Fund/Grant Utilisation Certificate Under FEMA, FERA & Other Laws: A Complete Guide
Last updated: 28 June 2026 | Written from a practising Chartered Accountant’s perspective
Introduction
If you have received foreign funds, a grant, a loan, or any inward remittance from outside India — or if you have sent funds abroad — sooner or later someone will ask you to prove how that money was actually used. That proof is called a Fund/Grant Utilisation Certificate.
This certificate is not a single fixed format prescribed by one statute. It is issued under different laws — the erstwhile Foreign Exchange Regulation Act (FERA), the current Foreign Exchange Management Act, 1999 (FEMA), Reserve Bank of India (RBI) guidelines, the Companies Act, 2013, the Income Tax Act, 1961, and in some cases SEBI regulations — depending on who gave the money, who received it, and what condition was attached to it.
As a practising Chartered Accountant, I am routinely asked by NGOs, companies, startups, and individuals to certify how foreign contributions, grants, ECB funds, or remittances were spent. This guide explains, in plain language, everything you need to know about this certificate — what it is, who can issue it, the legal basis, the process, the format, and the most common questions I get asked in practice.
Section 1: What is a Fund/Grant Utilisation Certificate?
A Fund/Grant Utilisation Certificate (also called a Utilisation Certificate or “UC”) is a formal written confirmation — usually issued by a Chartered Accountant after examining the books of account, bank statements, and supporting vouchers — that states the amount of funds or grant received, the purpose for which it was sanctioned, and how that exact amount was actually spent.
It answers one simple question for the person relying on it: “Was the money used for what it was given for, or not?”
Under FEMA and erstwhile FERA, this certificate becomes important whenever foreign exchange has crossed the border — money coming into India as a grant, donation, External Commercial Borrowing (ECB), or foreign contribution, or money going out of India that needs to be accounted for to RBI, an Authorised Dealer (AD) Bank, a foreign donor, or a regulatory authority.
| Term | Meaning in this context |
|---|---|
| FERA | Foreign Exchange Regulation Act, 1973 — repealed and replaced by FEMA from 1 June 2000. Still relevant for older transactions and pending proceedings. |
| FEMA | Foreign Exchange Management Act, 1999 — the current law governing all foreign exchange transactions in India. |
| Utilisation Certificate | A certificate confirming actual use of funds matches the sanctioned/declared purpose. |
| Grant | Funds given without expectation of repayment, usually for a specific purpose (research, relief, project, scholarship). |
Section 2: Purpose of a Fund/Grant Utilisation Certificate
The certificate serves different purposes depending on who asks for it:
- For RBI/AD Banks: To confirm that foreign exchange remitted out of India (e.g., advance payment for imports, or funds remitted under the Liberalised Remittance Scheme) was used for the declared purpose and not diverted.
- For foreign donors/grant-giving agencies: To confirm that grant money given to an Indian NGO, trust, or research body was spent strictly on the sanctioned project.
- For Government departments: Many Central and State Government schemes require a Utilisation Certificate (in Form GFR 12-A under the General Financial Rules) before releasing the next instalment of a grant.
- For FCRA compliance: Associations registered under the Foreign Contribution (Regulation) Act, 2010 (FCRA) must maintain and often furnish utilisation details of foreign contribution received.
- For lenders/ECB compliance: Borrowers of External Commercial Borrowings must report end-use of funds to RBI through the AD Bank, supported by such certification.
- For tax authorities: To demonstrate that exempt income (such as grants to a charitable trust under Section 11 of the Income Tax Act, 1961) was applied for charitable purposes.
Section 3: Why is a Fund/Grant Utilisation Certificate Required?
In simple terms, the certificate exists because Indian law treats foreign exchange and earmarked grants as funds that cannot be used freely — they come with strings attached, and someone independent has to confirm those strings weren’t cut.
- Regulatory accountability: FEMA requires that foreign exchange transactions are reported truthfully; RBI monitors end-use through AD Banks.
- Donor accountability: Foreign funding agencies need assurance their money reached the intended beneficiaries/project.
- Prevention of round-tripping and money laundering: Utilisation certificates are part of the audit trail that helps prevent misuse of cross-border funds, relevant also under the Prevention of Money Laundering Act, 2002 (PMLA).
- Continued funding/grant release: Many grants are released in tranches; the next tranche is conditional upon a clean utilisation certificate for the previous one.
- Statutory/tax compliance: To claim exemptions or to justify expenditure during scrutiny/assessment.
Section 4: Who Can Issue a Fund/Grant Utilisation Certificate?
The professional who certifies the utilisation depends on the nature of the entity, the law involved, and sometimes the specific requirement of the recipient/regulator.
Chartered Accountant (CA)
In the overwhelming majority of cases — FCRA returns, ECB end-use certification, grant utilisation for NGOs/trusts, certificates for AD Banks under FEMA — a practising Chartered Accountant holding a valid Certificate of Practice issued by the Institute of Chartered Accountants of India (ICAI) is the prescribed and most widely accepted signatory. CAs are qualified under the Chartered Accountants Act, 1949 to examine books of account and issue such certifications.
