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Checklist - Trust

Last updated · 3 August 2026

There is no single national statute for public charitable trusts. Registration and annual filing are governed by the State law — the Bombay Public Trusts Act, 1950 in Maharashtra and Gujarat, the Rajasthan Public Trusts Act, 1959 in Rajasthan, and in several States by nothing more than the trust deed and the general law. The table below sets out the shape of the obligation on the Bombay Public Trusts Act model, which is the fullest of them; the tax and FCRA obligations that follow it are national and apply to every trust wherever it is registered.

Filings with the Charity Commissioner

These are the obligations under the Bombay Public Trusts Act, 1950. They are not uniform across India. The forms, the thresholds and the filing windows differ materially between States, and a calendar prepared for one State must never be reused for another without checking.

#ComplianceDue date
1Registration of the trust with the Charity Commissioner — section 18One-time. In most States the registration is perpetual and there is no periodic renewal
2Budget in Schedule VII-A, where the annual income exceeds ₹10,000 — section 31AOne month before the start of the accounting year
3Balancing of the accounts — sections 32 and 33 and rule 17As at 31 March
4Audit of the accounts and preparation of the statements in Schedules VIII, IX and IX-C — sections 33 and 34 and rule 19Within six months of the balancing of the accounts, that is by about 30 September
5Filing of the audited accounts with the Charity Commissioner — section 34 and rule 19Within a fortnight of the audit being completed
6Contribution to the Public Trusts Administration Fund, at two per cent of the income shown in Schedule IX-C — section 58 and rule 32Annual, with the accounts
7Change report in Schedule III, on any change in the trustees or in the immovable property — section 22Within ninety days of the change

In Maharashtra a society registered under the Societies Registration Act, 1860 is also a public trust under section 2(13) of the Bombay Public Trusts Act, 1950 and must comply with both sets of obligations.

The tax calendar is the one that carries the real risk. A lapse under the State trusts Act is usually curable. A lapse under the Income-tax Act can cost the registration, and with it the exemption. Form 10B or Form 10BB — the audit report — by 30 September; Form 10B where income exceeds ₹5 crore, or foreign contribution has been received, or income has been applied outside India, and Form 10BB in every other case. Form ITR-7 by 31 October. Renewal of registration under section 12AB and under section 80G in Form 10AB, six months before expiry — the 12AB cycle is now ten years where income did not exceed ₹5 crore in each of the two preceding years and five years otherwise, while 80G remains a five-year cycle. Where the trust is registered under the Foreign Contribution (Regulation) Act, 2010, the annual return in Form FC-4 is due by 31 December and renewal in Form FC-3C six months before expiry.

Meetings of the trustees

Neither the Bombay Public Trusts Act, 1950 nor the general law prescribes a minimum number of meetings. What governs is the trust deed, and the deed is enforceable: if it says the trustees shall meet quarterly, then quarterly meetings, properly minuted, are part of the compliance record.

#Meeting or obligationRequirement
1Meetings of the board of trusteesAs provided in the trust deed. Where the deed is silent, at such intervals as are needed to administer the trust properly
2MinutesEvery meeting minuted and signed. The minute book is the primary evidence that the trustees have applied their minds, and it is what an assessing officer or the Charity Commissioner will ask to see
3Approval of the accounts and of the budgetBy resolution of the trustees, before the budget is filed and before the accounts are audited
4Resolutions on the application of incomeWhere income is accumulated or set apart under the Income-tax Act, the resolution and the Form 10 must be in place before the due date for the return

Documents required to be drafted

For a trust, the documents are the compliance. There are few forms to file, and an assessment or an inspection turns almost entirely on whether the deed, the minutes, the accounts and the donation records line up with one another.

#DocumentWhen
1Trust deed, with every supplementary deed and every order of the Charity Commissioner recording a changeKept permanently
2Budget in Schedule VII-A, where income exceeds ₹10,000One month before the start of the accounting year
3Annual accounts — income and expenditure account and balance sheet, with the statements in Schedules VIII, IX and IX-CFor the year ended 31 March
4Auditor's reportWithin six months of the balancing of the accounts
5Minutes of the meetings of the trusteesEntered and signed after each meeting
6Register of movable and immovable property of the trustKept current
7Records of donations, with the donor details required for Form 10BD, and the certificates issued in Form 10BEForm 10BD and Form 10BE by 31 May
8FCRA records — the designated FCRA account, the utilisation accounts and the asset register, where the trust is registered under the FCRAMaintained separately from domestic funds throughout the year
Records to be maintained
  • Books of account for the trust, and separately for each business undertaking and each institution run by the trust.
  • Register of the trust property, movable and immovable, with the particulars of every acquisition and disposal and of the sanction obtained under section 36 where it was required.
  • Minute book of the trustees.
  • Donation records and the counterfoils of the receipts issued, with the donor particulars needed for Form 10BD.
  • Separate books for foreign contribution, where the trust holds an FCRA registration.

