CSR Compliance for NGOs (Form CSR-1)

Companies (Corporate Social Responsibility Policy) Rules, 2014, Rule 4(2), as amended with effect from 1 April 2021 (mandatory CSR-1 filing), with the CSR-1 e-form notified vide G.S.R. 452(E) dated 7 July 2021: every entity — whether a Section 8 company, registered public trust, or registered society — seeking to receive CSR funding from companies must register with the Central Government by electronically filing Form CSR-1 with the Registrar of Companies, along with a certificate from a chartered accountant, company secretary, or cost accountant. On successful filing, a unique CSR Registration Number is generated, which is a mandatory prerequisite for any company to route CSR expenditure to that entity under Section 135 of the Companies Act, 2013. NGOs and trusts implementing CSR-funded projects should ensure CSR-1 registration is completed and current before entering into any CSR implementation agreement, since expenditure routed to an unregistered entity does not qualify as valid CSR spend for the contributing company.

CSR compliance for NGOs is the framework through which not-for-profit organisations become eligible to receive corporate CSR funds under Section 135 of the Companies Act 2013. Companies within the Section 135 thresholds must spend 2% of their average net profits on CSR activities listed in Schedule VII, and the funds can flow to eligible implementing agencies. Under the Companies (CSR Policy) Rules 2014, an NGO that implements CSR activities on behalf of companies must register in Form CSR-1 with the Ministry of Corporate Affairs — the registration that corporate donors check before releasing funds.

For an NGO, Form CSR-1 registration is effectively a licence to receive corporate money. CSR committees are required to undertake due diligence of implementing agencies, and the registration certificate — with its unique number — is the first document they ask for. Without it, the CSR funds either do not flow or flow in violation of the Rules, exposing both the corporate donor and the NGO.

For the NGO, the compliance continues after registration: the funds received must be used for Schedule VII activities, accounted for separately, and reported back to the corporate donor for its Form CSR-2 filing and its own disclosure under the Act. An NGO that cannot document the use of CSR funds damages the donor's compliance and its own credibility in one stroke.

This service is for NGOs, trusts and Section 8 companies that want to receive CSR funds from companies. We register the organisation in Form CSR-1 under the CSR Policy Rules 2014, advise on the activities that qualify under Schedule VII of the Companies Act 2013, set up the separate accounting and reporting for CSR funds, and support the annual reporting cycle so the NGO remains a preferred channel for corporate CSR.