CSR-1: Meaning, Purpose, Applicability and Filing Procedure under Companies Act, 2013

Summary: Form CSR-1 is the prescribed electronic registration form for eligible entities intending to undertake Corporate Social Responsibility (CSR) activities on behalf of companies under Section 135 of the Companies Act, 2013. Under Rule 4(2) of the Companies (Corporate Social Responsibility Policy) Rules, 2014, eligible implementing agencies must register with the Ministry of Corporate Affairs (MCA). The requirement applies to qualifying Section 8 companies, registered trusts, registered societies and specified statutory entities. Registration is not required where a company implements its CSR activities directly. The applicable eligibility conditions depend on the nature of the implementing agency, its income-tax registration or exemption status, and, in specified cases, a three-year track record. The CSR-1 form was also revised under the Companies (CSR Policy) Amendment Rules, 2025. This article explains the purpose, applicability, eligibility, documents, filing procedure and important compliance considerations.

What Is Form CSR-1?

Form CSR-1 is an electronic form prescribed under the Companies (Corporate Social Responsibility Policy) Rules, 2014, for registration of eligible entities intending to undertake CSR activities on behalf of companies.

It enables eligible organisations, including certain NGOs, Section 8 companies, registered public trusts, registered societies and statutory bodies, to register with the MCA and obtain a unique CSR Registration Number.

The requirement was introduced with effect from 1 April 2021 through the CSR implementing agency registration framework.

CSR-1 registration identifies an organisation as a registered implementing agency. However, registration does not automatically entitle the organisation to receive CSR funds or constitute approval of a particular CSR project.

Legal Framework Governing Form CSR-1

The principal legal provisions are:

• Section 135 of the Companies Act, 2013: Governs corporate social responsibility obligations of qualifying companies.
• Schedule VII of the Companies Act, 2013: Specifies the broad categories of activities that may qualify as CSR.
• Rule 4(1) of the Companies (CSR Policy) Rules, 2014: Specifies the eligible entities through which companies may undertake CSR activities.
• Rule 4(2): Prescribes mandatory registration of eligible implementing agencies through Form CSR-1.
• Companies (CSR Policy) Amendment Rules, 2022: Revised the categories and income-tax eligibility requirements of implementing agencies.
• Companies (CSR Policy) Amendment Rules, 2025: Substituted the prescribed e-form CSR-1.

For the revised eligibility provisions, refer to the Companies (CSR Policy) Amendment Rules, 2022. The 2025 amendment to Form CSR-1 should also be considered when preparing a current filing.

Why Is CSR-1 Registration Required?

The primary purpose of CSR-1 registration is to improve transparency and accountability in the implementation of CSR projects.

Its principal objectives include:

• Maintaining an identifiable database of eligible CSR implementing agencies.
• Helping companies identify organisations eligible to undertake CSR activities.
• Improving transparency in the flow and utilisation of CSR funds.
• Supporting monitoring and accountability of implementing agencies.
• Reducing the risk of engagement with organisations that do not satisfy the prescribed eligibility conditions.

The MCA’s FAQs on Corporate Social Responsibility clarify that registration is intended to create a database of implementing agencies and strengthen the CSR ecosystem.

Who Is Required to File Form CSR-1?

Under Rule 4(1), read with Rule 4(2), the following categories of eligible entities intending to undertake CSR activities on behalf of companies are required to register:

1. Entities Established by a Company

A Section 8 company, registered public trust or registered society established by a company, either individually or jointly with another company, may qualify if it satisfies the prescribed income-tax eligibility conditions.

2. Entities Established by the Government

A Section 8 company, registered trust or registered society established by the Central Government or a State Government may qualify under the applicable category.

3. Statutory Bodies

An entity established under an Act of Parliament or a State Legislature may qualify. For this purpose, the statutory explanation covers bodies constituted under such legislation to undertake activities covered by Schedule VII.

4. Independent Implementing Agencies

A Section 8 company, registered public trust or registered society not covered by the preceding categories may qualify if it meets the prescribed income-tax eligibility conditions and has an established track record of at least three years in undertaking similar activities.

Income-Tax Registration and Approval Requirements

The 2022 amendments to Rule 4(1) recognise specified income-tax exemption or registration routes.

Depending on the category of implementing agency, the relevant provisions include exemption under Section 10(23C)(iv), (v), (vi) or (via), or registration under Section 12A together with approval under Section 80G of the Income-tax Act, 1961.

Important: The statutory eligibility language and the applicable e-form declarations must both be examined. The amended form’s category descriptions expressly refer to Section 80G approval for certain entities. Applicants should not assume that an income-tax exemption certificate alone is sufficient without checking the exact category and current MCA filing requirements.

Is CSR-1 Mandatory for Every Company?

No. CSR-1 is a registration requirement for eligible implementing agencies and not a general annual filing requirement for every company.

A company may undertake CSR activities directly or through an eligible implementing agency.

Where the company undertakes CSR activities directly, Form CSR-1 registration is not required merely because the company is subject to Section 135.

However, if the company implements CSR activities through a separate eligible organisation, that implementing agency must comply with the applicable CSR-1 registration requirements.

The MCA has clarified this distinction in its CSR FAQs.

