Section 8 Company & CSR

How non-profit companies registered under Section 8 of the Companies Act, 2013 qualify for CSR funding, the registration process, annual compliance, and how they compare to trusts and societies.

Key Points

What is a Section 8 Company?

Section 8 of the Companies Act, 2013 governs companies that are formed for the purpose of promoting commerce, art, science, sports, education, research, social welfare, religion, charity, protection of the environment, or any other such object. These companies are the corporate-law equivalent of a non-profit: they operate with the governance and statutory recognition of a company, but their profits cannot be distributed to members.

A Section 8 company is registered with the Registrar of Companies (RoC) under the Companies Act, 2013, and must obtain a license from the Central Government. The license is issued upon a declaration in Form INC-12, which confirms that the company meets the conditions of Section 8. Because the company is formed for non-profit objects, the word "Limited" (or "Private Limited") is omitted from its registered name.

Key Characteristics

How to Register a Section 8 Company

Registration of a Section 8 company follows the standard company incorporation process under the Companies Act, 2013, with the additional requirement of obtaining a Section 8 license. The key forms in the process are:

  1. Form INC-12 — Application for a license under Section 8. This is the declaration submitted to the Central Government requesting permission to register the company as a non-profit.
  2. Form INC-13 — Memorandum of Association, which states the objects for which the company is incorporated and confirms that profits will be applied only to those objects.
  3. Form INC-14 — Declaration by a professional (Chartered Accountant, Company Secretary, or Cost and Management Accountant) confirming compliance with the requirements of Section 8.
  4. Form INC-15 — Declaration by each person named in the articles as a director, manager, or secretary, confirming compliance with Section 8 conditions.

Once the license is granted and the company is incorporated, the Section 8 company can begin operations. However, receiving CSR funds and tax benefits requires additional registrations described below.

Section 8 Company vs Trust vs Society

Indian non-profits can be structured as a Section 8 company, a trust, or a society. Each form is governed by a different statute and has different compliance obligations. The table below summarises the key differences.

Feature Section 8 Company Trust Society
Governing law Companies Act, 2013 Trust Act (state-level) Societies Registration Act, 1860
Regulator Registrar of Companies (RoC) Sub-Registrar / Charity Commissioner Registrar of Societies (state)
Minimum members 2 (private) / 7 (public) 2 trustees 7 members
Audit requirement Mandatory every year, regardless of income Income-threshold based (varies by state) Income-threshold based (varies by state)
Annual filings AOC-4, MGT-7 with RoC Varies by state; often minimal Annual return with Registrar of Societies
Board meetings Minimum 4 per year As per trust deed As per society bylaws
Corporate recognition High — statutory company structure Moderate Moderate

CSR Eligibility for Section 8 Companies

Section 8 companies are eligible to receive CSR funds from companies covered under Section 135 of the Companies Act, 2013. However, eligibility is not automatic upon incorporation. A Section 8 company must register separately with the Registrar of Companies using Form CSR-1 to be empanelled as a CSR implementation partner.

The CSR-1 registration is a distinct filing from the Section 8 license. It is filed after the company is already incorporated and has obtained its Corporate Identification Number (CIN). Once CSR-1 is approved, the Section 8 company is issued a CSR Registration Number, which companies can cite when directing CSR funds to it. For a detailed walkthrough of the CSR-1 process, see our CSR-1 Registration Guide.

Edge case: A Section 8 company that has not filed Form CSR-1 cannot receive CSR funds, even if it is fully incorporated and holds 12A/80G registration. CSR-1 is a mandatory, standalone requirement. Similarly, holding a CSR-1 registration does not by itself confer tax exemption — 12A and 80G are separate registrations with the Income Tax Department.

Tax Benefits: 12A and 80G

Section 8 incorporation provides company-level recognition under the Companies Act, but it does not automatically grant income-tax exemption. To access tax benefits, a Section 8 company must register separately with the Income Tax Department:

Both registrations are filed with the Income Tax Department and are independent of the Section 8 license and the CSR-1 registration. For the full process, see our 80G & 12A Registration Guide.

Edge case: A Section 8 company can operate and receive CSR funds without 12A/80G, but donors will not be able to claim tax deductions. Many corporate donors require 80G registration as a precondition for funding. If your CSR strategy depends on corporate donors, prioritise 80G registration early.

Annual Compliance for Section 8 Companies

Because a Section 8 company is a company under the Companies Act, 2013, it is subject to the annual compliance obligations that apply to companies generally. The key filings and obligations are:

Exemptions Available to Section 8 Companies

The Central Government has the power under Section 462 of the Companies Act, 2013 to modify or exempt provisions of the Act as they apply to Section 8 companies. A notification dated June 5, 2015 exempted Section 8 companies from several Companies Act provisions that would otherwise apply, recognising their non-profit character. These exemptions cover matters such as the use of certain words in the name, the requirement to hold an AGM in a particular manner, and provisions relating to the issue of prospectus, among others.

