CSR-2 Form Guide

What is Form CSR-2?

Form CSR-2 is an annual electronic return that companies file with the Registrar of Companies (RoC) to report their Corporate Social Responsibility activities for the preceding financial year. It was introduced by the Companies (Accounts) Amendment Rules, 2022, notified on February 11, 2022, and is governed by Rule 12(1B) of the Companies (Accounts) Rules, 2014. The form captures a comprehensive picture of a company's CSR governance, expenditure, project-level spending, and implementing partners, giving the Ministry of Corporate Affairs a structured, machine-readable record of CSR compliance across corporate India.

Before the introduction of CSR-2, CSR reporting was scattered across the Board's report and website disclosures, making it difficult for regulators to aggregate and compare data. CSR-2 consolidates this into a single electronic filing on the MCA21 portal, creating a standardised dataset that the MCA uses for monitoring, analysis, and enforcement.

Who Needs to File CSR-2

Every company that falls within the ambit of Section 135(1) of the Companies Act, 2013 must file Form CSR-2. A company is covered under Section 135(1) if it meets any one of the following thresholds in the immediately preceding financial year:

• Net worth of Rs 500 crore or more, or
• Turnover of Rs 1,000 crore or more, or
• Net profit of Rs 5 crore or more.

Meeting any single threshold triggers the obligation. Foreign companies having branch or project offices in India are also required to comply with CSR provisions and file CSR-2 if they meet the thresholds. Companies that did not undertake any CSR activity during the year are still required to file the form, reporting nil expenditure along with the reasons for not spending.

What Information Goes Into CSR-2

Form CSR-2 is structured to capture the full lifecycle of a company's CSR programme. The key sections include:

• CSR Committee composition — names, designations, and DIN/PAN of committee members, and details of committee meetings held during the year.
• CSR policy details — a summary of the company's CSR policy, the projects approved, and the areas or subjects selected from Schedule VII.
• Average net profit — the average net profit of the company for the immediately preceding three financial years, which is the basis for calculating the prescribed CSR expenditure.
• Prescribed CSR expenditure — 2% of the average net profit, representing the minimum amount the company is required to spend.
• Amount spent and unspent amount — the total CSR amount spent during the year and the unspent amount, if any, along with the reason for underspending.
• Project details — for each CSR project: the sector or Schedule VII item, the state and district of implementation, the approved budget, the amount spent, and the mode of implementation (direct, through an implementing agency, or through a registered trust or Section 8 company).
• Implementing agency details — the name, CSR Registration Number (from Form CSR-1), and PAN of each implementing agency, along with the amount disbursed to each.
• Transfers to unspent CSR account or Schedule VII funds — details of amounts transferred to an unspent CSR bank account for ongoing projects, or to funds specified in Schedule VII (such as the PM National Relief Fund) for projects that have not been undertaken.

The Three CSR Reporting Channels

It is important to understand that CSR-2 is one of three distinct CSR reporting channels, each serving a different purpose and filed in a different place. Confusing them is a common source of error:

1. Annual report on CSR (Annexure II format) — annexed to the Board's report under Section 134(3)(o) of the Companies Act, 2013. This is a narrative report describing the CSR policy, the rationale for project selection, and the outcomes achieved. It is part of the annual report sent to shareholders.
2. Form CSR-2 — the electronic return filed with the Registrar of Companies under Rule 12(1B). This is a structured, data-driven filing on the MCA21 portal that captures project-level financial details.
3. Website disclosure — under Rule 9 of the Companies (CSR Policy) Rules, 2014, companies must disclose the composition of the CSR Committee, the CSR policy, projects approved, and implementation details on their websites.

These three channels overlap in content but differ in format, audience, and filing mechanism. A company must comply with all three independently.

