CSR-1 and CSR-2 Filing: A Complete Guide for Indian Corporate CSR Teams (2026)
- Marpu Foundation
- Jul 6
- 12 min read
This article reflects CSR-1 and CSR-2 filing practice under Indian law as of April 2026. The forms, portal interfaces, and specific requirements are updated periodically by the Ministry of Corporate Affairs. This article is updated annually. Last updated: April 2026.
Two forms sit at the centre of Indian CSR filing. Form CSR-1 is the registration form filed by any implementing agency that wants to undertake CSR activities on behalf of a company. Form CSR-2 is the annual report on CSR activities filed by the company itself. Together, they define the filing infrastructure that supports the Companies Act 2013 CSR framework.
Yet both forms are widely misunderstood. Companies sometimes assume CSR-1 is their responsibility, when it belongs to the implementing agency. Implementing agencies sometimes file CSR-1 without keeping the registration current across years. Companies file CSR-2 as a compliance box-tick rather than the substantive annual disclosure it is designed to be. The result is a filing landscape where the paperwork gets submitted but not always with the discipline the forms were built to produce.
This article walks through what each form is, who files it, when, how, what it requires, and how the two forms connect to the broader CSR framework. It covers the filing process practically, the common errors, and the suggestions that make filing a discipline rather than a scramble.
It is written for the Company Secretary, the CSR head, the CSR Committee, the Chief Financial Officer, the implementing agency filing CSR-1, and the compliance function responsible for CSR-2. The article is a practitioner-voice operational reference. It is not a substitute for the company's own Company Secretary, Chartered Accountant, statutory auditor, and Legal counsel review of specific filings.
Important note: This article provides operational guidance on CSR-1 and CSR-2 filing under Indian law as of April 2026. It is informational guidance and does not constitute legal, financial, or compliance advice. The CSR filing framework, including Section 135 of the Companies Act 2013 and the Companies (CSR Policy) Rules 2014, and the specific form fields and portal interfaces on the MCA portal, are subject to amendment by the Ministry of Corporate Affairs. Every filing should be reviewed by the company's or implementing agency's Company Secretary, Chartered Accountant, statutory auditor, and Legal counsel. Verify against the current form and the current text of Section 135, the CSR Rules, and any recent MCA circulars before filing.
The Two Forms at a Glance
Before the detail, the essential difference between the two forms is worth making explicit.
Form CSR-1 is filed by the implementing agency, not by the company. It registers the agency (typically an NGO, Section 8 company, registered trust, or society) with the Ministry of Corporate Affairs, which then issues a CSR Registration Number the agency uses when receiving CSR contributions
Form CSR-2 is filed by the company, not by the implementing agency. It reports the company's CSR activities for the financial year, drawing on the Annual Action Plan, the Board's Report disclosures, and the actual spend across projects
The two forms serve different purposes. CSR-1 is an eligibility-and-identification form for the implementing agency. CSR-2 is a substantive annual reporting form for the company. Confusing the two, or assuming one substitutes for the other, produces filing errors that surface at audit.
Form CSR-1: The Implementing Agency Registration
Form CSR-1 was introduced through the January 2021 amendment to the Companies (CSR Policy) Rules 2014, specifically under Rule 4. The purpose is to bring implementing agencies into a common register maintained by the Ministry of Corporate Affairs, so companies can verify which agencies are eligible to receive CSR contributions.
Who Files CSR-1
CSR-1 is filed by the implementing agency, which under the Rules can be:
A company established under Section 8 of the Companies Act 2013, or a registered public trust, or a registered society, established by the company itself, either singly or with any other company
A company established under Section 8 of the Companies Act 2013, or a registered trust, or a registered society, established by the central government or state government
Any entity established under an Act of Parliament or a state legislature
A company established under Section 8 of the Companies Act 2013, or a registered public trust, or a registered society, registered under Sections 12A and 80G of the Income Tax Act 1961, having an established track record of at least three years in undertaking similar activities
The implementing agency should confirm its eligibility against the current text of Rule 4 with its Company Secretary or Legal counsel before filing.
