CSR Q1 Review and Adjustment Guide for Indian Companies

The first quarter of the Indian financial year ends on June 30 every year, and for most CSR teams in India, this is the natural moment to pause and assess how the CSR programme has performed in the first three months.

A clean Q1 review accomplishes two things. It tells the team where the programme stands against the plan made at the start of the year. And it gives the team early enough information to make sensible adjustments for the remaining three quarters of the financial year, in consultation with the CSR committee and other relevant stakeholders.

This article is a simple, practical guide to running a CSR Q1 review for Indian companies under Section 135 of the Companies Act 2013. It covers what to review, how to think about the findings, and how to plan adjustments responsibly. The guide is framed as a practical framework rather than a rigid formula, because every company's CSR programme is different and the right adjustments depend on context that only the team itself can fully assess.

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What Q1 Means in This Article

Q1 in this article means the first quarter of the Indian financial year. April 1 to June 30. This matches the financial year that CSR programmes under Section 135 of the Companies Act 2013 operate within. The CSR-2 disclosure that companies file with the Ministry of Corporate Affairs uses this same financial year, so Q1 here is aligned with how CSR reporting cycles work in India.

If your company uses a different fiscal calendar internally, adjust the timing of your review accordingly. But for most Indian companies, the natural CSR review cycle aligns with April to March, and Q1 ends on June 30.

Why a Q1 Review Matters

Three reasons make the Q1 review one of the most useful planning moments in the CSR year.

Q1 is when the year's CSR plan first meets reality

Most CSR plans are developed in February and March, based on assumptions about the year ahead. By the end of Q1, those assumptions have been tested against actual implementation. The Q1 review is where the team learns what is working and what needs attention, with enough time left in the year to act on the learning.

Adjustments made in Q2 are easier than adjustments made in Q3 or Q4

CSR teams that wait until October or November to assess programme health have less time and fewer options for course correction. Teams that review in July, when nine months still remain in the year, have meaningful time to adapt.

Q1 review prepares the team for the next planning cycle

The learnings from Q1 feed into Q2 execution, mid-year review, and ultimately into next year's CSR plan. A team that develops a clean Q1 review habit builds organisational memory and planning discipline that compounds across years.

What to Review in Q1

A clean Q1 review covers six areas. The areas are simple to describe, and the questions in each are straightforward. The depth of review can be adjusted based on the size of your CSR programme and the team's bandwidth.

1. CSR Spend Status

How much of the year's CSR budget has been deployed by June 30, and how much remains for Q2, Q3, and Q4.

Questions to ask:

→ How much of the planned annual CSR budget was deployed in Q1?→ Is the spend trajectory consistent with the annual plan, or are we ahead or behind?→ Are there programmes where spend is lagging the planned schedule?→ Are there programmes where spend is moving faster than planned?

The Q1 spend status report is the foundation of the rest of the review. Most other questions are easier to answer once you know where the financial position stands.

2. Project Activity Status

What has actually happened on the ground in Q1, across each of the programmes the company is funding.

Questions to ask:

→ Have planned activities been initiated according to schedule?→ Are activities producing the expected level of engagement and reach?→ Are implementation partners delivering as agreed?→ Are there activities that have not started, and if so, why?→ Are there activities that have started but are running into operational challenges?

This review focuses on implementation health. It is less about outcomes, which take time to materialise, and more about whether the programme is operationally on track.

3. Documentation Status

The documentation that supports CSR-2 disclosure and BRSR Core reporting needs to be captured systematically through the year, not assembled in a rush at year-end.

Questions to ask:

→ Are utilisation certificates being received from implementation partners on schedule?→ Are beneficiary records and impact data being captured systematically?→ Are photographs and documentation being collected with appropriate consent and dignity?→ Is the documentation organised in formats ready for audit and disclosure?→ Are there gaps in documentation that need to be addressed before they accumulate?

Documentation gaps caught in Q1 are easy to fix. Documentation gaps discovered in Q4 are stressful and sometimes costly.

4. Implementation Partner Health

The relationships with implementation partners are central to CSR programme success. Q1 is a good moment to assess these relationships honestly.

