On 22 June 2026, the Union government notified the Foreign Contribution (Regulation) Amendment Rules through the Ministry of Home Affairs. Parliament has not yet passed the Bill that would give these Rules statutory backing. It was introduced in the Lok Sabha in March, referred to a Joint Parliamentary Committee (JPC) after several parties objected, and is expected to return in the monsoon session that started on Monday (July 20). Parliament is supposed to debate and approve changes before they become law. Instead, churches, schools, hospitals, and charities have already begun complying with the new disclosure and registration conditions. By the time parliament takes up the Bill, the new framework will already be running, and scrutiny risks becoming a formality that merely ratifies decisions already taken.Christian institutions are among those most affected. There’s no denying they are deeply woven into India’s education and healthcare systems. Missionary societies built schools, colleges, hospitals, and orphanages long before independence, often in regions where public services were limited, and many still serve millions of Indians regardless of religion or caste. Many also rely on long-standing overseas church funding. Unfortunately, that historic feature has now become a source of vulnerability.The government says stronger regulation is needed to improve transparency, prevent misuse of funds, and protect national security. These are legitimate goals. Every sovereign state can regulate foreign funding, and the Supreme Court has held that receiving foreign contributions is a statutory privilege, not a fundamental right. However, the real question is whether the Rules regulate it fairly and proportionately.Excessive rigidityMeasures meant to prevent misuse by a few should not burden thousands with long records of lawful service. Amendments to the FCRA since 2020 have steadily expanded executive control over foreign-funded organisations, on the grounds that some NGOs interfere in domestic affairs. Such concerns may justify closer scrutiny where there is credible evidence, but not treating every religious or charitable institution as a source of suspicion.Independent assessments of India’s anti-money laundering framework have favoured a risk-based approach: focusing on organisations with identifiable risks, while allowing the wider charitable sector to function with minimal disruption. The new Rules do the opposite, imposing similar compliance obligations on every organisation regardless of size or record.Also read: In New FCRA Rules, Govt Wants NGOs to Declare Social Media Accounts, Specify Purpose and ScopeLarge dioceses may eventually build capacity to meet these requirements. Small parish trusts and tribal missions, which often have no lawyers or compliance officers, face the same demands. The Rules also reduce the flexibility these institutions have traditionally used to respond to community needs. Earlier, an organisation registered under broad categories such as education, religion, or social service could adapt its programmes as circumstances changed. A church running a school could start a health clinic during a disease outbreak without redesigning its registration. The new framework requires organisations to list specific approved activities and states, and any change now requires fresh approvals. Excessive rigidity can weaken the very organisations governments rely on during emergencies, since community needs do not always fit predetermined categories.Additionally, the Rules prohibit foreign contributions from being used for “proselytisation,” but the term is left undefined. State laws already address religious conversion through force, fraud, or material inducement. The new Rules permit foreign funding for worship, religious education, and charitable work, while banning “proselytisation” without explaining where one ends and the other begins. That uncertainty shifts interpretation from the law to individual officials. For Christian institutions, this is not a minor technicality: catechism classes, pastoral counselling, student hostels, and parish welfare programmes could all be read differently by different officials.Disclosure requirements add to this uncertainty. Organisations must report their websites, social media accounts, and publications, including books and articles by office bearers. Penalties for spending foreign funds outside declared purposes can reach 30% of the amount or Rs 1 lakh, whichever is higher. Individually, these look routine. Together, they create continuous oversight of ordinary communication, charitable work, and religious activity. The government says the Rules are religion-neutral, and on July 10, the home minister assured the Catholic Bishops’ Conference that the amendments do not target Christians and will not apply retrospectively. Such assurances deserve consideration, but confidence must rest on clear legal standards and equal enforcement, not assurances alone.Ensure that regulation does not become a tool of excessive controlThe experience of the past decade explains why many Christian organisations remain cautious. More than 20,000 FCRA registrations have been cancelled or allowed to lapse in this period, and independent reporting has repeatedly indicated that Christian-linked organisations account for a significant share of those affected. Christian institutions have also faced growing challenges through anti-conversion laws, local restrictions, and violence directed at churches and clergy.During the crisis in Manipur, church-run institutions were central to relief efforts even as churches were attacked and thousands of Christians displaced. Against this background, the new Rules are understandably seen as part of a wider pattern of state control over institutions linked to the Christian community.Also read: ‘Last Nail on the Coffin’: Opposition Leaders Write to Modi, Shah Demanding Withdrawal of New FCRA RulesDoes this mean the government intends to weaken Christian institutions? The available evidence does not support that conclusion. The government has consistently said it wants to strengthen national security, improve financial accountability, and reduce foreign influence over domestic affairs. These are legitimate goals. The real issue is whether the measures are proportionate and distinguish between genuine security concerns and long-established institutions engaged in public service.This question goes beyond Christian organisations. Religious freedom under Article 25 is not limited to private worship. Every major religious tradition expresses its values through institutions that educate children, run hospitals, care for the poor, and respond to disasters. When financial regulation significantly affects how these institutions function, it also affects the practical exercise of religious freedom. The issue is not simply one of minority rights, but of the relationship between the state and civil society. Democratic governments have the authority to regulate funding but also the responsibility to ensure that regulation does not become a tool of excessive control.This is why proportionality should guide parliament’s examination of the Bill. Restrictions should correspond to demonstrable risks. Organisations with long records of compliance should not face the same burden as those under credible investigation. Terms such as “proselytisation” need precise legal definitions, not broad administrative interpretations. Independent appellate mechanisms should be strengthened so disputes are decided through transparent legal processes rather than discretionary executive decisions.Debate should be centred on constitutional principlesChristian institutions also need to recognise that the regulatory environment has changed, and that they cannot rely solely on assurances from the government. Greater financial transparency, stronger internal compliance systems, and regular legal audits have become necessary. Dioceses, educational institutions, and charities should pool legal expertise, share compliance resources, and strengthen domestic fundraising to reduce reliance on overseas contributions for essential services.Also read: The RSS Takes Foreign Money Too. Why Doesn’t the Government Question It?They should also avoid treating this purely as a denominational issue. The autonomy of charitable institutions concerns all sections of Indian society, and partnerships with civil society groups and legal scholars can help keep the debate centred on constitutional principles rather than religious identity.Parliament still has an opportunity to restore that balance. It should examine not only whether foreign funding needs tighter regulation, but also whether the present Rules impose burdens wider than necessary. Effective regulation and constitutional liberty need not be opposing goals; a transparent, proportionate framework can protect both.India’s Christian institutions have served the country for generations through education, healthcare, and humanitarian work. Their future should not depend on administrative discretion or shifting political assurances, but on laws that are precise, fair, and consistent with the constitutional promise of religious freedom. That is the standard by which the new FCRA framework should be judged.John J. Kennedy – educator, columnist and political analyst – is based in Bengaluru.