Section 332 Transition: How Existing 12A/12AB Entities Migrate to RNPO Under IT Act 2025

The Income Tax Act, 2025 came into force on 1 April 2026, replacing the Income Tax Act, 1961. For the approximately 3 lakh charitable trusts, NGOs, and institutions registered under the old Act, the immediate question is: what happens to our 12A/12AB/10(23C) registration? Do we need to re-apply? When? How? And what changes in practice?

This guide answers these questions with scenario-based transition steps for every type of existing registration - 12A (perpetual), 12AA, 12AB, and 10(23C) - covering the automatic migration, renewal timeline, section mapping between old and new Acts, and the specific action items your NGO must complete.

The Core Transition Rule: Section 355 of IT Act 2025

Section 355(g) of the Income Tax Act 2025 defines a Registered Non-Profit Organisation (RNPO) as any person having a valid registration under any 'specified provision' and whose registration has not been cancelled. The 'specified provisions' include:

• Section 12A of the old Act (perpetual registrations granted before 2021)
• Section 12AA of the old Act (registrations granted between 2010-2021)
• Section 12AB of the old Act (5-year registrations granted from 2021 onwards)
• Section 10(23C) of the old Act (approvals for universities, hospitals, educational institutions)
• Section 332 of the new Act (registrations granted under the 2025 Act)

This means: if your entity holds a valid, non-cancelled registration under any of the old sections, you are automatically an RNPO from 1 April 2026. No application, no form, no fee, no action required for the transition itself. Your existing registration number continues. Your tax exemption continues. Your 80G approval continues. You simply operate under the RNPO label going forward. For a comprehensive overview of the RNPO framework, see our NGO and trust registration rules 2026 guide.

Section Mapping: Old Act to New Act

The following table maps the old Income Tax Act 1961 sections to their equivalents in the IT Act 2025:

Key takeaway: The forms (10A, 10AB, 10B/10BB, ITR-7) remain the same. The section numbers change. The operational rules (85% application, audit, filing) remain substantively identical. The transition is primarily a labelling and numbering exercise - not a substantive change in law.

Scenario-Based Transition Guide: What You Must Do Based on Your Current Registration

Scenario 1: Entity with 12AB registration (granted 2021-2025, 5-year validity).

This is the most common scenario. Your 12AB registration was granted between April 2021 and March 2026, valid for 5 years.

• Automatic transition: Yes - you are automatically an RNPO from 1 April 2026. No action needed.
• When to renew: File Form 10AB at least 6 months before your 12AB expiry date. Example: 12AB granted April 2022, expiry March 2027 → file Form 10AB by September 2026.
• Renewal validity: 5 years under Section 332. If your income does not exceed Rs 5 crore in each of the 2 preceding tax years, you qualify for 10-year registration.
• Action item: Note your 12AB expiry date. Set a reminder for 8 months before expiry. Prepare audited financials for 3 years. File Form 10AB on time.

Scenario 2: Entity with old perpetual 12A registration (pre-2021, never migrated to 12AB).

Some entities obtained 12A registration before 2021 when registrations were perpetual (no expiry). Most were required to migrate to 12AB in 2021-22, but some may not have completed the migration.

• If migrated to 12AB in 2021-22: Follow Scenario 1 above. Your 12AB has a 5-year validity - renew before expiry under Section 332.
• If NOT migrated to 12AB: Your old 12A registration technically continues under the transition provisions. However, this is a compliance risk - the Income Tax Department may not recognise it as active without the 12AB migration. Recommended action: Apply for Section 332 registration immediately using Form 10AB as a fresh/renewal application to regularise your status.

Scenario 3: Entity with 12AA registration (granted 2010-2021).

12AA registrations granted between 2010 and 2021 were supposed to be migrated to 12AB by 2021-22. If migrated, follow Scenario 1. If not migrated, the same risk applies as Scenario 2 - regularise immediately under Section 332.