What CSR-1 Requires
The form requires the implementing agency to provide, among other elements:
Basic identity information including PAN, address, and email
The nature of the entity (Section 8 company, trust, society, or other)
Registration details under the relevant Act
Registration under Sections 12A and 80G where applicable
Details of the entity's Directors, Board of Trustees, or Governing Body
A declaration by the entity confirming the accuracy of information provided
A certification by a practising Chartered Accountant, Company Secretary, or Cost Accountant
The specific fields on the current form should be reviewed against the live version on the MCA portal at the time of filing.
How CSR-1 Is Filed
Form CSR-1 is filed electronically through the MCA portal. The typical filing sequence is as follows:
The implementing agency prepares the required information and supporting documentation
The Directors, Trustees, or Governing Body members with valid Digital Signature Certificates are identified for signing
A practising Chartered Accountant, Company Secretary, or Cost Accountant is engaged for the certification
The form is completed on the MCA portal
The form is digitally signed and submitted
The MCA generates a CSR Registration Number, which is the identifier the agency uses in all subsequent CSR contexts
The current portal interface, filing fee (if any), and specific submission steps should be confirmed at the time of filing.
What Happens After CSR-1 Is Filed
Once the CSR Registration Number is issued, the implementing agency should:
Retain the CSR-1 acknowledgement and Registration Number in its records
Provide the Registration Number to companies engaging it as an implementing agency, so those companies can verify eligibility
Update the registration if any of the underlying information changes materially
Keep the associated documentation (12A, 80G, registration certificate, governance records) current to support any subsequent verification
The CSR Registration Number becomes a core credential that the implementing agency uses in every corporate CSR partnership.
Form CSR-2: The Company's Annual Report on CSR
Form CSR-2 was introduced through amendments to the CSR framework, and is now the annual report on CSR activities that companies subject to Section 135 are required to file. The form is under Rule 12(1B) of the Companies (Accounts) Rules 2014.
Who Files CSR-2
CSR-2 is filed by the company that is subject to the CSR obligation under Section 135 of the Companies Act 2013. The company is responsible for the filing, not the implementing agency, even where the CSR activities are executed through implementing agencies.
The specific applicability, particularly for companies just crossing the CSR thresholds and for particular corporate structures, should be confirmed with the company's Company Secretary and Chartered Accountant.
What CSR-2 Requires
The form is a substantive annual report on the company's CSR for the financial year. It typically requires:
The company's identifying information
The CSR obligation calculation, based on the average net profits and the prescribed percentage under Section 135
Details of the CSR Committee, including composition and meetings held
The CSR Policy and the Annual Action Plan reference
Details of CSR projects undertaken, including project-level data on activities, geographies, amounts, and implementing agencies
Details of ongoing projects and their multi-year status
Amounts spent, amounts unspent, and treatment of unspent amounts
Details of any transfer to the Unspent CSR Account or to a Schedule VII fund as required
Impact assessment references, where impact assessment applies under Rule 8(3)
Additional disclosures as the current form requires
The current form fields should be reviewed against the live version on the MCA portal at the time of filing.
When CSR-2 Is Filed
The filing timeline is set by the Rules and can be updated through MCA circulars. Companies should confirm the current deadline for their filing period against the current Rules and any recent MCA notifications with their Company Secretary and Chartered Accountant, and plan the preparation in advance of the deadline.
How CSR-2 Is Filed
CSR-2 is filed electronically through the MCA portal, generally in connection with or aligned to the company's annual filing cycle. The typical preparation sequence is:
The CSR data for the financial year is assembled, drawing on the Annual Action Plan, project records, financial records, and implementing agency reports
The data is reconciled against the statutory audit and Board's Report
The Company Secretary prepares the form based on the reconciled data
The form is reviewed by the CSR Committee, the CFO, and the statutory auditor as applicable
The form is signed digitally by the authorised signatories
The form is submitted through the MCA portal
Preparation is significantly easier when the underlying documentation, particularly the Annual Action Plan, project-level records, and Utilization Certificates from implementing agencies, has been maintained through the year rather than assembled at filing time.
How the Two Forms Connect to the Broader CSR Framework
CSR-1 and CSR-2 do not exist in isolation. They connect to the broader CSR compliance architecture.
