Multi-Year CSR Programme Planning: The Three-Year Framework for Indian Companies (2026 Guide)
- Marpu Foundation
- 3 hours ago
- 12 min read
Most CSR in India is planned one year at a time. The company calculates its annual obligation, deploys it across projects within the financial year, reports the spend, and starts again the next year. This annual rhythm is administratively simple, but it produces a recurring weakness: projects that need years to produce durable change are repeatedly designed, funded, and assessed as if they were single-year activities.
A school education programme does not transform learning outcomes in twelve months. A watershed restoration does not stabilise in one monsoon. A livelihood programme does not reach self-sustaining scale in a single financial year. These are multi-year efforts, and treating them as annual projects produces the familiar pattern of activity that starts, shows early output, and then stops when the year ends and attention moves to the next year's deployment.
The Companies (CSR Policy) Rules 2014 recognise this. They provide for the ongoing project, a multi-year project that a company can plan and fund across more than one financial year. Yet many companies underuse this provision, defaulting to annual planning because it is what they know. This article makes the case for multi-year planning and provides a three-year framework that companies can adapt to design CSR programmes built for durable change rather than annual output.
This article is written for the CSR head, the CSR Committee chairperson, the Company Secretary, the Chief Financial Officer, and the sustainability officer planning CSR programmes that aim for lasting impact. It is a practitioner-voice operational reference. It is not a substitute for the company's own CSR Committee, Company Secretary, Chartered Accountant, statutory auditor, and Legal counsel review of the specific programme the company adopts.
Important note: This article provides operational guidance on multi-year CSR programme planning under Indian law as of April 2026. It is informational guidance and does not constitute legal, financial, or compliance advice. The ongoing project provision and the broader CSR framework, including Section 135 of the Companies Act 2013 and the Companies (CSR Policy) Rules 2014, are subject to amendment by the Ministry of Corporate Affairs. Every multi-year programme should be reviewed and approved by the company's CSR Committee, Company Secretary, Chartered Accountant, statutory auditor, and Board before adoption. Verify against the current text of Section 135, the CSR Rules, and any recent MCA circulars before finalising the programme.
What an Ongoing Project Is Under the CSR Rules
Before the framework, the regulatory anchor needs to be clear. The Companies (CSR Policy) Rules 2014 define the ongoing project as a multi-year project undertaken by a company in fulfilment of its CSR obligation, having a timeline not exceeding three years excluding the financial year in which it was commenced.
Several features of this definition matter for planning.
It is explicitly multi-year. The ongoing project provision exists precisely to allow CSR planning beyond a single financial year
The timeline does not exceed three years excluding the commencement year. This means the project can span the commencement year plus up to three further years, and companies should confirm the current interpretation with their advisers
It allows funds to be carried to an Unspent CSR Account. For ongoing projects, amounts that remain unspent in a financial year can be transferred to a designated Unspent CSR Account and used for the project in subsequent years, within the framework the Rules specify
It requires the project to be identified as ongoing. The project should be designated as an ongoing project, with the Board approving and the CSR Committee monitoring it
It connects to the Annual Action Plan. The ongoing project sits within the company's Annual Action Plan, which is revisited each year
This provision is the legal foundation that makes genuine multi-year planning possible. The three-year framework in this article is a way of using it well.
Why Multi-Year Planning Produces Stronger CSR
Five reasons make multi-year planning stronger than repeated annual planning for projects that aim at durable change.
1. It Matches the Timeline of Real Change
Most meaningful social change takes longer than twelve months. Multi-year planning matches the funding and design timeline to the actual timeline of the change the programme aims to produce, rather than forcing a long-arc effort into an annual box.
2. It Reduces the Year-End Deployment Rush
Annual planning concentrates attention on deploying funds before the financial year ends. Multi-year planning, with the Unspent CSR Account provision for ongoing projects, reduces this pressure by allowing funds to carry to subsequent years for the designated project.
3. It Enables Deeper Partner Relationships
Multi-year programmes allow the company and its implementation partner to build the relationship and the shared understanding that single-year projects rarely develop. The deeper relationship produces better execution over time.