Questions to ask:

→ Are implementation partners delivering on agreed scope, timeline, and quality?→ Is communication with partners working well?→ Are reports from partners arriving on time and meeting the level of detail expected?→ Are there partners where the relationship is strong and could be deepened?→ Are there partners where issues need to be raised and addressed?

If a partnership is struggling, Q1 is the right time to have the conversation, not Q4 when the year is almost over.

5. Employee Volunteering Engagement

If the CSR programme includes employee volunteering, Q1 is a good moment to review participation, engagement, and feedback.

Questions to ask:

→ How many employees have participated in volunteering activities in Q1?→ Are participation levels meeting the annual target?→ Which activities have produced strong engagement?→ Which activities have struggled to draw participation, and why?→ Is there employee feedback that should shape the rest of the year's planning?

Employee volunteering is easier to course-correct in Q2 than in later quarters. The Q1 review surfaces issues while there is still time to address them.

6. Compliance and Regulatory Status

CSR under Section 135 has compliance requirements that need to be tracked through the year, not just at year-end.

Questions to ask:

→ Are activities aligned with Schedule VII as planned?→ Are implementation partners holding valid 12A, 80G, and Form CSR-1 registrations throughout Q1?→ Is the CSR committee meeting on schedule and making necessary approvals?→ Are there compliance gaps that need to be discussed with the company's CSR committee or auditor?

This is the area where the review framing matters most. The right approach to any compliance concern is to surface it to the CSR committee, the company's auditor, or appropriate internal stakeholders, not to make adjustments unilaterally.

How to Conduct the Review

The Q1 review can be a structured exercise or a lighter checkpoint, depending on the size of the CSR programme. For most companies, a balanced approach works well.

Step 1: Gather data

Pull together the financial data, activity reports, documentation records, and partner reports from Q1. This is the foundation of the review.

Step 2: Discuss with the implementation partner

Sit with each major implementation partner and walk through the Q1 status together. The partner will have visibility that the company team does not, and the conversation surfaces issues and opportunities together.

Step 3: Discuss internally

Walk through the Q1 status with the company's internal CSR team and relevant stakeholders. Identify what is going well, what needs attention, and what decisions need to be made.

Step 4: Engage the CSR committee

Present the Q1 findings to the CSR committee. The committee is the appropriate body for any significant decisions about programme adjustments, reallocation, or changes to the annual CSR plan.

Step 5: Engage the auditor or compliance team where needed

For any compliance question or significant programme adjustment, engage the company's auditor or compliance team early. They can confirm that proposed adjustments stay within Section 135 and Schedule VII requirements.

Step 6: Document the review

A simple written record of the Q1 review, the findings, and the decisions taken creates a useful planning resource for Q2 and beyond. It also supports audit readiness and year-end reporting.

How to Think About Q1 Adjustments

Adjustments to the CSR programme based on the Q1 review should be approached carefully. A few principles help.

Discuss before deciding

Any significant adjustment to the CSR programme, including reallocation between projects, changes in implementation partners, or shifts in Schedule VII focus, should be discussed with the CSR committee and the company's auditor before being implemented. This protects compliance integrity and ensures decisions are taken with appropriate oversight.

Distinguish operational fixes from strategic changes

Operational fixes, such as adjusting an activity schedule, improving documentation discipline, or addressing a partner communication issue, can usually be handled within the existing programme structure. Strategic changes, such as moving budget between projects, ending a partnership, or starting a new programme, require more formal review and approval.

Stay within Schedule VII

Any reallocation of CSR spend must remain within Schedule VII categories. The company's auditor can confirm that proposed adjustments meet this requirement. Adjustments that drift outside Schedule VII are not permitted under Section 135.

Document the adjustment rationale

Whatever adjustments are made, document the rationale clearly. This supports audit readiness, year-end reporting, and the planning of next year's CSR programme.

Be conservative in the first year of the practice

If this is your CSR team's first structured Q1 review, keep adjustments modest and focused. A clean review process is itself a meaningful accomplishment in the first year. Aggressive adjustments can be considered once the review habit is established and the team has more confidence in the data and the decisions.

Common Q1 Findings and How to Handle Them

A few patterns appear consistently in CSR Q1 reviews across companies.