The Annual Action Plan under Rule 5(2) feeds the CSR-2 disclosure, particularly the list of projects and their execution details
The CSR Policy provides the framework the Annual Action Plan and CSR-2 both draw on
Schedule VII alignment for each project should be documented and reflected in CSR-2
CSR-1 registration by implementing agencies enables the company to name eligible agencies in CSR-2
The Board's Report under Section 134 contains CSR disclosures that should reconcile with CSR-2
The statutory audit verifies actual spend, which reconciles with CSR-2
Utilization Certificates from implementing agencies support the project-level details in CSR-2
CSR Impact Assessment under Rule 8(3), where applicable, produces reports that CSR-2 references
BRSR Principle 8 for listed companies draws on CSR data that CSR-2 also captures
Filing CSR-1 and CSR-2 well is easier when the broader architecture is running well. Each supporting document reduces the effort at filing time.
Five Common Errors in CSR-1 Filing (For Implementing Agencies)
Across observed practice, five recurring errors weaken CSR-1 filings by implementing agencies.
1. Filing Without Confirming Eligibility Under Rule 4
The most common error is filing before confirming eligibility under the specific sub-clause of Rule 4 that applies. Some entities file believing they qualify when the criteria do not match. Confirming eligibility with a Company Secretary or Legal counsel before filing prevents this.
2. Weak or Inconsistent Governance Documentation
The form requires details of the Board or Governing Body, and weak or inconsistent governance documentation surfaces during MCA verification. Strong governance records supporting the form entries make filing smoother.
3. Lapsed 12A or 80G Registration at Filing
Where the eligibility route involves 12A and 80G, lapsed registrations create difficulty. Confirming that these registrations are current at filing avoids the issue.
4. Failing to Maintain the Registration Across Years
Some agencies file CSR-1 and then let the underlying documentation drift. Keeping the registration current, and updating it when material facts change, maintains the credibility that corporate partners rely on for verification.
5. Not Retaining the Acknowledgement Accessibly
The CSR-1 acknowledgement and Registration Number are core credentials that corporate partners will request. Losing the acknowledgement or making it hard to retrieve creates friction in every subsequent corporate partnership.
Five Common Errors in CSR-2 Filing (For Companies)
Across observed practice, five recurring errors weaken CSR-2 filings by companies.
1. Assembling Data Retrospectively Rather Than Continuously
The most common error is treating CSR-2 as a filing-time assembly rather than a filing-time submission of data captured continuously. Retrospective assembly produces data gaps, reconciliation problems, and inaccuracies. Continuous capture through the year is stronger.
2. Weak Reconciliation With the Statutory Audit
CSR-2 data should reconcile with the statutory audit's CSR figures. When it does not, the discrepancy is a problem to resolve, not to bury. Building the reconciliation into the filing preparation avoids the discrepancy.
3. Missing or Inconsistent Schedule VII Alignment
Projects should be aligned to specific Schedule VII clauses, and CSR-2 reflects this. Missing or inconsistent alignment across projects creates a weaker disclosure than clean alignment.
4. Not Reflecting Ongoing Projects Correctly
Where the company has ongoing projects with amounts carried to the Unspent CSR Account, CSR-2 should reflect this correctly. Errors in the ongoing-project treatment create compliance risk and audit friction.
5. Weak Documentation Behind the Filing
CSR-2 is a summary of the underlying documentation. Where the documentation is weak, the filing is exposed to any subsequent verification. Strong underlying documentation, including Annual Action Plan, project records, Utilization Certificates, and financial records, supports the filing.
Five Suggestions for Stronger CSR Filing Discipline
The following suggestions reflect practice that produces stronger CSR-1 and CSR-2 filings. They are observations, not prescriptions.
1. Build Filing Discipline Into the Annual Rhythm
Companies that treat CSR-2 as one point in a year-round rhythm, where documentation is captured continuously and reconciliation happens quarterly, file more easily than those who assemble at year-end. Implementing agencies that treat CSR-1 registration as ongoing rather than one-time similarly maintain stronger standing.
2. Reconcile CSR Data Quarterly
Quarterly reconciliation between project records, financial records, and Annual Action Plan reduces the year-end scramble and surfaces discrepancies while they can still be resolved. This applies to companies preparing CSR-2 across the year.
3. Verify Implementing Agency CSR Registration Every Year
Companies should verify each implementing agency's CSR Registration Number and supporting registrations at the start of each financial year, not assume that a registration confirmed once remains current forever. Registrations lapse, and verifying prevents downstream complications.