4. It Supports Sustainability and Handover
A multi-year arc can include a deliberate sustainability and handover phase, where the programme is designed to continue after the company's direct involvement ends. Single-year projects rarely include this, which is why so many fade when funding stops.
5. It Produces a Stronger Impact and Reporting Narrative
A multi-year programme with a clear arc produces a richer impact narrative than a series of disconnected annual activities. The narrative of sustained commitment strengthens the company's stakeholder reporting and, for listed companies, its BRSR disclosure.
The Three-Year Framework
The three-year framework organises a multi-year CSR programme into three phases, each with a distinct focus. The phases align with how durable change actually develops: a foundation year, a deepening year, and a sustainability year. Companies should adapt the framework to their specific programme, geography, and cause area.
Year 1: Foundation
The first year establishes the foundation. The temptation is to rush to visible output, but the strongest multi-year programmes invest the first year in building the base that the later years depend on.
The Year 1 focus areas are:
Baseline assessment. Capturing the baseline data that allows change to be measured across the programme. Without a baseline, the programme cannot demonstrate its impact in later years
Community engagement and trust-building. Establishing the relationship with the community the programme serves, which determines whether the later years' work is welcomed and sustained
Partner alignment. Building the shared understanding between the company and the implementation partner on goals, methods, and monitoring
Initial activities with learning orientation. Running the first activities with a focus on learning what works in this specific context, rather than on maximising output
Documentation systems. Establishing the documentation discipline that will support monitoring, reporting, and any impact assessment across the programme
Year 1 success is measured less by output and more by foundation strength: is the baseline captured, is the community engaged, is the partner aligned, are the systems in place. A strong foundation year makes the later years far more productive.
Year 2: Deepening
The second year deepens the work. With the foundation in place, the programme scales its activities, refines its approach based on Year 1 learning, and produces the bulk of its visible output.
The Year 2 focus areas are:
Scaling activities. Expanding the programme's activities to full scale, building on the foundation and learning from Year 1
Refining the approach. Adjusting methods based on what Year 1 revealed about the specific context
Building community ownership. Moving from the company and partner delivering to the community to the community increasingly participating in and owning the work
Mid-programme assessment. Assessing progress against the baseline at the programme's midpoint, identifying what is working and what needs adjustment
Deepening the partner relationship. Using the established relationship to execute more ambitiously than a first-year partnership could
Year 2 is typically where the programme produces its strongest output and where the multi-year investment begins to show returns that a single-year project could not have produced.
Year 3: Sustainability and Handover
The third year focuses on sustainability. The distinguishing feature of a strong multi-year programme is that it plans for what happens after the company's direct involvement ends. Year 3 is where this is built.
The Year 3 focus areas are:
Building self-sustaining structures. Establishing the community structures, local capacity, or institutional arrangements that allow the work to continue after the programme
Transitioning ownership. Completing the transition of ownership from the company and partner to the community or local institutions
Final impact assessment. Conducting the final assessment against the baseline, measuring the change the programme produced across its full arc
Documentation and knowledge capture. Capturing the full programme's learning for the company's future programmes and for the broader sector
Planning the exit or the next phase. Deciding whether the programme concludes with a sustainable handover or transitions into a new phase or a new geography
Year 3 done well means the programme's impact continues after the company's direct funding ends. This is the difference between a programme that produces lasting change and one that produces activity that stops when the money stops.
How to Design Each Year Within the Annual Action Plan
The three-year framework operates within the company's annual planning, because the Annual Action Plan is revisited each financial year. The two work together.
The multi-year programme is designated as an ongoing project in the Annual Action Plan, with its full arc described
Each year's specific activities are detailed in that year's Annual Action Plan, reflecting the phase the programme is in
The Unspent CSR Account provision is used where funds for the ongoing project remain unspent in a year and carry to the next, within the framework the Rules specify
The Board approves the ongoing project and the CSR Committee monitors it across the years
Each year's plan references the programme's progress against its multi-year arc, so the annual planning reflects the multi-year design
This connection means the multi-year framework does not replace annual planning. It gives the annual planning a multi-year structure to work within.