Spend is slower than planned

This is common in Q1 because programmes often take time to initiate. The right response is usually patience plus close monitoring. If spend is significantly lagging, work with implementation partners to identify the cause and plan the catch-up trajectory. Avoid the temptation to rush spend deployment, which can compromise programme quality.

One programme is doing better than expected and another is underperforming

This is normal. The right response is to understand why, before deciding on any reallocation. Sometimes the underperforming programme is in an early stage that will produce strong results later. Sometimes it has structural issues that warrant a different approach. Discuss with the implementation partner, the CSR committee, and the auditor before making significant changes.

Documentation is behind schedule

Catch this early. Documentation gaps compound through the year. Q1 is the right moment to establish the documentation discipline that will support clean year-end reporting.

Employee participation is lower than hoped

If volunteering participation is below target in Q1, dig into why before planning Q2. Sometimes it is a communication gap, sometimes a calendar conflict, sometimes a programme design issue. Each cause has a different fix.

A partnership is struggling

Difficult conversations with partners are easier in Q1 than in Q4. If a partnership is struggling, raise it directly and honestly, work with the partner on the path forward, and engage the CSR committee if significant change is being considered.

What a Clean Q1 Review Looks Like

Five characteristics consistently appear in CSR Q1 reviews that produce real value.

It happens on schedule. A review that gets delayed to August or September loses much of its value. The Q1 review is most useful in July, when there is still meaningful time to act on findings.

It is based on real data. Spend reports, partner reports, beneficiary data, and documentation status all need to be assembled before the review. A review based on impressions rather than data does not produce reliable decisions.

It involves the implementation partner. A review done by the company team alone misses the on-ground perspective that only the implementation partner has.

It engages the CSR committee. Significant findings and decisions should flow through the committee. This protects compliance integrity and ensures appropriate oversight.

It produces written outputs. A documented review supports Q2 execution, year-end reporting, and next year's planning.

Compliance and Reporting Notes

A few points on compliance and reporting are worth keeping in mind throughout the Q1 review.

Schedule VII alignment. Activities must remain within Schedule VII categories. Any proposed adjustment must be checked against this requirement.

Implementation partner eligibility. Partners must hold valid 12A, 80G, and Form CSR-1 registrations throughout the year. Confirm this at Q1.

CSR-2 readiness. The CSR-2 disclosure filed at year-end requires documentation that has been accumulated through the year. The Q1 review is an opportunity to verify that the documentation pipeline is working.

BRSR Core readiness. For listed companies subject to BRSR Core, the disclosure principles on community engagement, environmental impact, and human rights all draw from CSR programme data. The Q1 review is an opportunity to confirm that the data needed for BRSR is being captured.

Engage the auditor where appropriate. For any compliance question or significant programme adjustment, engage the company's auditor early. This is good practice and protects the programme from year-end surprises.

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How Marpu Foundation Helps Companies With CSR Programme Reviews

At Marpu Foundation, we work with companies across India as their implementation partner for CSR programmes, and we support the review process in ways that make Q1 and subsequent reviews simpler and more useful for the corporate team.

What we offer for the review process:

We provide structured Q1 reporting to corporate partners covering activity status, beneficiary engagement, spend deployment, and documentation status. The reports are designed to feed directly into the company's internal Q1 review process.

We participate in joint review conversations with the corporate team, walking through the Q1 status together so the team has both the data and the on-ground context they need.

We provide documentation in formats ready for audit and CSR-2 disclosure, so the review process is supported by clean records rather than scrambling for paperwork.

We support BRSR Core data requirements where applicable, with community engagement and impact data captured in formats that feed listed-company disclosures.

We engage transparently on any operational challenges that surface in Q1, working with the corporate team on the path forward.

Our experience:

We work across 23 states with over 250 corporate partners, including organisations from the Fortune 500. We hold valid 12A and 80G registrations and Form CSR-1 filing. We understand the documentation, audit, and reporting standards Indian CSR teams require, and we bring the discipline and infrastructure that supports clean quarterly review cycles throughout the year.

If your CSR team is preparing for a Q1 review and you would benefit from an implementation partner with the reporting infrastructure to support it, reach out to Marpu Foundation at connect@marpu.org. A short conversation will help you understand whether Marpu fits the programme structure and review rhythm your team is building.