Chartered Accountant · ICAI M.No. 153926 · FRN 136869W · Reviewed on 12 October 2026
What changed, structurally
Old world: register once under 12A (pre-1996) or 12AA, hold it forever unless cancelled. New world since 1 April 2021: all registrations run through section 12AB with expiry dates — five years for regular registration, three years provisional for trusts yet to commence activities — applied for in Form 10A/10AB (Forms 104/105 from 1 April 2026), granted electronically with a URN. The same overhaul hit 80G approvals, which now also run in renewable blocks, plus the annual 10BD (Form 113 from 1 April 2026)/10BE (Form 114 from 1 April 2026) donation-reporting trail.
The renewal discipline
Renewal applications are due at least six months before expiry (provisional registrations convert within six months of starting activities, or before expiry, whichever is earlier). Diary it like a statutory due date — a lapsed 12AB doesn’t just pause the exemption; it can trigger the section 115TD exit tax on the trust’s accreted income, which is the single most expensive miss in the trust world. Renewals also reopen the trust deed and activities to scrutiny, so keep objects, books and filings consistent throughout the block.
What stays the same
The operating rules of exemption are untouched: 85% application of income, the audit under section 12A(1)(b) read with Rule 17B (Form 10B/10BB (Form 112 from 1 April 2026)), ITR-7 filing, section 13 specified-person discipline, and 115BBC on anonymous donations. If your trust still quotes a 12A certificate from 2004, it has either been migrated — check the URN — or it has silently lapsed; both are worth confirming today. Our 12AB & 80G practice handles migrations, renewals and the annual trail.