Documentation Across the Three-Year Arc
Documentation is what allows a multi-year programme to demonstrate its impact and support the company's compliance. Across the three-year arc, the documentation priorities are:
Year 1 baseline documentation, which establishes the starting point against which change is measured
Continuous activity-level documentation across all three years, capturing what was done, where, with whom, and with what output
Mid-programme assessment documentation in Year 2, capturing progress against the baseline
Final impact assessment documentation in Year 3, measuring the full programme's change, particularly where impact assessment applies under Rule 8(3) of the CSR Rules
Handover and sustainability documentation in Year 3, capturing how the work will continue after the programme
This documentation supports the company's CSR-2 filing, Board's Report, statutory audit, and BRSR Principle 8 disclosure across the programme's life, and it produces the impact narrative that single-year documentation cannot.
How Multi-Year Planning Strengthens Partner Retention and Outcomes
Multi-year planning has a relationship dimension that is worth naming directly, because it affects both the partner relationship and the programme outcomes.
It allows the partner relationship to mature. A partner working with a company across three years develops an understanding of the company's priorities, standards, and communication style that a single-year partner cannot
It produces accumulated context. The partner's accumulated knowledge of the specific community and geography across years produces better execution than starting fresh each year
It supports honest course-correction. A multi-year relationship has the trust for honest conversations about what is not working, which produces better adjustment than a transactional single-year arrangement
It aligns incentives toward durability. When both the company and the partner are committed to a multi-year arc, both are incentivised toward durable outcomes rather than annual output
It builds the track record that supports future work. A successful multi-year programme builds the relationship and the evidence that support future programmes, in the same geography or in new ones
The retention of strong implementation partners across multi-year programmes is itself a marker of programme health. Programmes that change partners every year rarely produce the depth that multi-year continuity allows.
Five Common Mistakes in Multi-Year CSR Planning
Across observed practice, five recurring patterns weaken multi-year programmes.
1. Rushing to Output in Year 1
The most common mistake is treating Year 1 as a full-output year rather than a foundation year. Programmes that rush to output before the baseline, community engagement, and systems are in place tend to be weaker across their full arc.
2. Not Designating the Project as Ongoing
Companies sometimes run what is effectively a multi-year programme without formally designating it as an ongoing project, which means they cannot use the Unspent CSR Account provision and lose the regulatory benefit the provision offers. Designating the project correctly matters.
3. Skipping the Sustainability Phase
Some multi-year programmes invest in foundation and deepening but neglect the Year 3 sustainability and handover work, producing programmes that still fade when funding ends. The sustainability phase is what makes the multi-year investment durable.
4. Failing to Maintain Documentation Across Years
Programmes that document Year 1 well but let documentation lapse in later years lose the ability to demonstrate the full arc's impact. Documentation discipline must be maintained across all three years.
5. Treating the Three Years as Three Separate Projects
The strongest multi-year programmes are designed as a single arc with three phases, not as three disconnected annual projects that happen to be in the same area. The arc is what produces the durable change.
Five Suggestions for Stronger Multi-Year Programmes
The following suggestions reflect practice that produces stronger multi-year programmes. They are observations, not prescriptions.
1. Design the Full Arc Before Year 1 Begins
The strongest multi-year programmes are designed as a full three-year arc from the start, with each year's role clear. This is stronger than designing Year 1 and figuring out the later years as they come.
2. Invest Seriously in the Foundation Year
Resisting the pressure to rush to output and investing Year 1 in baseline, engagement, and systems produces a far stronger programme across its full arc.
3. Build the Sustainability Plan From the Start
The Year 3 sustainability and handover work is more effective when it is designed from the start and built toward across all three years, rather than added at the end.
4. Choose a Partner Who Can Commit to the Full Arc
Multi-year programmes work best with a partner who can genuinely commit to the full arc, with the geographic presence and operational capacity to sustain the work across years.
5. Review and Adjust at Each Year's Planning
While the arc is designed from the start, each year's annual planning is an opportunity to review progress and adjust. The strongest programmes hold the arc steady while adjusting the specifics based on what each year reveals.
