The full corporate-social-responsibility exercise — from computing the spend obligation, vetting the recipient and choosing the route, through the Committee and Board, to disbursal, CFO certification and filing — so no step is missed.
Before anything is spent, two questions are settled: is the company within §135(1), and what is the rupee obligation? The obligation drives everything downstream — including whether a CSR Committee is even mandatory.
| Net worth | ≥ ₹500 crore |
| Turnover | ≥ ₹1,000 crore |
| Net profit | ≥ ₹5 crore (§198-adjusted PBT) |
| Committee mandatory? | Only if obligation > ₹50 lakh [§135(9)]; also if any Unspent CSR Account is ever held [Rule 3 proviso] |
| Impact assessment? | Only if average CSR obligation ≥ ₹10 crore over 3 preceding FYs [Rule 8(3)] |
| Financial year | §198-adjusted net profit (₹) |
|---|---|
| Year T-1 (most recent) | |
| Year T-2 | |
| Year T-3 | |
| Average net profit | — |
| CSR obligation @ 2% | — |
List every NGO, foundation, fund or nodal agency under consideration, the Schedule VII activity each would carry, and its CSR-1 number. This is the shortlist the Committee will choose from.
| Recipient | Proposed activity | Sch. VII item | CSR-1 No. | Eligibility |
|---|
Pre-loaded with two common recipient types. Edit or delete — the eligibility column updates automatically based on whether a valid CSR-1 number is entered.
Eligibility turns on Rule 4(1) — read with Rule 4(2) for CSR-1 — not on §135(1). The conditions depend on how the entity was established. Switch the classifier; the checklist rewrites itself.
| CSR Registration No. | Obtained on CSR-1 filing; verified by CA / CS / CMA in practice — confirm validity on MCA21 |
| 12A / §10(23C) status | Copy of CBDT order; check expiry date — re-registration under revised provisions required post-2020 |
| 80G approval | Copy of CBDT approval; confirm it has not lapsed |
| PAN / bank details | Verified against the CSR-1 registration and recipient's letterhead |
Both are lawful. The choice changes the paperwork, the registration burden and the monitoring obligations. Read both columns, then record the decision in the Committee minute.
Where constituted, the Committee owns the policy and the annual action plan. At obligation ≤ ₹50 lakh a Committee is optional [§135(9)], but if any Unspent CSR Account is ever held it becomes mandatory [Rule 3 proviso].
CSR is a Board-driven process. The Board approves the policy and the AAP, ensures the spend, satisfies itself on utilisation, and authorises the CFO certification. Where there is a shortfall, the Board records reasons in its report.
The money moves, the activity happens, and the file is built. The pivotal rule: a transfer is not "spend" until the recipient actually utilises it within the year.
| Payment evidence | Bank transfer advice / cheque details; date of disbursal within the FY |
| Recipient identification | PAN, CSR-1 registration number, 12A/80G certificates, bank details on letterhead |
| Utilisation confirmation | Utilisation certificate from recipient (with project details, amount utilised, period) |
| CFO certificate | Rule 4(5) — funds utilised for the purposes and in the manner approved by the Board |
| Acknowledgement | Receipt from recipient / fund / nodal agency |
If the full obligation is spent within the FY, this stage is a formality. If not, the treatment forks on whether the underspend relates to an ongoing project — and the timelines are strict, with a civil penalty for default.
| Company | Twice the unspent amount OR ₹1 crore, whichever is less — over and above the obligation |
| Officer in default | 1/10th of the unspent amount OR ₹2 lakh, whichever is less |
| Note | Penalty is in addition to — not instead of — the transfer obligation |
The exercise closes on the public record: the Board's report annexure, the website, and Form CSR-2 to the Registrar. Miss none of these — disclosure is the spine of the CSR architecture.
| Item | What | Trigger / due | Authority |
|---|---|---|---|
| Board's report — CSR annexure | Annual report on CSR in the Annexure II format (post-2021 amendment) — Committee composition, spend, projects, shortfall reasons if any | With the Board's report for the FY | Rule 8(1) |
| Website disclosure | CSR Committee composition, CSR Policy, and Board-approved projects — for public access | On approval / ongoing | Rule 9 |
| Form AOC-4 | Financial statements with the Registrar | Within 30 days of the AGM | §137 |
| Form CSR-2 | Report on CSR — addendum to AOC-4 (revised e-form w.e.f. 14.07.2025). Confirm the operative MCA due date for each FY before filing. | Verify MCA21 for current operative date | Accounts Rule 12(1B) |
| Impact assessment report | Only if average CSR obligation ≥ ₹10 crore over 3 preceding FYs — if triggered, annex to Board's report | With the Board's report (if triggered) | Rule 8(3)(b) |
The CSR-2 due date has shifted by notification several times; confirm the operative date on MCA21 for the relevant FY rather than relying on a remembered date.