Scenario 4: Entity with 10(23C) approval (universities, hospitals, educational institutions).

Section 10(23C) approvals for specified institutions (universities, hospitals, educational institutions with annual receipts above Rs 5 crore) are now covered under Section 332.

• Automatic transition: Yes - valid 10(23C) approvals continue as RNPO status.
• When to renew: Same rule - 6 months before expiry, file Form 10AB under Section 332.
• Key difference: Under the new Act, the 10(23C) regime is fully merged into the RNPO framework. There is no separate 10(23C) track anymore. All compliance (audit, ITR-7, 85% rule) is identical to trusts registered under the former 12AB. For entities needing professional support with the transition filing, 12A and 80G registration services include Section 332 renewal assistance.

Scenario 5: Newly formed entity (post-1 April 2026).

Entities formed after 1 April 2026 apply directly under Section 332 of the new Act - they never had old-Act registrations. The process is: Form 10A for provisional registration (3 years) → build track record → Form 10AB for regular registration (5 or 10 years).

The 80G Transition: Section 354 Is Separate from Section 332

This is one of the most important points existing entities must understand: 80G renewal is a SEPARATE process from RNPO (Section 332) renewal.

Under the old Act, 80G registration was governed by Section 80G(5). Under the new Act, it moves to Section 354. Like RNPO, existing 80G registrations continue until their expiry date. But the renewal must be filed independently:

• Section 332 (RNPO): Renewal via Form 10AB for tax exemption of the entity's income
• Section 354 (80G): Separate renewal via Form 10AB (selecting the 80G option) for donor tax deduction eligibility

Both must be renewed. Both use Form 10AB (but filed separately with different section selections). Both must be filed 6 months before expiry. Missing either one has different consequences: losing Section 332 means the entity's income is taxed. Losing Section 354 means donors cannot claim deductions - reducing donation inflows.

Note: Section 354 (80G) renewal is always 5 years - there is no 10-year extension for 80G even if the entity qualifies for 10-year RNPO registration under Section 332. The two renewal cycles may fall out of sync - track both dates independently.

What Changes vs What Stays the Same

Action Items Checklist for Existing Entities

1. 1. Note your current 12AB/80G expiry dates. Check your 12AB registration certificate and 80G approval letter for the validity period. Set calendar reminders for 8 months before each expiry date.
2. 2. Confirm your registration status on the IT portal. Login to incometaxindia.gov.in and verify that your entity shows as 'Active' with a valid registration number. Any discrepancy should be resolved immediately.
3. 3. Continue all existing compliance unchanged. File ITR-7 by 31 October, upload Form 10B/10BB by 30 September, file Form 10BD by 31 May, maintain 85% application, and file Form FC-4 by 31 December (if FCRA-registered). Nothing changes in the compliance calendar. For professional tax audit support, ensure your CA is familiar with the revised ITR-7 for AY 2026-27.
4. 4. File Section 332 renewal (Form 10AB) 6 months before 12AB expiry. When renewal is due, file Form 10AB selecting the Section 332 option. Attach: audited financials for 3 years, activity reports, trustee/director KYC, and entity registration documents. Processing: 1-3 months.
5. 5. File Section 354 renewal (Form 10AB) 6 months before 80G expiry. Filed separately from Section 332 renewal. Same form (10AB) but different section selection. Same documents. Track the 80G expiry date independently - it may be different from the RNPO expiry date.
6. 6. Check 10-year eligibility. If your entity's total income (before exemptions) did not exceed Rs 5 crore in each of the 2 preceding tax years, you may qualify for 10-year RNPO registration instead of 5 years. This applies only to Section 332 - not Section 354 (80G), which is always 5 years. Calculate your income for the 2 preceding years before filing Form 10AB.
7. 7. Update internal documentation. Update your letterhead, donation receipts, and website to reflect RNPO terminology if you reference the Income Tax Act. While not legally mandatory immediately, it demonstrates awareness and compliance. For NGOs also managing accounting and bookkeeping, ensure the chart of accounts reflects any revised reporting categories.

