Last reviewed: 24 September 2026. On 2 July 2026, the CBDT quietly issued Circular No. 06/2026 – a one-time condonation for a specific, narrow band of NGOs and trusts that filed their Section 80G renewal (Form 10AB) late in the second half of FY 2025-26. If your trust's 80G approval fell due for renewal around 31 March 2026 and the paperwork went in after 30 September 2025, this circular is the difference between your donors keeping their deduction and your NGO having to start the registration process over from scratch.
What CBDT Circular 06/2026 actually says
Circular No. 06/2026 (F. No. 300176/3/2026-ITA-I, dated 2 July 2026) was issued under Section 119(2)(b) of the Income-tax Act, 1961, read with Section 536(2) of the Income-tax Act, 2025. It addresses one specific problem: a batch of trusts and institutions applied for renewal of their final approval under Section 80G(5) by filing Form 10AB electronically after the prescribed due date of 30 September 2025, but before 31 March 2026. Some of these applications were being rejected purely on the ground of delay, without the tax department looking at the merits of the 80G claim at all.
| Aspect | Position under Circular 06/2026 |
|---|---|
| Form covered | Form 10AB – renewal of regular/final approval under Section 80G(5) only |
| Eligible filing window | 1 October 2025 to 31 March 2026 (electronically filed) |
| Original due date missed | 30 September 2025 |
| Effect of the circular | Delay is condoned – the application is treated as filed within time |
| Disposal deadline for the department | On or before 31 December 2026 |
| Does approval follow automatically? | No – only the delay objection is removed; the application is still examined on merits |
Two things to note carefully. First, this is not a fresh filing window – you cannot file a new Form 10AB today and claim this circular; it only regularises applications that were already submitted in the stated period. Second, it covers Section 80G(5) renewal specifically; it does not, on its wording, extend to Form 10A/10AB filings for Section 12AB registration, which is a separate (if closely related) approval. It also has nothing to do with the Form 10B/10BB audit report a trust files every year regardless of its 12A/80G renewal cycle, or with the donation-reporting Form 10BD/10BE obligation – those are separate, recurring filings.
The Form 10A/10AB regime in one page
Since the 2020-21 overhaul, every charitable trust, society, Section 8 company or religious institution seeking income-tax exemption (Section 12AB) and donor-deduction status (Section 80G(5)) has moved through the same two-stage cycle:
- Provisional registration (Form 10A) – granted for 3 assessment years, typically to a newly set up or newly applying entity that has not yet started charitable activity at scale.
- Regular/final registration (Form 10AB) – the trust converts from provisional to regular status, or renews an existing regular registration, before it lapses.
The trigger for filing Form 10AB is the earlier of two dates: at least 6 months before the provisional registration's 3-year period ends, or within 6 months of the date the trust actually commenced its charitable activities – whichever comes first. For a regular (already-final) registration nearing the end of its validity, the rule is simpler: file Form 10AB at least 6 months before that validity period expires.
Worked example – provisional to regular. A trust is granted provisional registration effective from AY 2024-25, running through AY 2026-27 (three assessment years, expiring 31 March 2027). If it starts activities immediately, the 6-months-from-commencement test and the 6-months-before-expiry test both point to the same broad window – in practice the trust should file Form 10AB well before 30 September 2026 to be safe, rather than waiting for the last date.
Worked example – the circular in context. A trust's regular 80G(5) approval was due to expire 31 March 2026. Working back 6 months, its Form 10AB was due by 30 September 2025. The trust actually filed on, say, 15 December 2025 – genuinely late under the standard rule. Under Circular 06/2026, because that filing falls inside the 1 October 2025 – 31 March 2026 window, the delay is condoned; the Commissioner (Exemptions) must still examine and decide the application, by 31 December 2026 at the latest.
The 10-year window: a separate relief worth checking at the same time
Independently of the circular, Finance Act 2025 amended Section 12AB (and the parallel Section 80G(5) proviso) to let smaller trusts and institutions get a 10-year regular registration instead of the standard 5 years. The test looks at the trust's total income computed without giving effect to Sections 11 and 12 – i.e., income before claiming the charitable exemption – for each of the two previous years immediately preceding the year of application.
| Condition | Registration validity on renewal |
|---|---|
| Income (pre-Sec 11/12) ≤ ₹5 crore in each of the two preceding years | 10 years (regular registration) |
| Income exceeds ₹5 crore in either of the two preceding years | 5 years (regular registration, standard rule) |
| Provisional registration (any income level) | 3 years – unaffected by the ₹5 crore test |
Worked example. A Section 8 company running a school had gross receipts (before claiming exemption) of ₹3.2 crore in FY 2023-24 and ₹4.1 crore in FY 2024-25 – both under ₹5 crore. When it files Form 10AB in 2026 to renew its regular 12AB/80G approval, it should be granted a 10-year window rather than 5, provided the application is otherwise in order. If receipts had touched, say, ₹5.4 crore in even one of those two years, the standard 5-year renewal would apply instead.
What happens if the deadline is missed altogether
Outside a specific condonation circular, missing the Form 10AB deadline is not a minor lapse:
- The Section 11/12 exemption stops applying to the trust's own income from the date the registration/approval expires.
- Donors lose the Section 80G deduction on donations received after the lapse – a real fundraising problem, since many donors ask for the approval order before writing a cheque.
- The trust ordinarily has to apply afresh, in most cases restarting from provisional registration, which means going through the 3-year and 6-month cycle again rather than simply picking up where it left off.
