How to File CSR Annual Report in India

Marpu Foundation
2 days ago
4 min read

If you are a CSR manager or company secretary, you already know the stress that comes with the annual reporting season. Filing the CSR annual report is mandatory for every company that falls under Section 135 of the Companies Act, 2013. Get it wrong, and you risk penalties, board-level questions, and reputational damage.

This guide walks you through exactly how to file your CSR annual report in India step by step, in plain language, with zero jargon.

Who Needs to File a CSR Annual Report?

Your company must file a CSR annual report if it meets any one of these conditions in the preceding financial year:

Net worth of ₹500 crore or more
Turnover of ₹1,000 crore or more
Net profit of ₹5 crore or more

If your company qualifies, you are required to spend at least 2% of your average net profits from the last three financial years on CSR activities. And every rupee spent must be reported.

What Forms Do You Need to File?

There are two main filings involved:

Your company must file a CSR annual report

1. Form CSR-2

This is the dedicated CSR return introduced by the Ministry of Corporate Affairs. It captures all the details of your CSR spending, projects, implementing agencies, and unspent amounts.

Form CSR-2 must be filed separately from the annual return. It is submitted through the MCA21 portal.

2. Board's Report (Annexure on CSR)

Your company's Board Report must include an annexure in the format prescribed under the Companies (CSR Policy) Rules. This annexure summarises your CSR policy, committee composition, spending, and impact.

Step-by-Step Process to File CSR Annual Report

Step 1: Gather All Project Documentation

Before you start the filing, collect complete records for every CSR project undertaken during the year. This includes:

Fund Utilisation Certificates from implementing NGOs
Beneficiary details and locations
Photographs and field evidence
Impact assessment data
Board resolutions and approvals

If your implementing partner has not sent you a proper FUC and impact report, chase them now. You cannot file without this.

Step 2: Calculate Your CSR Obligation

Work out your average net profit for the last three financial years. Calculate 2% of that amount. This is your mandatory CSR spending for the year.

Compare this with your actual spending. If there is a shortfall, you must either transfer the unspent amount to a Schedule VII fund or carry it forward with a valid explanation.

Step 3: Prepare the CSR Annexure for Board Report

Use the prescribed format to prepare your annexure. It must include:

Brief outline of your CSR policy and web link
Composition of CSR committee
Average net profit and 2% obligation
Total amount spent and project-wise breakup
Details of implementing agencies including their CSR registration number
Excess or unspent amounts and reasons
Impact assessment summary (mandatory for companies spending ₹10 crore or more)

Step 4: Get Board and Committee Approvals

Your CSR committee must review and approve the annual CSR report before it goes to the board. The board must then approve it as part of the directors' report.

Ensure meeting minutes are properly recorded for audit purposes.

Step 5: File Form CSR-2 on MCA Portal

Fill in all the required fields:

CIN and company details
CSR registration numbers of implementing agencies
Project-wise spending with location and sector
Ongoing vs completed projects
Unspent amounts and fund transfers

Attach supporting documents where required. Pay the filing fee and submit.

Step 6: Include CSR Annexure in Annual Return

Attach the CSR annexure to your Board Report. This goes into your company's annual return filed under Form AOC-4.

Double-check that the figures in the annexure match the figures in Form CSR-2. Any mismatch will trigger scrutiny.

Common Mistakes to Avoid

Filing without verified FUCs

Many companies file based on estimates or incomplete documentation. This creates problems during audits and assessments. Always get signed Fund Utilisation Certificates before you file.

Using NGOs without CSR registration

From April 2021, every implementing agency must have a CSR registration number issued by MCA. If your NGO partner does not have this, the spending may be disqualified.

Missing the deadline

Form CSR-2 must be filed within 30 days from the date of the AGM. Late filing attracts additional fees and potential penalties.

Ignoring the impact assessment requirement

If your company has spent ₹10 crore or more on CSR in the preceding three years, you must conduct an independent impact assessment. Skipping this is a compliance violation.

Deadlines You Must Know

Filing	Deadline
Form CSR-2	Within 30 days of AGM
Board Report with CSR Annexure	Along with Annual Return (Form AOC-4)
Transfer of unspent amount	Within 6 months of financial year end

Mark these dates in your calendar at the start of every financial year.

How Marpu Foundation Supports CSR Compliance

At Marpu Foundation, we understand that CSR reporting is only as good as the documentation behind it.

That is why every corporate partner working with us receives complete compliance support Fund Utilisation Certificates prepared to MCA standards, satellite-mapped beneficiary registers, photographic evidence from every project site, and detailed impact reports aligned to Schedule VII categories and SDG indicators.

Whether your company is funding tree plantation drives, solar street light installations, school infrastructure, or community water projects, we ensure you have every document you need before your filing deadline.

With operations across 23 states and partnerships with over 250 corporates, we have built our systems specifically to make CSR compliance painless for your team.

If you are planning your next CSR project and want a partner who handles both impact and paperwork with equal seriousness, reach out to our CSR team today.

Final Checklist Before You File

All FUCs collected and verified
CSR registration numbers of all implementing agencies confirmed
2% obligation calculated correctly
Project-wise breakup prepared
Unspent amounts transferred or explained
Impact assessment completed (if applicable)
CSR committee approval recorded
Board approval recorded
Form CSR-2 filed on MCA portal
CSR annexure attached to Board Report

Get this right, and your CSR reporting becomes a straightforward annual exercise instead of a last-minute crisis.

Marpu Foundation is one of India's leading NGOs for corporate CSR partnerships, specialising in environmental conservation, education infrastructure, women empowerment, and sustainable community development.

Write to us at connect@marpu.org to discuss your CSR goals.