Statutory Auditor
Where the entity is a company or a body whose accounts are statutorily audited (under the Companies Act, 2013 or a specific statute governing trusts/societies), the Statutory Auditor is often the appropriate person to certify utilisation, since they have direct access to and responsibility for the audited financial statements.
Cost Accountant
For certain cost-related certifications (e.g., where a grant utilisation involves project costing, cost audit compliance under Section 148 of the Companies Act, 2013), a Cost Accountant registered with the Institute of Cost Accountants of India (ICMAI) may certify the cost-related aspects, though the overall fund utilisation certificate is still typically a CA function.
Company Secretary
A Company Secretary in practice may certify compliance-related aspects (e.g., compliance with FEMA reporting timelines, Companies Act filings linked to the grant/loan), but does not typically certify financial utilisation, which falls within the CA’s domain.
Other Professionals
Government departments occasionally accept utilisation certificates signed by the Drawing and Disbursing Officer (DDO) or the Head of the institution for purely internal government scheme purposes — but where the matter touches FEMA/FERA, RBI, or foreign donors, an independent CA certificate is almost always insisted upon.
| Professional | Typical Role | Governing Body |
|---|---|---|
| Chartered Accountant | Primary certifier for FEMA/FCRA/grant/ECB utilisation | ICAI |
| Statutory Auditor | Certifies utilisation as part of/alongside statutory audit | ICAI (must be a CA firm) |
| Cost Accountant | Cost-specific aspects of project/grant utilisation | ICMAI |
| Company Secretary | Procedural/compliance certification | ICSI |
| DDO/Head of Institution | Internal government scheme UCs (Form GFR 12-A) | Concerned Government Department |
Section 5: Legal Provisions and Applicable Laws
FEMA, 1999 and erstwhile FERA, 1973
FEMA governs all current and capital account transactions involving foreign exchange. Sections 6 and 7 deal with capital and current account transactions; AD Banks (authorised under Section 10) require end-use certification before remitting funds abroad or while reporting inward remittances for grants/ECBs. FERA, though repealed, remains relevant for proceedings/transactions that took place before 1 June 2000 and are still under adjudication (FERA cases are saved and continued under Section 49 of FEMA for a limited period, and enforcement of older contraventions continues through the erstwhile Enforcement Directorate framework).
RBI Guidelines
RBI’s Master Directions on Reporting under FEMA, Master Direction on External Commercial Borrowings, Trade Credit and Structured Obligations, and various AD Bank circulars require periodic end-use certification, often via Chartered Accountant certificates, for ECBs, foreign investment, and certain inward remittances.
Foreign Contribution (Regulation) Act, 2010 (FCRA)
Associations registered or granted prior permission under FCRA must maintain separate accounts for foreign contribution and file Form FC-4 annually, which requires a Chartered Accountant’s certificate confirming the contribution received and utilised, along with a statement of receipts and payments.
Companies Act, 2013
Section 143 (Auditor’s powers and duties), Section 134 (Board’s Report), and provisions relating to related party transactions and loans (Sections 185-186) may require disclosure and certification of fund utilisation, particularly where funds raised (e.g., through preferential allotment, ECBs, or loans) must be applied for the stated object as per the offer document or board resolution.
Income Tax Act, 1961
Sections 11, 12 and 12A/12AB (charitable trusts), Section 35(1)(ii)/(iii) (scientific research grants), and Section 10(23C) exemptions require that the funds/grants received are applied for the specified charitable, religious, or research purpose; utilisation certificates support this claim during assessment.
GST Law
GST itself does not mandate a “utilisation certificate,” but grants received by way of consideration for supply (as opposed to pure donations) may attract GST; CAs often need to examine fund utilisation to determine whether GST applies, especially for government grants to NGOs/research institutions.
SEBI Regulations
For listed companies, SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 require a “Statement of Utilisation of Issue Proceeds” certified by the Statutory Auditor or a Monitoring Agency (for issues exceeding the specified threshold) to be placed before the Audit Committee and disclosed to stock exchanges.
General Financial Rules (GFR), 2017
For Government of India grants-in-aid, Rule 230 and Form GFR 12-A prescribe the format of the Utilisation Certificate that grantee institutions must submit.
| Law/Authority | Relevance to Fund/Grant Utilisation Certificate |
|---|---|
| FEMA, 1999 / FERA, 1973 | Foreign exchange end-use reporting and compliance |
| RBI Master Directions | ECB end-use certificates, AD Bank reporting |
| FCRA, 2010 | Form FC-4 annual return, CA certification of foreign contribution utilisation |
| Companies Act, 2013 | Audit and disclosure of fund application |
| Income Tax Act, 1961 | Exemption claims tied to actual application of funds |
| SEBI Regulations | Statement of utilisation of issue proceeds for listed entities |
| GFR, 2017 (Form GFR 12-A) | Government grants-in-aid utilisation certificate |
Section 6: When is a Fund/Grant Utilisation Certificate Required?