Common Transition Mistakes to Avoid

Mistake 1: Panic-applying for fresh Section 332 registration. Some entities, confused by the new Act, are filing fresh Form 10A applications thinking they need to re-register. This is unnecessary and incorrect. Your existing registration continues automatically. A fresh Form 10A creates a duplicate record and confuses the system. Wait for your existing registration to approach expiry, then file Form 10AB for renewal.

Mistake 2: Assuming 80G renewal happens automatically with RNPO renewal. Section 332 (RNPO) and Section 354 (80G) are separate registrations with separate renewal cycles. You must file two separate Form 10AB applications - one for each. Missing the 80G renewal means donors lose their deduction benefit even though the entity remains tax-exempt.

Mistake 3: Not checking the expiry date of existing registration. Many 12AB registrations granted in 2021-22 expire in 2026-27. If your registration expires in, say, September 2026, you should have filed Form 10AB by March 2026 (6 months before). Entities that miss this window may face a gap in registration - and any income during the gap is fully taxable.

Mistake 4: Ignoring the new ITR-7 format for AY 2026-27. CBDT has notified a revised ITR-7 form for AY 2026-27 (effective 31 March 2026). The new form includes additional disclosures on capital gains, foreign contributions, and accumulated income. Ensure your CA uses the updated form - filing the old format may result in a defective return.

Mistake 5: Failing to leverage the 10-year registration benefit. Small trusts with income under Rs 5 crore in each of the 2 preceding years qualify for 10-year registration under Section 332 - double the standard 5-year period. This reduces renewal frequency and compliance burden. Check eligibility before filing Form 10AB and claim the 10-year option if qualified. For NGOs assessing their eligibility, income tax return filing services can compute the qualifying income threshold.

Timeline: When Different Types of Entities Must Act

Key Takeaways

Existing registrations under Sections 12A, 12AA, 12AB, and 10(23C) of the old Income Tax Act automatically transition to RNPO status under Section 355 of the Income Tax Act 2025 from 1 April 2026 - no fresh application, no form, no fee is required for the transition itself, and all tax benefits continue uninterrupted until the existing registration expires.

When renewal is due, entities file Form 10AB under Section 332 (for RNPO/tax exemption) and separately under Section 354 (for 80G/donor deduction) at least 6 months before their respective expiry dates - these are two independent processes that may have different expiry dates and must be tracked separately.

The substantive rules remain identical: 85% application of income for charitable purposes, Form 10B/10BB audit by 30 September, ITR-7 by 31 October, Form 10BD by 31 May, and the same accumulation rules via Form 10 - the changes are primarily in section numbering (12A→332, 80G→354, 11/12→334-342, 13→351-353) and terminology (Trust/Institution→RNPO, Previous Year→Tax Year).

Small trusts with total income not exceeding Rs 5 crore in each of the 2 preceding tax years qualify for 10-year RNPO registration instead of the standard 5 years - a significant new benefit under Section 332 that reduces renewal frequency - but this extended validity does NOT apply to Section 354 (80G), which remains at 5 years always.

The most common transition mistakes are: panic-filing fresh Form 10A (unnecessary - existing registration continues), assuming 80G renewal is automatic with RNPO (it is separate), missing the 6-month-before-expiry renewal window (creates taxable gap), and not using the revised ITR-7 format for AY 2026-27 (defective return risk).

Need Help with the Section 332 Transition? We Handle It End-to-End

The transition from the old Act to the new Act is designed to be smooth - but timing is critical. Missing the 6-month renewal window creates a taxable gap. Filing the wrong form or section wastes time. Not tracking 80G separately from RNPO creates donor relationship damage.

Explore our 12A and 80G registration services - covering Section 332 RNPO renewal, Section 354 80G renewal, Form 10AB filing, 10-year eligibility assessment, and ongoing annual compliance management for trusts, societies, and Section 8 companies.

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