Documents and Information Required for CSR-1 Registration

The following documents and details should ordinarily be kept ready, subject to the requirements of the current MCA form and instruction kit:

• PAN of the implementing agency.
• Certificate of incorporation or registration, as applicable.
• Details of the entity’s legal constitution and registered office.
• Relevant Section 12A/12AB registration, Section 80G approval or Section 10(23C) exemption documentation, where applicable.
• Details of directors, trustees, governing body members or other authorised office-bearers.
• Valid email address and mobile number.
• Digital Signature Certificate of the authorised signatory.
• Authorisation or resolution permitting the designated person to sign and submit the form, where applicable.
• Details and supporting records establishing the three-year track record, where that condition applies.

The exact attachments and mandatory fields should be checked against the prevailing MCA version of Form CSR-1. For a general registration checklist, see FAQs on NGO Registration.

Step-by-Step Procedure for Filing Form CSR-1

Step 1: Check Eligibility

Identify the appropriate category under Rule 4(1). Verify the organisation’s legal constitution, income-tax registration or exemption status, and three-year track record wherever applicable.

Step 2: Prepare Supporting Documents

Collect the entity’s PAN, registration certificate, income-tax approvals, governing body details, contact information and other documents required under the applicable e-form.

Step 3: Access the MCA Portal

Access the MCA filing facility and select the prescribed Form CSR-1 for registration of entities undertaking CSR activities.

Step 4: Complete the Form

Enter the organisation’s particulars, select the correct implementing-agency category and provide the information and declarations required by the current version of the form.

Step 5: Digital Signature and Professional Certification

The authorised signatory of the implementing agency must digitally sign the form. It must also be electronically verified by a practising Chartered Accountant, Company Secretary or Cost Accountant, as prescribed.

The authorised signatory’s signature and the practising professional’s certification serve different purposes and should not be treated as interchangeable.

Step 6: Submit the Form

Submit the completed and certified form through the MCA portal and address any validation errors or resubmission requirements communicated through the filing system.

Step 7: Obtain the CSR Registration Number

Upon successful processing, the system generates a unique CSR Registration Number. The organisation should preserve the acknowledgement and registration details for future reference.

Who Can Certify Form CSR-1?

Form CSR-1 requires electronic verification by one of the following professionals in practice:

• Chartered Accountant (CA).
• Company Secretary (CS).
• Cost Accountant (CMA).

The professional should examine the relevant registration documents, statutory eligibility, declarations and supporting information before certifying the form.

Important Compliance Points for Companies and NGOs

• CSR-1 registration is not a funding guarantee: Companies retain responsibility for selecting suitable implementing agencies and approving CSR projects.
• Three-year experience is category-specific: It should not be treated as a universal condition for every eligible implementing agency.
• Registration is different from project eligibility: Activities must independently satisfy Section 135, Schedule VII and the applicable CSR Rules.
• Income-tax approvals require verification: The relevant registration or exemption should be valid and appropriate for the selected category.
• CSR fund utilisation must be monitored: The company’s Board remains responsible for ensuring that disbursed CSR funds are used for approved purposes.
• Historical guidance may be outdated: Applicants should consider the 2022 eligibility amendments and the revised 2025 CSR-1 form rather than relying exclusively on older filing guides.

For additional guidance on utilisation monitoring, refer to the ICAI Advisory on CSR Fund Utilisation.

Frequently Asked Questions on Form CSR-1

1. Can a Newly Registered NGO Apply for CSR-1?

It depends on the applicable eligibility category. An independent implementing agency falling under Rule 4(1)(d) must have an established track record of at least three years in undertaking similar activities. Other categories have different eligibility conditions.

2. Is CSR-1 Registration the Same as Section 80G Approval?

No. CSR-1 registration is governed by the Companies (CSR Policy) Rules, whereas Section 80G approval is governed by income-tax law. Both serve different statutory purposes.

3. Does CSR-1 Registration Automatically Make Donations Tax-Deductible?

No. The income-tax deductibility of a contribution must be determined independently under the applicable provisions. CSR-1 registration does not itself grant a deduction to the donor company.

4. Can an NGO Receive CSR Funding Without CSR-1?

An entity acting as an implementing agency under Rule 4(1) must comply with the registration requirement, subject to the specific transitional exception for certain projects approved before 1 April 2021. The nature of the arrangement should be examined before concluding that a payment constitutes CSR implementation through an agency.

5. Is CSR-1 an Annual Return?

No. CSR-1 is a registration form for eligible implementing agencies. It should not be confused with the separate CSR reporting obligations applicable to companies, including Form CSR-2 where applicable.

Conclusion

Form CSR-1 is an important compliance mechanism under the Corporate Social Responsibility framework established by the Companies Act, 2013. It helps identify eligible implementing agencies, promotes transparency and supports accountability in CSR implementation.

Organisations intending to implement CSR projects should first establish their eligibility under Rule 4(1), verify their income-tax registration or exemption status, prepare the required documents and complete the prescribed MCA filing process.

Companies engaging such organisations should also undertake appropriate due diligence, because obtaining a CSR Registration Number does not remove the company’s responsibility to ensure proper implementation and utilisation of CSR funds.