| Situation | Requirement |
|---|---|
| Receipt of foreign grant/donation by NGO/trust | Yes |
| FCRA annual return (Form FC-4) | Yes |
| External Commercial Borrowing (ECB) end-use reporting | Yes |
| Government of India grants-in-aid (GFR 12-A) | Yes |
| Listed company – utilisation of IPO/FPO/QIP proceeds | Yes |
| Bank Loan (general purpose business loan) | Sometimes (lender-specific) |
| Visa Application | Not typically (Net Worth/Income Certificate is more common) |
| Education Loan disbursed for study abroad | Sometimes (lender may ask for fee receipts instead) |
| Business Expansion funded by foreign investment | Yes, if FEMA reporting (FC-GPR/FLA) is involved |
| Research grant from foreign university/agency | Yes |
| Scientific research grant under Section 35(1)(ii)/(iii) of IT Act | Yes |
Note: Requirements vary by lender, donor, or authority. Always check the specific terms of the sanction letter, grant agreement, or RBI circular applicable to your transaction.
Section 7: Who Needs a Fund/Grant Utilisation Certificate?
- Salaried persons: Rarely need this certificate unless they have personally received a foreign scholarship/grant or remitted funds abroad under LRS for a specific declared purpose.
- Proprietors: If they have availed an ECB, received export incentive linked grants, or foreign buyer advances tied to specific use.
- Partnership firms: Similar to proprietors — relevant where foreign funds/grants are tied to firm’s business activity.
- LLPs: Where LLP has received foreign direct investment (FDI) or ECB and must report utilisation under FEMA (e.g., LLP-I/LLP-II forms with RBI).
- Companies: Most frequent users — for ECBs, FDI, IPO proceeds, government grants, and CSR-linked fund flows.
- Trusts: Mandatory for charitable/religious trusts receiving domestic or foreign grants, to support tax exemption claims and FCRA compliance.
- NGOs: One of the most common users — FCRA Form FC-4, donor reporting, and government scheme grants all need this certificate.
- NRIs: When remitting/receiving funds for a specific declared purpose (e.g., funding a relative’s medical treatment, education, or a specific project in India) under LRS or other RBI schemes, and the bank/authority seeks confirmation of end-use.
Section 8: Documents Required for a Fund/Grant Utilisation Certificate
The exact list depends on the nature of funds, but generally a Chartered Accountant will ask for:
- Grant sanction letter / loan agreement / donor agreement specifying the purpose and amount
- Bank statements showing inward remittance and all subsequent outflows
- Foreign Inward Remittance Certificate (FIRC) / Foreign Inward Remittance Advice from the bank
- Books of account (cash book, bank book, ledger) for the relevant period
- Supporting bills, invoices, and vouchers for each item of expenditure
- Board resolution/trustee resolution authorising acceptance and application of the funds
- Project report or budget approved along with the grant, for comparison against actual spend
- FCRA registration certificate/prior permission letter (for foreign contribution cases)
- Previous utilisation certificates, if the grant is released in tranches
- PAN, TAN, and registration certificates of the recipient entity (trust deed, society registration, certificate of incorporation, LLP agreement, as applicable)
- Auditor’s report and financial statements for the relevant financial year
- Declaration from management confirming no diversion of funds for purposes other than sanctioned
Section 9: Information Required by the Chartered Accountant
- Exact amount of grant/fund sanctioned and date(s) of receipt
- Purpose for which the grant was sanctioned, as per the agreement/sanction letter
- Period over which the funds were/are to be utilised
- Break-up of actual expenditure incurred against each budget head
- Unspent balance, if any, and whether it is refundable or carried forward
- Whether the funds were kept in a separate bank account (often mandatory under FCRA and grant agreements)
- Any interest earned on unutilised funds and its treatment
- Confirmation of statutory compliance — TDS deducted where applicable, GST treatment, FEMA reporting filed (e.g., ECB-2 returns, FC-GPR)
Section 10: Process of Issuing a Fund/Grant Utilisation Certificate
- Engagement and scope discussion: The CA understands the purpose of the certificate (which authority/donor it is for) and the applicable format.
- Collection of documents: Sanction letter, bank statements, FIRC, vouchers, and books of account are obtained from the client.
- Verification of receipt: The CA confirms the amount and date of receipt from bank statements/FIRC and matches it to the sanction letter.
- Examination of expenditure: Each item of expenditure is checked against supporting vouchers/invoices and mapped to the approved budget heads.
- Reconciliation: Total expenditure is reconciled with total funds received; unspent balance is identified.
- Compliance check: The CA verifies whether applicable FEMA reporting, TDS, and GST compliance have been completed.
- Drafting the certificate: The certificate is drafted in the format required by the donor/authority (or GFR 12-A format for government grants), stating facts examined and the CA’s opinion.
