Suggestion by VANI to Home Secretary, 20th May 2022
The recent news reports of alleged corrupt practices by some junior officials, intermediaries and voluntary organisations in the approval of applications for FCRA registrations/renewals has highlighted the risks inherent in current FCRA processes.
While the Department and the Ministry are doubtless working to reduce the risk of such infractions in future, we would like to make some suggestions for changes on
behalf of the sector:
1. Simplify the FCRA registration, renewal and reporting forms.
2. Give clear reasons for rejecting registration or renewal applications in addition to mentioning the provisions of the Act with which the organisation is not compliant.
3. Establish a Grievance Redressal/ Appellate process where queries and complaints from voluntary organisations can be dealt with under specified timetable and escalation process.
4. To cut down on the delays (averaging 12-15 months) in renewal process, we suggest that revalidation of checks already performed during initial registration should be done away with.
S. In order to ensure greater efficiency, time-bound approvals and enhance accountability, MHA could outsource the administrative processes on the lines of passport issuance/renewal processes. Sensitive aspects such as Intelligence Bureau inputs and decision-making can be retained with the Department.
6. These processes could be further streamlined by focusing scrutiny on entities deemed to pose significant potential risk of misuse for terrorism, money laundering or other criminal ends as recommended by the Financial Action Task Force (FATF).
7. Accompanying the above steps with a concerted campaign to educate Voluntary Organisations about the potential risks and consequences of misuse, would go a long way towards building support for compliance.
As you are aware, vast majority of Voluntary Organisations in India deliver critically needed services, to the most underserved and marginalised of our fellow citizens, under extremely challenging circumstances; without ever knowingly violating any provision of law. Focusing the resources of the Ministry on streamlining the abovementioned steps would maximise both effectiveness and efficiency.