Chartered Accountant · ICAI M.No. 153926 · FRN 136869W
Old vs new
12A/12AA: one-time. 12AB: fixed-period registration that expires and renews.
Migration + renewal
Existing trusts re-registered under 12AB and now track renewal dates.
What the migration changed in practice
The shift from 12A/12AA to 12AB was more than administrative. Under the old regime, a registration once granted was effectively permanent, with little periodic re-examination. The 12AB regime made registration time-bound — provisional for three years for new trusts, five years for established ones — and renewable, which means the department revisits the genuineness of activities at each renewal in Form 10AB. Every existing trust had to migrate by re-applying in Form 10A within the window, and trusts that missed it risked losing their exemption. The regime also linked 12AB and 80G more tightly to annual reporting: the donation statement in Form 10BD and the donor certificate in Form 10BE became part of the 80G machinery, and tighter conditions and an exit tax on accreted income were introduced for trusts that lose registration. The exemption a registered trust enjoys is the same as before — income applied to objects is exempt — but the compliance is more active: track the validity, renew ahead of expiry, file the donation statements, and keep the activities genuinely charitable. For trustees the practical change is simply that registration is now something to maintain on a calendar, not file once and forget. Confirm the current renewal timelines.