- Management representation: A signed management representation letter is obtained confirming the accuracy of information provided.
- Issuance: The certificate is signed, stamped with the CA’s Unique Document Identification Number (UDIN) as mandated by ICAI, and issued on the CA’s letterhead.
- UDIN generation: As per ICAI’s mandatory UDIN requirement (effective from 2019 onwards for all certificates), the CA generates a UDIN from the ICAI portal for traceability and to prevent forged certificates.
Section 11: Sample Format of a Fund/Grant Utilisation Certificate
This is an illustrative specimen only. The actual format must follow the specific requirement of the donor, bank, or government department (e.g., GFR 12-A for Government of India grants).
| CERTIFICATE OF UTILISATION OF FUNDS/GRANT | |
| To Whomsoever It May Concern | |
| Name of Recipient Entity | [●] |
| PAN | [●] |
| Name of Donor/Grantor | [●] |
| Sanction Letter Reference & Date | [●] |
| Amount of Grant Sanctioned | ₹/USD [●] |
| Amount Received and Date | ₹/USD [●] on [date] |
| Purpose of Grant | [●] |
| Period of Utilisation | [From – To] |
| Total Amount Utilised | ₹/USD [●] |
| Unspent Balance (if any) | ₹/USD [●] |
| This is to certify that we have examined the books of account, bank statements, and supporting vouchers of [Entity Name] in respect of the above grant/fund, and that the amount has been utilised for the purpose for which it was sanctioned, as detailed in the Annexure attached. | |
| For [CA Firm Name] Chartered Accountants Firm Registration No.: [●] (Signature) Name: [●], Partner/Proprietor Membership No.: [●] UDIN: [●] Place: [●] Date: [●] | |
Section 12: How a CA Verifies the Information
- Vouching: Each expense entry in the books is traced back to the original bill/invoice/receipt.
- Bank reconciliation: Receipt of grant and outflows are matched with bank statements and FIRC.
- Budget vs actual comparison: Expenditure is mapped against the approved budget heads in the sanction letter/grant agreement.
- Physical/on-site verification: Where feasible, the CA may verify assets purchased (equipment, infrastructure) physically or through photographs/asset registers.
- Third-party confirmation: Where significant, confirmations may be sought from vendors or sub-grantees.
- Statutory compliance review: TDS returns, GST returns, and FEMA filings are cross-checked for consistency with claimed expenditure.
- Management representations: Written confirmations are obtained from the entity’s management on matters not independently verifiable.
It is important to understand that a CA’s certificate is based on the records made available and reasonable verification procedures — it is not a guarantee or forensic audit unless specifically engaged as one.
Section 13: Common Reasons for Rejection
- Mismatch between amount certified and amount actually credited as per bank statement/FIRC
- Expenditure not supported by proper vouchers/invoices
- Funds utilised for a purpose different from what was sanctioned, without prior approval from the donor
- Certificate not signed by an independent, practising CA holding a valid Certificate of Practice
- Missing or invalid UDIN on the certificate
- Certificate format not matching the donor’s/authority’s prescribed format (e.g., GFR 12-A not used for government grants)
- Unexplained or unusually large unspent balance without satisfactory reason
- Funds not kept in a separate bank account where this was a mandatory condition
- Non-compliance with FEMA reporting requirements (e.g., ECB-2 return not filed) flagged alongside the certificate
- Certificate issued without adequate supporting documentation or based solely on management’s oral statements
Section 14: Validity Period of a Fund/Grant Utilisation Certificate
Unlike a Net Worth Certificate (which typically has a validity of 3-6 months from date of issue for most practical purposes), a Fund/Grant Utilisation Certificate does not “expire” in the same sense — it certifies utilisation for a specific, fixed period (e.g., a financial year or a project duration) and remains valid as a record of that period forever.
However:
- If the grant/project continues beyond the certified period, a fresh certificate is required for the subsequent period.
- Donors and government departments commonly require a fresh annual Utilisation Certificate as a condition for releasing the next tranche.
- For FCRA purposes, a fresh certificate is needed every financial year along with Form FC-4.