Taxation and accounting compliances

Alongside the filings with the Registrar, the following tax and accounting compliances commonly apply. Which of them actually bite depends on turnover, on the nature of the receipts and on registration under the respective statute.

#ComplianceDue date
1Form ITR-7 — return of income31 October following the financial year
2Form 10B or Form 10BB — audit report of the trust or institution30 September
3Form 10AB — renewal of registration under section 12AB and under section 80GSix months before expiry
4Form 10BD and Form 10BE — statement of donations and the certificate to each donor, where the trust is registered under section 80G31 May
5Form FC-4 — FCRA annual return, where the trust holds an FCRA registration31 December
6GST returns — GSTR-1 monthly (11th of the following month) or quarterly under QRMP (13th of the month after the quarter), and GSTR-3B monthly (20th) or quarterly (22nd or 24th, depending on the State group). Registration is required once turnover crosses ₹40 lakh for goods or ₹20 lakh for services (₹20 lakh and ₹10 lakh in special-category States).Monthly or quarterly, as opted
7GSTR-9 — GST annual return, where aggregate turnover exceeds ₹2 crore31 December following the financial year
8GSTR-9C — self-certified reconciliation statement, where aggregate turnover exceeds ₹5 crore31 December following the financial year
9TDS returns — Form 24Q (salary), 26Q (resident non-salary) and 27Q (non-resident), by every person holding a TAN31 July, 31 October, 31 January and 31 May
10TCS return — Form 27EQ, by every person liable to collect tax at source15 July, 15 October, 15 January and 15 May
11Monthly deposit of TDS and TCS7th of the following month; 30 April for March
12TDS and TCS certificates — Form 16 (salary), Form 16A and Form 27DForm 16 by 15 June; Form 16A and 27D within 15 days of the return due date
13Advance tax — where the tax liability for the year is ₹10,000 or more, in instalments of 15, 45, 75 and 100 per cent of the estimated liability15 June, 15 September, 15 December and 15 March

Dates are those applicable to the financial year 2025-26 (assessment year 2026-27). The Income-tax Act, 2025 replaces the 1961 Act from tax year 2026-27, and the section numbers in every tax checklist will change from that year — the dates above are stated on the 1961 Act as it applies to this cycle.

Labour law compliances and their applicability

Labour law obligations are triggered by headcount and by wage levels rather than by the form of the entity, so the same table applies whether the employer is a company, an LLP, a firm or a proprietor. The threshold column is what decides whether a line applies at all.

#ComplianceApplies to
1Employees' Provident Fund — monthly ECR and remittance of contributions at 12 per cent by each of employer and employee. Paid by the 15th of the following month. The separate annual returns in Form 3A and 6A were discontinued when the ECR was introduced; the annual account is generated automatically.Establishments employing 20 or more persons. Mandatory coverage up to a wage of ₹15,000 a month; voluntary coverage is possible below the threshold
2Employees' State Insurance — monthly contribution and challan at 3.25 per cent (employer) and 0.75 per cent (employee), by the 15th of the following month, and the half-yearly return of contributions where the region still requires itEstablishments employing 10 or more persons (20 in some States for shops). Covers employees drawing wages up to ₹21,000 a month, or ₹25,000 for a person with disability
3POSH — constitution of the Internal Committee, a policy, and an awareness and training programmeEvery workplace with 10 or more employees, counting all workers of every description. Members hold office for a maximum of three years and must then be reconstituted
4POSH annual report to the District Officer, and the disclosure of the number of complaints in the Board's reportEvery employer that is required to have an Internal Committee. Section 22 does not fix a central date — the date is set by the State rules, and is 31 January in several States and 28 February or 31 March in others. Confirm the date for the State in which the workplace is situated.
5Payment of Bonus — payment of the annual bonus and the annual return in Form DEstablishments employing 20 or more persons, for employees drawing up to ₹21,000 a month. Bonus is payable within eight months of the close of the year
6Payment of Gratuity — payment on the event, and the notices in Forms A, B and CEstablishments employing 10 or more persons. Payable after five years of continuous service, and after one year for a fixed-term employee
7Maternity Benefit — 26 weeks of paid leave, and the registers and returns under the State rulesEstablishments employing 10 or more persons. A creche is required at 50 or more
8Professional tax — enrolment, registration and the periodic returnOnly in the States that levy it — Maharashtra, Karnataka, West Bengal, Tamil Nadu, Andhra Pradesh, Telangana, Gujarat, Madhya Pradesh, Odisha, Kerala, Assam and others. It is not levied in Delhi, Uttar Pradesh, Haryana, Rajasthan or Punjab
9Shops and Establishments — registration and, where the State requires it, renewalEvery shop and commercial establishment, from the day it commences. Registration within 30 days; renewal cycles run from one year to lifetime depending on the State
10Contract labour — registration of the principal employer, licensing of the contractor, and the periodic returnsWhere 20 or more contract workers are engaged (the threshold is 50 under the Occupational Safety, Health and Working Conditions Code, 2020)
11Minimum wages — payment at not less than the notified rate, with the variable dearness allowance revisionEvery scheduled employment. Central revisions usually take effect on 1 April and 1 October; State cycles differ

