-end help for 12A & 80G registration
- Department-ready document pack
- Application tracking updates
- Renewal calendar starter