Section 15: Difference Between Related Certificates
Net Worth Certificate vs Income Certificate
| Aspect | Net Worth Certificate | Income Certificate |
|---|---|---|
| What it shows | Total assets minus total liabilities of a person/entity at a point in time | Income earned during a specific period |
| Typical use | Visa, loan collateral evaluation, tender eligibility | Loan eligibility, scholarship, visa (financial capacity) |
| Basis | Balance sheet, asset valuation, liability statements | Income Tax Returns, salary slips, Form 16/26AS |
Turnover Certificate vs Revenue Certificate
| Aspect | Turnover Certificate | Revenue Certificate |
|---|---|---|
| What it shows | Total sales/turnover for tender eligibility, GST/bank purposes | Often used loosely; sometimes refers to government land revenue records (a different, non-CA certificate) or total revenue for specific compliance |
| Issued by | Chartered Accountant | CA (for business revenue) or Revenue/Tehsildar office (for land revenue records) |
Working Capital Certificate vs Net Worth Certificate
| Aspect | Working Capital Certificate | Net Worth Certificate |
|---|---|---|
| What it shows | Current assets minus current liabilities — short-term liquidity position | Total assets minus total liabilities — overall financial strength |
| Typical use | Bank cash credit/working capital loan limits, tender eligibility | Visa, immigration, term loan collateral assessment |
Fund/Grant Utilisation Certificate vs Net Worth Certificate
| Aspect | Fund/Grant Utilisation Certificate | Net Worth Certificate |
|---|---|---|
| What it shows | How a specific sum of money was spent against its sanctioned purpose | Overall financial position at a point in time |
| Time orientation | Backward-looking, transaction-specific | Point-in-time snapshot |
| Governing context | FEMA/FERA, FCRA, GFR, RBI, donor agreements | General purpose (banking, visa, immigration) |
Section 16: Professional Responsibilities of the Chartered Accountant
- Exercise due professional care and skepticism in line with the ICAI’s Code of Ethics and applicable Standards on Auditing/Assurance, even when the engagement is a “certificate” rather than a statutory audit.
- Maintain independence — a CA should not certify utilisation of funds in an entity where they hold a disqualifying interest as defined under the Chartered Accountants Act, 1949 and Regulations.
- Generate a valid UDIN for every certificate issued, as mandated by ICAI.
- Retain working papers and supporting documentation for the period prescribed under the Standards on Quality Control and ICAI guidelines.
- Issue the certificate strictly based on records examined — not assumptions or unverified management claims, beyond what is reasonably represented in writing.
- Disclose clearly in the certificate the scope, basis, and any limitations of the verification carried out.
- Avoid issuing certificates that could mislead the end-user (bank, donor, RBI, tax authority) regarding the true state of affairs.
Section 17: Penalty for Misrepresentation
Misrepresentation in a Fund/Grant Utilisation Certificate can expose both the recipient entity and the certifying professional to serious consequences:
- Under FEMA, 1999: Contraventions can attract a penalty up to three times the amount involved, or up to ₹2 lakh where the amount is not quantifiable, under Section 13, along with possible compounding proceedings before RBI.
- Under FCRA, 2010: Misutilisation or misreporting of foreign contribution can lead to suspension or cancellation of FCRA registration, and prosecution under the Act.
- Under the Income Tax Act, 1961: False claims of application of funds can lead to withdrawal of exemption, reopening of assessment, and penalty under Section 270A for under-reporting of income.
- Under the Chartered Accountants Act, 1949: A CA found guilty of professional misconduct (issuing a certificate without verification, or a false certificate) faces disciplinary proceedings before ICAI’s Disciplinary Committee, which can result in reprimand, fine, or removal of name from the Register of Members for a specified period or permanently.
- Under the Indian Penal Code / Bharatiya Nyaya Sanhita, 2023: Knowingly making a false certificate can attract criminal liability for forgery/false documentation under the relevant provisions.
Section 18: Frequently Asked Questions
Q1. What is a Fund/Grant Utilisation Certificate?
It is a certificate, usually issued by a Chartered Accountant, confirming that a specific sum of money received as a grant, donation, loan, or foreign remittance was actually used for the purpose for which it was sanctioned.
Q2. Who can issue a Fund/Grant Utilisation Certificate?
Typically a practising Chartered Accountant holding a valid Certificate of Practice from ICAI. In certain government scheme contexts, the Head of Institution/DDO may certify, but for FEMA, FCRA, and donor purposes, a CA’s certificate is standard.
Q3. Is CA certification mandatory for this certificate?
For FCRA returns, ECB end-use reporting, and most donor/RBI requirements, yes — CA certification is either explicitly mandated or the universally accepted norm. For purely internal government scheme utilisation certificates, a Head of Institution’s certificate may sometimes suffice unless the scheme guidelines require CA certification.
Q4. How much does a Fund/Grant Utilisation Certificate cost?
Fees vary depending on the complexity, volume of transactions, and the entity’s location and the CA firm engaged. There is no fixed government or ICAI-prescribed fee; you should discuss the scope and fee directly with the practising CA.
Q5. Can I get this certificate online?
Many CA firms, including ours, accept documents digitally and can issue the certificate after verification, with the final certificate carrying a valid UDIN. However, the underlying verification of records must still be thorough regardless of the mode of document submission.
Q6. What is the validity period of this certificate?
It certifies utilisation for a fixed past period and does not expire, but a fresh certificate is required for each new period/tranche of funds.
Q7. Is it accepted by foreign embassies?
Embassies more commonly ask for Net Worth or Income Certificates for visa purposes. A Fund/Grant Utilisation Certificate is relevant where the embassy or a foreign authority specifically wants proof of how a grant/scholarship/remitted fund was used.
Q8. Can a bank reject this certificate?