- A gap period with no valid registration is difficult to cure retrospectively; a condonation circular, where one applies, is the exception, not something to plan around.
Action checklist for NGOs and trusts
- Pull the current Form 10AC/10AD registration order from the e-filing portal and note the exact expiry date – not the date from memory or an old engagement letter.
- If a Form 10AB for 80G renewal was filed between 1 October 2025 and 31 March 2026 and is still pending or was rejected for lateness, ask your CA to check its status against Circular 06/2026 and, if needed, request restoration for merit review before 31 December 2026.
- Work out whether the trust's total income (before Sections 11/12 exemption) stayed under ₹5 crore in each of the two years preceding the renewal year – if so, confirm the 10-year validity is being applied, not the default 5 years.
- For any registration or approval expiring in the next 12 months, calendar the Form 10AB filing at least 6 months ahead – do not wait for a reminder. (Section numbers referenced here are under the Income-tax Act, 1961; the Income-tax Act 2025 carries the substance of these provisions forward from FY 2026-27, with primary handles staying on the 1961 numbering for now.)
- If a 12AB (not just 80G) filing has also lapsed, check separately whether any condonation route applies – Circular 06/2026 does not, on its wording, cover Section 12AB.
Common mistakes we see
- Assuming the 10-year validity is automatic for every renewal, without actually checking the two-year income test.
- Treating Circular 06/2026 as a general amnesty for any late Form 10AB, rather than the specific 80G(5)-only, Oct 2025-Mar 2026 window it actually covers.
- Filing Form 10AB at the last permissible moment instead of building in a buffer for portal errors, DSC issues or document gathering.
- Not checking whether the 12AB registration and the 80G approval are running on different expiry timelines for the same trust – they can, and often do, drift apart.
Frequently asked questions
Does CBDT Circular 06/2026 apply to my trust automatically, or do I need to do something?
It is not automatic in the sense of a fresh approval. It removes the "filed late" objection for Form 10AB applications for Section 80G(5) final approval that were filed electronically between 1 October 2025 and 31 March 2026 despite the prescribed due date of 30 September 2025. The jurisdictional Principal Commissioner or Commissioner (Exemptions) still examines the application on merits and must dispose of it on or before 31 December 2026. If your application was rejected earlier only on the ground of delay, ask your CA to have it restored for merit review under this circular.
Does the condonation also cover Section 12A/12AB registration, or only Section 80G?
Circular 06/2026 is worded specifically for Form 10AB applications for regular approval under Section 80G(5). It does not extend, in terms, to Form 10A/10AB filings for Section 12AB registration. CBDT has, from time to time, issued separate condonation circulars for 12A/12AB matters, so a trust with both a lapsed 12AB and a lapsed 80G filing should not assume one circular covers both — check the specific circular text or confirm with your CA before relying on either.
My trust's Form 10AB was filed in April 2026, after the window in the circular. Am I covered?
No. The relief in Circular 06/2026 is limited to applications filed electronically between 1 October 2025 and 31 March 2026. A Form 10AB filed outside that window is not automatically condoned by this circular; a separate condonation application under Section 119(2)(b), explaining the reasons for delay, would need to be filed and decided on its own facts.
What is the new 10-year registration validity, and does my NGO qualify?
Finance Act 2025 lets a trust or institution get a 10-year (instead of 5-year) regular registration/approval under Section 12AB and the parallel Section 80G(5) provision, provided its total income computed without giving effect to Sections 11 and 12 does not exceed ₹5 crore in each of the two previous years immediately preceding the year of application. If either of those two years crosses ₹5 crore, the registration reverts to the standard 5-year cycle. Provisional registration continues to run for 3 years regardless of income.
What actually happens if a trust misses the Form 10AB renewal deadline altogether (outside any condonation window)?
The provisional or regular registration/approval lapses from the date of expiry. The trust loses the Section 11/12 exemption on its own income from that date, and donors lose the Section 80G deduction on donations made after the lapse. The trust must then apply afresh, ordinarily starting again from provisional registration, which resets the compliance clock and can create a gap period with no valid registration at all.
We run both a Section 8 company and a separate public trust for CSR receipts. Does each entity need its own Form 10AB?
Yes. Registration, approval and renewal under Sections 12AB and 80G(5) attach to the specific legal entity (the trust, society or Section 8 company) that holds the PAN, not to the group or the cause. Each entity tracks its own provisional/regular status, its own expiry date and, where relevant, its own ₹5 crore test independently.
Where do I check my trust's actual registration/approval expiry date?
The expiry date is stated on the registration/approval order issued in Form 10AC (provisional or regular) or Form 10AD, downloadable from the income-tax e-filing portal under the trust's PAN. Do not rely on memory or on a CA's earlier engagement letter — orders issued after a renewal replace the earlier expiry date, and this is the figure any Form 10AB timeline should be calculated from.
We handle Form 10A/10AB filings, condonation applications and ongoing NGO compliance for trusts, societies and Section 8 companies across Maharashtra.
NGO & Section 8 Compliance Trust & Society Registration Talk to usThis article summarises CBDT Circular No. 06/2026 (dated 2 July 2026) and the Finance Act 2025 amendments to Section 12AB/80G(5) validity as understood on the date of review. It is general information, not advice on your trust's specific registration status – confirm your exact expiry dates and filing history against the e-filing portal, and consult us or your tax advisor before relying on any condonation relief. CA Somesh Chandak & Associates, FRN 158694W.