How This Connects to the Broader CSR Framework
Multi-year programme planning connects to the broader CSR compliance framework in several ways.
The ongoing project provision under the Companies (CSR Policy) Rules 2014 is the regulatory foundation for multi-year planning
The Annual Action Plan under Rule 5(2) incorporates the multi-year programme and details each year's activities
The Unspent CSR Account provision allows funds for ongoing projects to carry across years
Schedule VII alignment applies to multi-year programmes as to annual projects, with the primary clause documented
CSR Impact Assessment under Rule 8(3) applies to qualifying projects, and the multi-year arc supports the assessment with baseline and final data
The Board's Report and Form CSR-2 report the ongoing project across its years
BRSR Principle 8 disclosure for listed companies draws on the multi-year programme's sustained engagement
Understanding these connections helps companies plan multi-year programmes that strengthen their whole CSR compliance rather than complicating it.
A Note on the Limits of This Article
This article provides operational guidance on multi-year CSR programme planning based on the requirements of the Companies (CSR Policy) Rules 2014 as understood as of April 2026. It is informational guidance and does not constitute legal, financial, or compliance advice.
The ongoing project provision and the broader CSR framework are subject to amendment by the Ministry of Corporate Affairs. The specific timeline interpretation, the Unspent CSR Account mechanics, and related provisions should be confirmed against the current Rules with the company's advisers. Every multi-year programme should be reviewed and approved by the company's CSR Committee, Company Secretary, Chartered Accountant, statutory auditor, and Board before adoption.
Verify against the current text of Section 135 of the Companies Act 2013, the Companies (CSR Policy) Rules 2014, Schedule VII, and any recent MCA circulars before finalising the programme. The three-year framework in this article is a starting reference, not a definitive template, and should be adapted to the company's specific context with professional review.
What This Article Is Actually Saying
Three things are worth holding onto.
1. Most meaningful change takes longer than one year, and annual planning forces long-arc efforts into an annual box. Multi-year planning matches the funding and design timeline to the actual timeline of the change.
2. The ongoing project provision exists precisely to enable multi-year planning. Designating a programme as an ongoing project unlocks the Unspent CSR Account provision and the regulatory foundation for planning across years.
3. The three-year arc, foundation then deepening then sustainability, is what produces durable change. A strong foundation year, a productive deepening year, and a deliberate sustainability and handover year together produce impact that continues after the company's direct involvement ends.
The companies that produce the strongest CSR outcomes are increasingly those that plan in multi-year arcs, invest in the foundation, build toward sustainability, and design the full programme before Year 1 begins. The compounding effect across the arc, and across successive programmes, is considerable.
Working With Marpu Foundation on Multi-Year CSR Programmes
At Marpu Foundation, multi-year programme planning is central to how we work across our network of 250+ corporate partnerships and 23+ Indian states. Our 85 percent corporate partner retention rate, which sits considerably above the Indian sector average, is built substantially on multi-year orientation: the programmes that produce durable change and lasting partnerships are the ones designed as arcs rather than as repeated annual projects.
For corporate CSR teams planning multi-year programmes for FY 2026-27 and beyond, the ways we support the three-year framework include the following:
Full-arc programme design: Helping CSR teams design the complete three-year arc, with the foundation, deepening, and sustainability phases clear from the start
Foundation-year delivery: Conducting baseline assessment, community engagement, and systems establishment in Year 1, with the discipline that the later years depend on
Schedule VII alignment and ongoing project designation: Supporting the correct designation of the programme as an ongoing project and its alignment with the relevant Schedule VII clause
Documentation across the arc: Maintaining baseline, activity-level, mid-programme, and final assessment documentation that supports CSR-2 filing, the Board's Report, statutory audit, and BRSR Principle 8 disclosure across the programme's life
Sustainability and handover: Designing and delivering the Year 3 sustainability and handover work that allows the programme to continue after direct involvement ends
We hold current CSR-1 registration, 12A registration, and 80G registration, and our documentation discipline supports corporate partners' multi-year programme execution and reporting across the full arc.
For CSR teams planning a multi-year programme, write to connect@marpu.org or visit marpu.org.
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