Yes — banks/AD Banks can reject a certificate if it does not match the bank’s own records (FIRC, remittance details), is incomplete, lacks UDIN, or does not follow the format prescribed by RBI/the bank’s internal policy.
Q9. Can an NRI obtain this certificate?
Yes, if an NRI has remitted or received funds for a specific declared purpose and needs to demonstrate compliant end-use, a CA in India (or sometimes a CA with cross-border practice) can issue this certificate based on available records.
Q10. What is the difference between FERA and FEMA in this context?
FERA was the older, more rigid foreign exchange law (1973-2000) with criminal penalties for violations. FEMA, effective from 1 June 2000, replaced it with a civil/economic offence framework. Old FERA cases pending as of the transition continue under saved provisions.
Q11. Do NGOs always need this certificate?
NGOs receiving foreign contribution under FCRA need it almost every year as part of Form FC-4 filing, and domestic grant-giving agencies/government departments also commonly require it.
Q12. What documents support this certificate?
Sanction letter, bank statements, FIRC, vouchers/bills, books of account, and the original grant/loan agreement, among others detailed in Section 8 above.
Q13. Is UDIN mandatory on this certificate?
Yes. ICAI has made UDIN mandatory for all certificates issued by practising Chartered Accountants, including utilisation certificates, to prevent forged or duplicate certificates.
Q14. Can the certificate be issued in a foreign currency?
Yes, where the grant/fund was received and utilised in foreign currency, the certificate can state amounts in that currency, often alongside the INR equivalent at the prevailing exchange rate for clarity.
Q15. What happens if funds are partially unutilised?
The certificate should clearly disclose the unspent balance, and depending on the grant agreement, this balance may need to be refunded to the donor or carried forward with their written consent.
Q16. Does the certificate need to be notarised?
Not generally — a CA’s signature with UDIN and firm seal is usually sufficient. Some foreign authorities may additionally ask for notarisation or apostille, depending on their own requirements.
Q17. Can a CA refuse to issue this certificate?
Yes, if the CA is not satisfied with the documentation, finds discrepancies, or believes the funds were not utilised as represented, professional ethics require the CA to decline issuing a clean certificate rather than certify something inaccurate.
Q18. Is a separate bank account mandatory for grant funds?
Many grant agreements and FCRA rules require foreign contribution/grant funds to be kept in a separate, designated bank account to allow easy tracing and certification of utilisation.
Q19. What is the GFR 12-A format?
It is the prescribed format under the General Financial Rules, 2017 for utilisation certificates submitted by institutions receiving grants-in-aid from the Government of India.
Q20. Does GST apply to grants received?
It depends on whether the grant is a pure donation (no consideration for supply) or is linked to specific deliverables that amount to a “supply” under GST law. This needs case-specific analysis by a CA/GST consultant.
Q21. Can the certificate cover multiple grants together?
Generally, each grant/fund is certified separately to maintain clarity and traceability, especially when different donors or different conditions are attached, though a consolidated certificate with separate annexures is sometimes used.
Q22. What if the donor’s format differs from the standard CA format?
The CA should adapt the certificate content to the donor’s prescribed format while ensuring the substance, verification basis, and professional opinion remain accurate.
Q23. Is this certificate required for ECB (External Commercial Borrowing)?
Yes — RBI’s ECB framework requires periodic end-use certification (commonly through ECB-2 returns and CA certificates) to confirm the borrowed funds were used for permitted end-uses.
Q24. What are “permitted end-uses” under ECB?
RBI’s Master Direction on ECB lists permitted end-uses (e.g., capital expenditure, working capital in certain cases) and a negative list of prohibited end-uses (e.g., real estate speculation, on-lending except by NBFCs); utilisation must align with the permitted list.
Q25. Can a Cost Accountant issue this certificate instead of a CA?
For pure cost-allocation certification within a larger project, yes a Cost Accountant may certify specific cost aspects, but the overall financial fund utilisation certificate for FEMA/FCRA/RBI purposes is conventionally a CA’s domain.
Q26. Does the certificate need audited financial statements?
Where available, yes — audited financials strengthen the certificate’s reliability. For unaudited interim periods, the CA will rely on management accounts along with appropriate disclosure.
Q27. What if the entity has no formal accounting system?
The CA will need to first help the entity reconstruct basic records (cash book, ledger) before being able to verify and certify utilisation reliably.
Q28. Can the certificate be backdated?
No. A certificate must bear the actual date of issue after verification is complete; backdating would amount to professional misconduct and potentially a false certification.
Q29. How long does it take to get this certificate?
Depending on the volume of transactions and quality of records provided, it can range from a few days to a few weeks. Well-organised records with all supporting vouchers speed up the process considerably.
Q30. Is this certificate the same as a CA’s audit report?
No. An audit report expresses an opinion on financial statements as a whole; a utilisation certificate is a narrower, specific-purpose certification focused only on the application of a defined sum of money.
Q31. What if the grant was used for an emergency purpose different from the original sanction?