4. Involve the Company Secretary and Chartered Accountant Early
CSR-2 preparation is significantly easier when the Company Secretary and Chartered Accountant are engaged before filing time. Early involvement means the filing is a reconciliation of already-verified data rather than a last-minute assembly.
5. Refresh Filing Discipline Annually as the Rules Evolve
The MCA updates the CSR framework, the forms, and the portal periodically. An annual refresh of the filing approach keeps the discipline current with the evolving requirements.
A Note on Verification for Corporate Partners
For corporate CSR teams engaging implementing agencies, verifying CSR-1 registration is a fundamental step. The verification should include:
Requesting the implementing agency's CSR Registration Number
Requesting the CSR-1 acknowledgement
Confirming the associated registrations, particularly 12A and 80G where applicable
Confirming the eligibility route the agency claimed under Rule 4
Reviewing the agency's governance structure and track record
This verification is one input to the broader partner evaluation, and it belongs early in the engagement process.
A Note on the Limits of This Article
This article provides operational guidance on CSR-1 and CSR-2 filing based on the requirements of the Companies (CSR Policy) Rules 2014 and the Companies (Accounts) Rules 2014 as understood as of April 2026. It is informational guidance and does not constitute legal, financial, or compliance advice.
The specific form fields, portal interfaces, filing timelines, and related requirements are subject to amendment by the Ministry of Corporate Affairs and should be confirmed against the current live forms and current text of the Rules. Every filing should be reviewed by the company's or implementing agency's Company Secretary, Chartered Accountant, statutory auditor, and Legal counsel.
Verify against the current text of Section 135 of the Companies Act 2013, the Companies (CSR Policy) Rules 2014, the Companies (Accounts) Rules 2014, Schedule VII, and any recent MCA circulars before filing. The guidance in this article is a starting reference, not a definitive filing manual, and should be adapted to the specific facts of each filing with professional review.
What This Article Is Actually Saying
Three things are worth holding onto.
1. CSR-1 and CSR-2 do different jobs and are filed by different entities. CSR-1 registers the implementing agency; CSR-2 reports the company's annual CSR. Confusing the two produces filing errors.
2. Both forms are stronger when supported by continuous discipline through the year. Retrospective assembly at filing time produces weaker filings than continuous capture supported by quarterly reconciliation and early professional involvement.
3. The forms connect to the broader CSR architecture. The Annual Action Plan, the CSR Policy, Schedule VII, the Board's Report, the statutory audit, Utilization Certificates, Impact Assessment, and BRSR all feed into or draw from CSR-1 and CSR-2. Filing well is easier when the whole architecture is running well.
The companies and implementing agencies that file CSR-1 and CSR-2 well treat filing as a discipline rather than a scramble, maintain the underlying documentation continuously, verify registrations and reconciliations quarterly, and involve professional advisers early. The compounding effect across years is considerable, both for filing quality and for the broader CSR compliance posture.
Working With Marpu Foundation as Your Implementation Partner
At Marpu Foundation, we operate as an implementation partner across our network of 250+ corporate partnerships and 23+ Indian states. Our CSR-1 registration is current and verifiable, and our filing discipline supports corporate partners' CSR-2 preparation across the year rather than at filing time.
The practices we maintain include:
Current CSR-1 registration with a valid Registration Number, refreshed and verifiable at the start of each engagement
Current 12A registration and 80G registration under the Income Tax Act 1961
Continuous project-level documentation across the year, including activity records, beneficiary data, Schedule VII alignment, and financial tracking
Utilization Certificates produced in the format that supports corporate partners' Board's Report drafting and CSR-2 filing
Quarterly reconciliation between project records, financial records, and Annual Action Plan references, so year-end CSR-2 preparation is a reconciliation of verified data rather than a scramble
Documentation discipline that supports the company's statutory audit and, for listed partners, BRSR Principle 8 disclosure
For corporate CSR teams preparing CSR-2 for FY 2026-27 and considering implementing agencies for their programmes, Marpu Foundation would be glad to provide our CSR Registration Number, our CSR-1 acknowledgement, our 12A and 80G certificates, our recent audited financial statements, and our documentation samples for evaluation.
To begin that conversation, write to connect@marpu.org or visit marpu.org. Send a brief note on your focus areas, your geographies, your sectors, and your evaluation timeline, and we respond within two working days with the verification documentation, project design input, Schedule VII alignment mapping, and a programme proposal aligned to your priorities.
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