Headcount thresholds are counted across the establishment, not the entity, and several of them are State-specific. Where an entity operates from more than one State the position must be tested State by State.

The four Labour Codes are now in force. The Code on Wages, 2019, the Industrial Relations Code, 2020, the Occupational Safety, Health and Working Conditions Code, 2020 and the Code on Social Security, 2020 were brought into force on 21 November 2025, and the Central Rules were notified in May 2026. The Employees' State Insurance Act, the Payment of Bonus Act, the Payment of Gratuity Act and the Maternity Benefit Act stand subsumed into the corresponding chapters of the Code on Social Security; the Employees' Provident Funds Act was preserved by a corrigendum issued in December 2025 pending a further notification. In practice the EPFO and ESIC portals, forms and dates continue as before, so the table above still describes what has to be done. The change that matters most is the new definition of wages, under which basic pay and dearness allowance must be at least half of total remuneration — it re-bases provident fund, gratuity, bonus and leave encashment for almost every employer. State rules remain incomplete in several States.

Event-based compliances

Everything set out above recurs every year. Separately from these, a public charitable trust attracts event-based compliances — obligations that arise only when something particular happens, and that usually carry a short deadline running from the date of the event itself rather than from the close of the financial year.

These are not listed here, and deliberately so. They run to a very long list, they depend entirely on what has actually happened, and a general page cannot tell you which of them apply to you. Typical triggers include a change in the persons in charge, a change in capital or in the constitution, the creation or satisfaction of security over assets, a change of address, the approval of a transaction of a kind that requires prior consent, and the acquisition or disposal of an interest by a person who has to be reported to the Charity Commissioner. Several of them carry a filing window of 15 or 30 days, and the additional fee for filing late can be many times the normal fee.

If an event of this kind has occurred, or is being planned, the position should be checked before the deadline rather than after it. Please write to us with what has happened and we will tell you what has to be filed and by when.

These are the major compliances applicable to a public charitable trust. They are not the whole of the law. This checklist is general. It sets out the filings, meetings, documents and returns that apply to most Public Charitable Trusts in the ordinary course. Apart from these, there may well be further compliances that apply to you — because of the sector you operate in, the licences you hold, the States you operate from, the composition of your ownership, a foreign shareholder or lender, a registration you have taken under a special statute, or simply because of something that has happened during the year. Thresholds and due dates also change from year to year, and a date that is right for one financial year may not be right for the next.

Please do not treat this page as advice on your own facts. Before you rely on it, have the position checked against your own constitution documents, your last filed accounts and your actual figures for the year. We would be glad to do that for you.

Have your position checked

Tell us what the entity is and we will confirm exactly which of these apply to you this year, what is already overdue, and what it will cost to put right.

Prepared by MPS & Associates, Company Secretaries, on the law as it stood on 3 August 2026, by reference to the Ministry of Corporate Affairs, the Securities and Exchange Board of India, BSE Limited, the National Stock Exchange of India Limited, the Reserve Bank of India, the Central Board of Direct Taxes and the Goods and Services Tax Network, as applicable. Statutes, rules, thresholds and due dates change. Nothing on this page is professional advice, and no professional relationship arises from reading it. Please see our Disclaimer.

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