Categories: NGO

Registered Non-Profit Organisation under Income-tax Act 2025

What is an Registered Non-Profit Organisation under the Income-tax Act, 2025?

A Registered Non-Profit Organization (RNPO) is a new, unified statutory classification introduced in the proposed Income Tax Act, 2025, which is scheduled to come into force from 1 April 2026. The Registered Non-Profit Organisation concept consolidates all earlier tax regimes applicable to charitable and religious institutions into a single, uniform framework.  This reform is not about creating a new type of entity. it is about simplifying, standardizing, and modernizing the tax architecture governing nonprofit organizations.

Why RNPO Was Introduced

Under the 1961 Act, the provisions governing nonprofits were scattered across many sections, such as 2(15), 10(23C), 11, 12, 12A, 12AA, 12AB, 13, 80G, etc. This fragmentation led to overlapping regimes, confusion, and litigation. The Income-tax Act, 2025, consolidates all these provisions into Part B of Chapter XVII (Sections 332–355). This makes the Registered Non-Profit Organization regime a single code for all non-profit taxation.

Unified Terminology

The term “registered non-profit organization” replaces multiple earlier expressions such as “trust,” “society,” “charitable institution,” “religious institution,” “NGO,” etc. The goal is terminological clarity: one category, one compliance system, and one exemption framework.

Automatic Migration of Existing Entities

Entities already registered under Sections 12A / 12AA / 12AB or Section 10(23C) of the 1961 Act will automatically transition to RNPO status, provided their current registration is valid and not cancelled. No fresh registration is needed; tax benefits continue seamlessly. Key Features of the RNPO Framework

  1. Consolidation of Law

All earlier provisions relating to charitable and religious institutions are now consolidated into a single chapter to ensure coherence and reduce ambiguity. The word count for NPO-related provisions has been reduced from ~12,800 to ~7,600, making it clearer and more accessible.

  1. Restrictions on Commercial Activities

Registered Non-Profit Organisation cannot carry on commercial activities except those incidental to their charitable purpose. Non-incidental commercial activities may jeopardise Registered Non-Profit Organisation status. (This principle is consistent with the long-standing charitable purpose test carried over into the 2025 Act.)

  1. Application & Accumulation of Income

  • The 85% application rule is retained.
  • 15% remains as deemed accumulated income.
  • Investments must follow prescribed modes.

The 2025 Act codifies long‑standing judicial interpretations into statute.

Revised Regulatory Framework for Registered Non-Profit Organisation

Regulatory Intent Behind Registered Non-Profit Organization: The reform aims at simplification, uniformity, litigation reduction, and greater clarity for compliance officers, tax administrators, and non-profits. As experts note, the new Registered Non-Profit Organization framework eliminates redundant provisions, reduces cross‑references, and enhances ease of compliance.

Donor Deductions Simplified : The old Section 80G regime is consolidated under Section 354 of the 2025 Act. Registered nonprofit organizations remain eligible for donor deductions subject to compliance.

What RNPO Does Not Change : The Registered Non-Profit Organization is not a new tax privilege. The fundamental principles remain intact: purpose test, application of income, compliance discipline & restriction on private benefit. The reform changes how nonprofits are classified and regulated, not the underlying philosophy of charitable taxation.

Commercial Activities

  • Registered Non-Profit Organisation cannot carry on commercial activities
  • Exception: Activities incidental to charitable objectives
  • Non-incidental commercial activity can jeopardise Registered Non-Profit Organisation status

Application & Accumulation of Income

  • Minimum 85% application rule retained
  • Up to 15% treated as “deemed accumulated income.”
  • Such accumulation must be invested strictly as per prescribed modes

This codifies earlier judicial interpretations into statute.

Donor Deductions

  • Provisions relating to donor deductions (earlier Section 80G)
  • Now consolidated under Section 354 of the 2025 Act
  • Deduction eligibility continues, subject to RNPO compliance

When Does the Registered Non-Profit Organisation Regime Begin? : The Income Tax Act, 2025—including RNPO provisions—is proposed to take effect from 1 April 2026. Registered Non-Profit Organization is the new unified tax identity for all charitable and religious organisations under the Income Tax Act, 2025, replacing fragmented regimes with a single, simplified statutory framework.

Comparative between 12AB vs RNPO Obligations

Particulars Regime under Income-tax Act, 1961 (Section 12AB / 10(23C)) Regime under Income-tax Act, 2025 (RNPO Framework)
Legal Classification Trust / Society / Institution / NGO / Charitable or Religious Entity Registered Non-Profit Organisation (RNPO) single statutory category
Governing Provisions Scattered across multiple sections: 2(15), 10(23C), 11, 12, 12A, 12AA, 12AB, 13, 80G Consolidated in Part B of Chapter XVII (Sections 332–355)
Registration Authority Registration under 12AB or approval under 10(23C) Unified registration as RNPO
Terminology Multiple overlapping terms (trust, institution, fund, NGO) Single uniform term  RNPO
Transition / Migration Fresh registration often required on conversion or amendment Automatic migration for existing registered entities (if registration valid)
Validity of Registration Time-bound registration (typically 5 years) Expected structured periodic validity & renewal under RNPO rules
Charitable Purpose Test Defined under Section 2(15) Retained but codified within RNPO framework
Commercial Activity Allowed if incidental to objects (Section 11(4A)); litigation-prone Explicitly restricted; only incidental permitted
Separate Books for Business Activity Mandatory if business incidental Continues to be mandatory
Application of Income Rule Minimum 85% application required 85% rule retained
Accumulation of Income 15% permitted; additional accumulation via Form 10 15% treated as “deemed accumulated income” with prescribed investment norms
Investment Restrictions Section 11(5) specified modes Codified and aligned under RNPO provisions
Violation Consequences Exemption denial under Section 13 / cancellation under 12AB RNPO cancellation/suspension/denial of exemption under unified regime
Cancellation Grounds Specified under Section 12AB(4) Expanded & codified cancellation triggers
Donor Deduction Provision Section 80G Section 354 (RNPO donor deduction regime)
Reporting & Compliance Form 10B/10BB audit, ITR-7 filing Expected unified reporting architecture
Assessment Framework Multiple parallel regimes (11–13 vs. 10 (23°C)) Single assessment & exemption framework
Litigation Exposure High due to fragmented provisions Designed to reduce disputes via clarity
Regulatory Objective Exemption-driven Governance-driven compliance framework

12AB regulated entities. RNPO regulates the ecosystem.

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Rajput Jain & Associates is a Chartered Accountants firm, with it's headquarter situated at New Delhi (the capital of India). The firm has been set up by a group of young, enthusiastic, highly skilled and motivated professionals who have taken experience from top consulting firms and are extensively experienced in their chosen fields has providing a wide array of Accounting, Auditing, Taxation, Assurance and Business advisory services to various clients and their stakeholders. Rajput jain & Associates, a professional firm, offers its clients a full range of services, To serve better and to bring bucket of services under one roof, the firm has merged with it various Chartered Accountancy firms pioneer in diversified fields. We have associates all over India in big cities. All our offices are well equipped with latest technological support with updated reference materials. We have a large team of professionals other than our Core Team members to meet the requirements of our prospective clients including the existing ones. However, considering our commitment towards high quality services to our clients, our team keeps on growing with more and more associates having strong professional background with good exposure in the related areas of responsibility.

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