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FCRA Bank Account Structure Compliance Checklist

The post-2020-amendment FCRA account structure — mandatory SBI New Delhi main branch FCRA account, the permitted "utilisation" account, and every other account that must NOT receive foreign contribution.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Mandatory account
SBI, New Delhi Main Branch — "FCRA Account"
Amendment
FCRA (Amendment) Act, 2020
Admin expense cap
20% of foreign contribution utilised (post-2020)
Common red flag
Foreign funds received directly into a utilisation account
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FCRA BANK ACCOUNT STRUCTURE COMPLIANCE CHECKLIST

Entity: ___ · FCRA registration/URN: ___ · Year ended: ___

The Foreign Contribution (Regulation) Amendment Act, 2020 restructured how FCRA-registered entities must bank their foreign contribution. This checklist tests the account structure actually in place against the mandatory requirements — a common, and heavily scrutinised, area of FCRA non-compliance.

A. Mandatory "FCRA Account" — State Bank of India, New Delhi Main Branch

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Common questions

FAQs.

Can an NGO still use its old FCRA bank account at a different bank?
No — since the FCRA (Amendment) Act, 2020 took effect, every FCRA-registered entity must maintain its designated "FCRA Account" specifically at the SBI New Delhi Main Branch, and this is where ALL foreign contribution must first be received, regardless of where the entity is otherwise based. Entities with an older FCRA account at a different bank were required to open the SBI account and route all foreign receipts through it; continuing to receive foreign contribution into the old account after the transition deadline is a compliance breach.
What is a "utilisation account" and why does it matter?
A utilisation account is any other scheduled-bank account the entity opens purely to spend foreign contribution funds already received into the mandatory SBI FCRA account — it lets an entity actually operate locally (paying vendors, staff, etc. from a more convenient account) while keeping the receipt point centralised. The critical rule is direction of flow: money must go FCRA account first, utilisation account second. Foreign contribution received directly into a utilisation account (skipping the SBI account) is a structural violation even if every rupee is eventually spent on legitimate charitable purposes.
Is there a cap on foreign contribution spent on administrative expenses?
Yes — the FCRA (Amendment) Act, 2020 reduced the permissible administrative expense limit from 50% to 20% of the foreign contribution utilised in a financial year (amended Section 8). Administrative expenses that exceed this cap are themselves a violation, independent of whether the bank account structure is otherwise compliant — test both separately.
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