Section 8 companies should review the notified exemptions carefully, as they reduce the compliance burden in specific areas while leaving core obligations (audit, AOC-4, MGT-7, board meetings) intact.

Common Mistakes and Edge Cases

Mistake: Assuming that Section 8 incorporation automatically makes the company eligible for CSR funds. It does not. CSR-1 registration is a separate, mandatory filing. Incorporate first, then file CSR-1.
Mistake: Skipping 12A/80G registration because the company is "already a non-profit." Tax exemption is not automatic; it requires a separate application to the Income Tax Department.
Edge case: A Section 8 company can be converted to a regular company if its objects change and it no longer meets the conditions of Section 8. The conversion must comply with the conditions attached to the original license and the procedures laid down in the Companies Act, 2013. Any assets remaining after winding up are typically transferred to another entity with similar objects, not distributed to members.
Edge case: A Section 8 company can be wound up under the Companies Act, 2013. On winding up, surplus assets are not returned to members but are transferred to another Section 8 company or similar non-profit entity, as specified in the company's memorandum.

Guardrails and Important Points

When to Choose Section 8 Over a Trust or Society

A Section 8 company is often the preferred structure when an organisation needs strong corporate governance, plans to work extensively with corporate CSR partners, or intends to scale operations nationally. The statutory recognition of a company, combined with the mandatory audit and ROC filings, gives corporate donors and government agencies a higher degree of confidence in the organisation's governance.

A trust may be simpler and faster to set up, and is commonly used for family-run or single-donor charitable initiatives. A society is typically chosen for membership-based organisations such as clubs, associations, or community groups. Section 8 companies are distinct from both trusts (governed by the Trust Act) and societies (governed by the Societies Registration Act, 1860), and the choice depends on the organisation's objects, funding model, and governance preferences.

If your primary funding strategy is CSR under Section 135, a Section 8 company with CSR-1 registration and 80G approval is often the most credible structure to present to corporate CSR committees.

Frequently Asked Questions

Can a Section 8 company receive CSR funds?

Yes. A Section 8 company is eligible to receive CSR funds from companies covered under Section 135 of the Companies Act, 2013, provided it registers separately with the Registrar of Companies using Form CSR-1. The CSR-1 registration is distinct from the Section 8 incorporation license and must be filed after the company is already registered.

What is the difference between a Section 8 company and a trust?

A Section 8 company is registered under the Companies Act, 2013 with the Registrar of Companies, while a trust is registered under the Trust Act with the relevant state authority. Section 8 companies have stricter annual compliance (mandatory audit, four board meetings, ROC filings) but are often preferred by corporate CSR committees for their statutory recognition and governance structure.

Is audit mandatory for a Section 8 company?

Yes. Unlike trusts and societies where audit is often income-threshold based, a Section 8 company must be audited every year regardless of its income level. This is a requirement under the Companies Act, 2013.

What forms are required to register a Section 8 company?

Registration involves filing a declaration in Form INC-12 to obtain a license from the Central Government, a declaration by each subscriber in Form INC-13, a declaration in Form INC-14 by a professional (CA/CS/CMA), and Form INC-15 (declaration of compliance). The license is issued under Section 8 of the Companies Act, 2013.

Does a Section 8 company need 12A and 80G registration?

Yes. While Section 8 incorporation provides company-level recognition, tax benefits require separate registration with the Income Tax Department. Form 12A grants income-tax exemption to the organization, and 80G registration allows donors to claim tax deductions on their contributions.

What is the minimum capital requirement for a Section 8 company?

There is no minimum capital requirement for a Section 8 company under the Companies Act, 2013. The company can be incorporated with any amount of authorised and paid-up capital.

How many directors are required for a Section 8 company?

A minimum of 2 directors is required if the Section 8 company is incorporated as a private limited company. If incorporated as a public limited company (without the word Private in its name), a minimum of 3 directors is required.

Can a Section 8 company be converted to a regular company?

Yes. A Section 8 company can be converted to a regular company if its objects change and it no longer meets the conditions of Section 8. The conversion process and any conditions attached to the original license must be complied with under the Companies Act, 2013.

Disclaimer: This guide is for informational purposes only and does not constitute legal, tax, or professional advice. The provisions of the Companies Act, 2013, the Income Tax Act, 1961, and related notifications are subject to change. Always verify current rules and consult a qualified professional (Chartered Accountant, Company Secretary, or lawyer) before making registration or compliance decisions.

Check Your CSR Readiness

Run our free CSR Readiness Check to see how your Section 8 company scores across registration, compliance, and documentation.

Run CSR Readiness Check Talk to Founders
Sources:
Ministry of Corporate Affairs, Government of India — mca.gov.in (Companies Act, 2013; Section 8; Section 135; Section 462 notification dated June 5, 2015; Form INC-12)
Institute of Companies Secretaries of India — FAQs on Section 8 Companies
Income Tax Department, Government of India — 12A and 80G registration provisions under the Income Tax Act, 1961
Societies Registration Act, 1860