Most donor agreements require prior written approval for re-allocation; without such approval, this would typically count as a deviation and should be disclosed transparently in the certificate.
Q32. Can a Statutory Auditor and the utilisation-certifying CA be different persons?
Yes, an entity may engage its Statutory Auditor or a separate CA specifically for this certification, as long as independence and the donor’s/authority’s requirements are respected.
Q33. Is interest earned on unspent grant money taxable?
Generally yes, unless specifically exempted by the donor agreement or applicable tax provision; this needs to be disclosed and accounted for, and may also need to be reported back to the donor depending on the grant terms.
Q34. What is the penalty if the CA’s certificate is found false?
The CA can face ICAI disciplinary action (Section 21/22 of the Chartered Accountants Act, 1949), and depending on the facts, civil and criminal liability may also follow under other applicable laws.
Q35. Does RBI directly ask for this certificate from individuals?
Usually RBI deals through AD Banks; an individual remitting/receiving funds under LRS or similar schemes would typically furnish the certificate to their AD Bank, which in turn may report compliance to RBI.
Q36. Is a Utilisation Certificate needed for a CSR grant given by a company?
Yes — companies giving CSR grants to implementing agencies/NGOs under Section 135 of the Companies Act, 2013 typically require the recipient to furnish a utilisation certificate confirming the CSR funds were spent on the approved project.
Q37. Can the certificate be issued in digital/electronic form?
Yes, a digitally signed certificate by the CA, bearing a valid UDIN, is acceptable in most cases, subject to the specific authority’s acceptance of digital signatures.
Q38. What if part of the grant was returned to the donor?
This should be clearly disclosed in the certificate, along with the date and mode of refund, to give the donor/authority a complete and accurate picture.
Q39. Does a startup receiving a government grant need this certificate?
Yes, most startup grant schemes (Central or State government) require periodic utilisation certificates, often in the GFR 12-A format, before releasing further tranches.
Q40. Can this certificate be relied upon as the sole basis for fresh fund release?
Donors and government departments typically use the certificate as one key input alongside their own monitoring/review process; it is not always the sole determinant, especially for large grants subject to further scrutiny.
Section 19: People Also Ask
1. What is the difference between FERA and FEMA?
FERA (1973) was a criminal-offence-oriented law; FEMA (1999) replaced it with a civil-offence framework, focusing on management rather than strict regulation of foreign exchange.
2. Who enforces FEMA in India?
The Reserve Bank of India administers FEMA regulations, while the Directorate of Enforcement investigates and adjudicates contraventions.
3. What is an FIRC?
A Foreign Inward Remittance Certificate is issued by the receiving bank confirming that foreign currency was received and converted into Indian Rupees, and is key evidence for utilisation certificates.
4. What is FCRA registration?
It is registration under the Foreign Contribution (Regulation) Act, 2010, mandatory for associations wishing to receive foreign contributions/donations regularly in India.
5. What is Form FC-4?
It is the annual return that FCRA-registered associations must file online with the Ministry of Home Affairs, detailing receipt and utilisation of foreign contribution, supported by a CA certificate.
6. What is an ECB?
An External Commercial Borrowing is a loan availed by an Indian entity from a foreign lender, governed by RBI’s ECB framework under FEMA.
7. What is the Liberalised Remittance Scheme (LRS)?
LRS allows resident individuals to remit up to USD 2,50,000 per financial year abroad for permitted current and capital account transactions, without prior RBI approval, subject to documentation.
8. Is UDIN compulsory for all CA certificates?
Yes, ICAI has made UDIN mandatory for all certificates, GST and tax audit reports, and other attest functions issued by practising CAs since 2019.
9. What happens if FCRA return is not filed on time?
Late filing of Form FC-4 attracts penalty as prescribed under FCRA rules and can also risk suspension of FCRA registration for continued non-compliance.
10. Can a private trust receive foreign donations?
Only if it is registered under FCRA or has obtained prior permission; receiving foreign contribution without FCRA compliance is a contravention of the Act.
11. What is the penalty for FEMA violation?
Under Section 13 of FEMA, the penalty can extend up to three times the sum involved, or up to ₹2 lakh if the amount is not quantifiable, with additional daily penalty for continuing contraventions.
12. Can FEMA contraventions be compounded?
Yes, RBI has a compounding mechanism under FEMA that allows contraveners to settle the matter by paying a compounding amount, avoiding prolonged adjudication.
13. What is the role of an AD Bank?
An Authorised Dealer Bank is licensed by RBI to deal in foreign exchange and acts as the first point of compliance check for most FEMA-related remittances and reporting.
14. Is a Utilisation Certificate the same as a Statement of Accounts?
No, a Statement of Accounts merely lists transactions; a Utilisation Certificate is a professional’s certified opinion confirming the funds were used for the sanctioned purpose.
15. What is Form FC-GPR?
It is the form filed with RBI through the AD Bank reporting allotment of shares to a foreign investor following receipt of FDI, relevant where FDI funds also need end-use tracking.
