Form 10BB is the shorter road, and most registered trusts in India qualify for it. But it is available only if you clear all three gates — and one of them is tested on a figure most trustees never look at.
At a glance
- What it is
- The shorter audit report for registered trusts and institutions
- Rules
- Rules 16CC and 17B, rewritten with effect from 1 April 2023
- Who signs
- A Chartered Accountant in practice
- Deadline
- One month before the return due date
- Available only if
- Income ≤ ₹5 crore and no foreign contribution and nothing applied outside India
- Otherwise
- Form 10B applies
- Under the 2025 Act
- Audit obligation at section 348
Who can use Form 10BB
All three conditions must hold for the year:
| Condition | Test |
|---|---|
| Size | Total income, computed without giving effect to sections 11 and 12, does not exceed ₹5 crore |
| Foreign money | No foreign contribution received during the year |
| Overseas application | No part of income applied outside India during the year |
Fail any one and Form 10B is compulsory. There is no partial route.
The ₹5 crore test ignores your exemption. Income is measured before sections 11 and 12 apply. A trust that spends everything it receives and pays no tax at all can still be far above the threshold. Trustees who reason from “we had no taxable income” reach the wrong answer almost every time.
What changed in 2023
Before April 2023, Form 10BB was associated with institutions approved under section 10(23C) and Form 10B with trusts registered under section 12A. The rewritten Rules 16CC and 17B ended that split.
Now both forms serve both routes, and the choice is purely mechanical — the three conditions above. A 10(23C)-approved institution with ₹40 crore of income files Form 10B; a 12A-registered trust with ₹80 lakh and no foreign money files Form 10BB.
Old guidance is still circulating. A good deal of online material — and some template engagement letters — still describes the pre-2023 position. If a checklist tells you the form follows your registration section, it is out of date.
What Form 10BB covers
Shorter than Form 10B, but not trivial. It still requires:
- Registration or approval particulars and any change during the year
- Whether activities were carried on in accordance with the objects
- Voluntary contributions, and corpus donations kept separately
- Application of income against the 85% requirement
- Accumulation under section 11(2), where claimed
- Payments to specified persons under section 13(3)
- Investments tested against the permitted modes in section 11(5)
- Any business activity and whether it is incidental to the objects
The schedules that Form 10B adds — detailed foreign contribution reporting and overseas application — are exactly the ones a Form 10BB filer, by definition, does not need.
Getting it wrong is expensive
Filing Form 10BB when Form 10B was required is treated as not filing the audit report at all. The consequence is not a correction notice — it is that the report was never furnished, which puts the year’s exemption under sections 11 and 12 at risk. Trusts caught by this have had to apply for condonation of delay.
The safe practice is to settle the form at the start of the engagement, on the previous year’s figures plus a check on FCRA receipts and overseas spending, rather than at upload time.
Deadline
The report is due one month before the due date for the return — 30 September where the return is due 31 October. The CA files it electronically and the trust must then accept it on the portal; until acceptance the filing is incomplete.
UDIN on Form 10BB
Form 10BB is an audit report, so the Audit and Assurance Functions category applies — UDIN mandatory since 1 July 2019, not the 1 February 2019 date that applies to certificates.
Update within 60 calendar days of upload. A form uploaded without a UDIN and not updated inside that window is treated by the CBDT as invalid with all due consequences of law, even after the trust has accepted it. For a small trust, an invalid audit report and a lost exemption are wholly disproportionate to the omission. Revocation closes at 48 hours.
See our guide to UDIN generation.
Under the Income-tax Act, 2025
The 2025 Act consolidates the charitable regime into sections 332 to 355, a dedicated part for registered non-profit organisations. Per ICAI’s tabular mapping:
| Subject | 1961 Act | 2025 Act |
|---|---|---|
| Registration and approval | Sections 11, 12A, 12AB, 80G | Section 332 |
| Application of income | Section 11 | Section 341 |
| Accumulated income | Section 11(2) | Section 342 |
| Audit | Sections 11, 12A and 139 | Section 348 |
| Permitted modes of investment | Section 11(5) | Section 350 |
Section 333 also introduces provisions on switching over of regimes, which is worth watching for trusts that move between routes.
Frequently asked questions
Who can file Form 10BB?
A registered trust or institution whose income before sections 11 and 12 does not exceed ₹5 crore, which received no foreign contribution, and which applied no income outside India during the year.
Is the ₹5 crore before or after exemption?
Before. Income is computed without giving effect to sections 11 and 12.
We received one small foreign donation. Can we still use 10BB?
No. Any foreign contribution during the year moves you to Form 10B.
Is Form 10BB only for section 10(23C) institutions?
Not since April 2023. Both forms serve both registration routes; the three conditions decide which applies.
What if we file 10BB but should have filed 10B?
It is treated as the audit report not having been furnished, and the year’s exemption is at risk. Condonation of delay may be needed.
When is Form 10BB due?
One month before the return due date — 30 September where the return is due 31 October.
Does the trust need to do anything after the CA files?
Yes. The trust must accept the form on the e-filing portal, otherwise the filing is incomplete.
Which UDIN category applies?
Audit and Assurance Functions, mandatory since 1 July 2019.
Does Form 10BB still ask about specified persons?
Yes. Payments and benefits to persons covered by section 13(3) are reported in both forms.
Where does the audit requirement sit under the 2025 Act?
Section 348, within the registered non-profit organisation provisions at sections 332 to 355.
In short
Form 10BB is the right report for the large majority of Indian trusts, but eligibility is all-or-nothing and one of the three tests is measured before exemption. Check the pre-exemption income, the FCRA register and any overseas spending at the start of the audit. That five-minute check is the difference between the shorter form and a lost year of exemption.
Micro Advisor audits charitable trusts, societies and Section 8 companies and advises on exemption compliance.
References
Disclaimer. General information, not professional advice. Verify the applicable form and thresholds for the trust and year concerned before filing.