Filing Procedure on the MCA21 Portal

After the MCA21 V3 migration, Form CSR-2 is filed as a separate form on the portal, not merely as an addendum to AOC-4. The filing procedure is as follows:

1. Log in to the MCA21 portal using valid credentials.
2. Ensure that the AOC-4 (annual financial statement) has already been filed, as CSR-2 is filed after and separately from AOC-4.
3. Open Form CSR-2 from the MCA21 forms list and fill in the company's CIN and the relevant financial year.
4. Enter the CSR Committee details, policy summary, average net profit, prescribed expenditure, and amount spent.
5. Add project-level details for each CSR project undertaken during the year, including the implementing agency's name and CSR Registration Number.
6. Enter details of any unspent amounts and transfers to unspent CSR accounts or Schedule VII funds.
7. Have the form certified by a practising professional (CA/CS/CMA) if professional certification is applicable.
8. Submit the form, pay the applicable filing fee, and download the acknowledgement for records.

Due Dates and Extensions

The general due date for Form CSR-2 follows the AOC-4 due date, which is within 30 days of the date of the Annual General Meeting (AGM). However, the MCA has the power to notify a different deadline for a specific financial year, and it has exercised this power on more than one occasion.

For the financial year 2023-24, the MCA issued G.S.R. 317(E) dated May 19, 2025, extending the deadline for filing CSR-2 to June 30, 2025. The original deadline had been March 31, 2025. Companies that had not filed by the original date were given this additional window to comply without facing late-filing consequences.

Why NGOs Should Care About CSR-2

Form CSR-2 is a company filing, not an NGO filing. An NGO does not file CSR-2 itself. However, there are several reasons why NGOs should understand this form thoroughly:

• Your name appears in it. When a company funds an NGO to implement a CSR project, the NGO's legal name and CSR Registration Number (obtained through Form CSR-1) are entered into the company's CSR-2 return. This makes the NGO's identity and the amount received part of the public regulatory record.
• Discrepancies trigger scrutiny. If the amount a company reports as disbursed to an NGO in CSR-2 does not match the amount the NGO acknowledges receiving, the mismatch can attract attention from auditors, the MCA, or the Income Tax Department. NGOs should maintain records that reconcile with what their corporate funders report.
• It is a source of funder intelligence. Because CSR-2 filings are public, an NGO can use them to identify which companies are spending on CSR, which sectors they prioritise, and which implementing agencies they work with. This is valuable intelligence for business development.
• It signals funder reliability. A company that files CSR-2 on time and reports consistently is more likely to be a reliable, compliant partner. Conversely, a company with a history of late filings or unspent CSR amounts may signal internal governance issues.

Common Mistakes and Edge Cases

Guardrails and Important Points

• CSR-2 is mandatory for all Section 135(1) companies, including those that spent nothing during the year. A nil filing with reasons is still required.
• The form must be filed for every financial year in which the company is covered, not just the years in which it undertook CSR activity.
• Project-level reporting is granular: each project must be reported with its sector, geography (state and district), budget, and amount spent. Aggregate or summary-only reporting is not acceptable.
• The implementing agency's CSR Registration Number must be valid and active at the time of disbursement. An NGO whose CSR-1 registration has lapsed cannot legally receive CSR funds.
• Amounts transferred to unspent CSR accounts must be spent within three years (for ongoing projects) or transferred to a Schedule VII fund, and the subsequent utilisation must be reported in the relevant year's CSR-2.
• Professional certification of CSR-2 may be required depending on the company's classification; verify the current requirement on the MCA21 portal before filing.

Penalties for Non-Filing

Rule 12(1B) of the Companies (Accounts) Rules, 2014, which mandates the filing of CSR-2, does not itself prescribe a penalty. This means that non-filing or late filing is prosecuted under the general penalty provision of Section 450 of the Companies Act, 2013. Under Section 450, the company and every officer in default is liable to a fine that may extend to Rs 10,000 for every day of continued default. If the default continues beyond one year, the company and its officers may face additional consequences, including potential prosecution.

Given that CSR-2 is an annual filing, the per-day penalty can accumulate quickly. Companies should treat the filing deadline with the same seriousness as other annual RoC filings such as AOC-4 and MGT-7.

Conclusion

Form CSR-2 has become the central regulatory instrument for tracking CSR expenditure in India. For companies, it is a compliance obligation that demands accurate, project-level reporting. For NGOs, it is both a risk surface — because their name and registration number appear in it — and an opportunity, because the public filings are a rich source of funder intelligence. Understanding how CSR-2 works, what it contains, and when it is due helps both companies and their implementing partners stay compliant and avoid the penalties that flow from non-filing under Section 450.