16. Can a sole proprietorship receive FDI?
No, FDI is generally permitted into companies, LLPs, and certain other structures recognised under FEMA’s FDI regulations, not into a sole proprietorship.
17. What is the negative list under ECB end-use?
It includes uses such as real estate activities (with limited exceptions), investment in capital markets, and on-lending to other entities except by NBFCs, as specified in RBI’s ECB Master Direction.
18. Does a Utilisation Certificate need to mention TDS compliance?
It is good practice to confirm TDS was deducted and deposited on applicable expenditure, since non-compliance could affect the genuineness of the claimed expenditure.
19. What is a Monitoring Agency under SEBI regulations?
For large public issues, SEBI requires appointment of an independent agency (often a Credit Rating Agency or similar) to monitor and report on utilisation of issue proceeds.
20. Can NGOs use foreign grants for administrative expenses?
FCRA rules cap administrative expenses (generally at 20% of the utilised foreign contribution in a financial year) unless special permission is obtained; this must be reflected correctly in utilisation reporting.
21. What is the difference between FCRA registration and prior permission?
Registration is a one-time, renewable approval for ongoing receipt of foreign contributions; prior permission is a one-time approval limited to a specific donor and specific amount/purpose.
22. Is FCRA applicable to individuals?
FCRA primarily targets associations/organisations; however, certain restrictions also apply to specified categories of individuals (e.g., those in government service, judges, election candidates) receiving foreign contribution.
23. What is Form ECB-2?
It is the monthly return filed by the borrower through the AD Bank, reporting drawdown, utilisation, and outstanding ECB amounts to RBI.
24. Can a foreign grant be used for capital asset purchase?
Yes, if the grant agreement permits capital expenditure; the utilisation certificate should clearly identify and value such capital assets purchased.
25. What is the difference between grant-in-aid and a loan?
A grant-in-aid generally does not require repayment, while a loan creates a repayment obligation; utilisation certification requirements and underlying laws differ accordingly.
26. Who certifies utilisation for Central Government schemes for startups?
Typically a practising Chartered Accountant, following the scheme guidelines, which often mirror the GFR 12-A format or a scheme-specific format.
27. Can a company use ECB funds to repay a domestic rupee loan?
Refinancing of domestic rupee loans through ECB is permitted only in specific circumstances and subject to RBI conditions under the relevant Master Direction; it is not a blanket permitted use.
28. What if a donor wants the certificate audited by a “Big 4” firm only?
This is a contractual condition set by the donor in the grant agreement; the recipient must comply with such a specific requirement if it has been mutually agreed upon.
29. Is a Utilisation Certificate required for personal remittances to family abroad?
Generally no formal utilisation certificate is required for routine personal remittances such as maintenance of close relatives, though documentation of purpose is still advisable for LRS compliance.
30. What is the consequence of FCRA registration cancellation?
A cancelled FCRA registration bars the association from receiving foreign contribution for a specified period and may require surplus foreign contribution to be transferred to a government-prescribed fund.
Section 21: Conclusion
A Fund/Grant Utilisation Certificate is one of those documents that quietly underpins trust in cross-border and grant-funded transactions — between donor and recipient, between regulator and regulated entity, and between lender and borrower. Whether you are an NGO reporting under FCRA, a company managing an ECB, or an individual accounting for a foreign remittance, getting this certificate right starts with maintaining clean, well-documented records from day one.
If you are unsure which format applies to your situation, or whether your transaction even requires this certificate under FEMA, FCRA, or any other law, it is best to consult a practising Chartered Accountant before the funds are even received — proper planning at the start makes the certification process far smoother later.
Section 22: Disclaimer
This article is intended for general informational purposes only and does not constitute professional advice. The issuance of any Fund/Grant Utilisation Certificate depends entirely on the verification of actual records, supporting documents, and the professional judgement of the Chartered Accountant concerned in each specific case. Laws, RBI/FEMA circulars, and ICAI guidelines referred to herein are subject to amendment from time to time; readers should verify the current applicable provisions or consult a qualified professional before relying on this content for any specific transaction or filing.
Suggested Internal Links
- Net Worth Certificate by Chartered Accountant – Complete Guide
- Foreign Contribution Regulation Act (FCRA) Registration – Process & Compliance
- ECB Compliance & RBI Reporting for Indian Companies
- Income Tax Exemptions for Charitable Trusts under Section 11 & 12A
- FEMA Compliance Checklist for Indian Businesses
Suggested External Authority References
- Reserve Bank of India – Master Directions on Foreign Exchange Management (rbi.org.in)
- Ministry of Home Affairs – FCRA Online Portal (fcraonline.nic.in)
- Institute of Chartered Accountants of India – UDIN Portal (udin.icai.org)
- Department of Expenditure, Ministry of Finance – General Financial Rules, 2017 (doe.gov.in)
- Securities and Exchange Board of India – ICDR Regulations (sebi.gov.in)

