Contract management for foundations and non-profits

Foreign contribution: no sub-granting, 20% administrative cap, one bank branch

The Foreign Contribution (Regulation) Amendment Act, 2020, in force from 29 September 2020, rewrote section 7 of the FCRA so that a registered recipient of foreign contribution may not transfer it to any other person, cut the administrative-expense cap in section 8 from 50% to 20%, and under section 17 requires foreign contribution to be received in an FCRA Account at the State Bank of India's New Delhi Main Branch, with further utilisation accounts allowed elsewhere. For grant agreements this means a foreign-funded project cannot provide for onward grants to implementing partners; partners must be engaged as service providers under contracts for defined deliverables, budgets must hold administrative costs within 20%, and donor remittance instructions must name the designated account. Registration is valid for five years, renewal must be applied for in the six months before expiry, and the annual return in Form FC-4 is due within nine months of the year end.

• IntelloContract: partner agreements drafted from a template that is a services contract, not a sub-grant, with AI review flagging onward-transfer language.
• IntelloComply: FCRA renewal, FC-4 filing and administrative-cap monitoring as dated obligations with owners and evidence.

CSR funding: registration, unspent amounts and impact assessment

Under section 135 of the Companies Act, 2013 and the Companies (CSR Policy) Rules, 2014 as amended from 22 January 2021, an implementing agency must be registered with the Ministry of Corporate Affairs in Form CSR-1 before taking on a new project; unspent amounts on ongoing projects must be transferred to an Unspent CSR Account within 30 days of the financial year end and spent within three financial years; and companies with a CSR obligation of ₹10 crore or more must commission impact assessments of completed projects of ₹1 crore or more. CSR grant agreements should carry the agency's CSR-1 number, define whether the project is ongoing, match utilisation and reporting timelines to the 30-day and three-year rules, and give the company access for impact assessment.

Government grants: the utilisation certificate clock

Rule 238 of the General Financial Rules, 2017 requires a certificate of actual utilisation in Form GFR 12-A for non-recurring grants, with output-based performance reporting, submitted within twelve months of the close of the financial year; a ministry may blacklist a grantee that fails to submit it. A sanction order is a contract with a utilisation covenant, and grantees should mirror the twelve-month and output-reporting obligations in their downstream agreements with partners and vendors.

Registrations that expire

Tax-exemption registration and donor-deduction approval under the income-tax law run on five-year cycles, with renewal applications due months before expiry and an annual statement of donations to file; because the Income-tax Act, 2025 came into force on 1 April 2026 and renumbered the 1961 Act, agreement templates that cite old section numbers need a cross-reference pass. State society and trust laws add their own filings: the Societies Registration Act, 1860 requires an annual list of the governing body within fourteen days of the annual general meeting, Karnataka adds audited accounts to that list, Telangana requires the list within fifteen days of the general body meeting, and the Maharashtra Public Trusts Act, 1950 requires registration within three months of creation, change reports within 90 days and annual audited accounts. Donor due diligence and bank KYC turn on these filings, so they belong on the same calendar as the grants they enable.

Why one platform

The donor agreement, the partner contract, the covenant and the registration that makes them possible are one chain. IntelloSync keeps the contract, the vendor record, the obligation and the evidence on one repository with one permission model. IntelloContract drafts and negotiates agreements as real Word documents, routes approvals and executes with Aadhaar eSign, DSC or virtual signatures and e-stamping. IntelloVendor onboards and risk-scores third parties. IntelloComply puts statutory and contractual obligations on a calendar with owners, reminders, evidence and an audit trail. IntelloVault stores and indexes every signed document. Pricing is per module with unlimited users, and the platform is ISO/IEC 27001:2022 certified.