Checklist
The documents CSR teams will ask for
Before it funds you, a company’s CSR team will ask for a set of documents and check them against public records. Here is the full list, why each one matters, how to keep a ready data room, and what to keep private.
At a glance9 min read
- The core pack: registration certificate and founding document, PAN, income-tax registration and donor approval orders, CSR-1 number, NGO Darpan ID, three years’ audited accounts, annual reports, board list and key policies.
- CSR teams check documents against public records, so the same name, address and PAN must appear on every one.
- The CSR Rules still say 12A and 80G: send your section 332 registration and section 354 approval orders under the Income-tax Act, 2025, or your old orders while they are valid.
- Good funders ask for less on small, low-risk grants and more on large or sensitive ones, such as work with children.
- Share board members’ personal documents only when they are genuinely needed, and never publish them or anyone else’s personal data.
On this page
A CSR team will usually ask for your registration certificate and founding document, PAN, income-tax registration and donor approval orders, CSR registration number, NGO Darpan ID, three years of audited accounts and tax returns, annual reports, a list of your board, key policies, your FCRA status and bank details, plus references and reports on past projects. Have them ready, current and consistent before you approach a company: missing or mismatched documents are among the commonest reasons a grant stalls.
This checklist is for NGO leaders and finance staff. It lists each document, why it’s asked for and what to watch, then covers where companies check documents, how much to expect, keeping a data room, and what to keep private.
Why companies ask for so much
A company’s board must ensure its CSR money goes only to an eligible implementing agency (Rule 4(1) of the CSR Rules) and must satisfy itself that the money was used as approved, with its chief financial officer certifying it (Rule 4(5)). The documents are how it does that. Checking partners is the company’s job, and a careful team checks each document against the public record rather than taking a copy on trust.
Good teams keep checks in proportion to the grant. Many set three levels in their grant manual, for example:
| Level | Typical grant | What it adds |
|---|---|---|
| Light | One year, under ₹10 lakh, low risk | Registrations, latest audited accounts, board list, a short plan and recent report |
| Standard | ₹10 lakh to ₹1 crore, or up to two years | Three years of accounts, founding documents read in full, conflict-of-interest policy, references, one site visit |
| Deep | Over ₹1 crore, multi-year, or high-risk | Board minutes, budget against actuals for past grants, results data, more references and visits |
These bands are practice, not law. Work with children or vulnerable adults, construction, cash-heavy work or a grant much larger than your budget will raise the level whatever the size.
Legal identity and eligibility
| Document | Why it’s asked for | Watch out for |
|---|---|---|
| Registration certificate: trust, society or Section 8 company (with its Section 8 licence) | Shows you exist, with your exact legal name, date and number | The name must match every other document |
| Founding document: trust deed, society memorandum and rules, or memorandum and articles | Your objects must cover the project, and the dissolution clause must keep assets charitable | Include every registered amendment |
| PAN of the organisation | Your tax identity, quoted on every tax and CSR document | Same name as the registration |
| Income-tax registration order (section 332, formerly 12A or 12AB) | Required for an implementing agency under Rule 4(1) | Check the validity dates |
| Donor-deduction approval order (section 354, formerly 80G) | Also required under Rule 4(1) | Note when renewal is due |
| CSR-1 registration number | Required since 1 April 2021 to implement CSR (Rule 4(2)) | It must be in your name and PAN, not a sister organisation’s |
| NGO Darpan ID (now also called NPO Darpan) | Mandatory for central government grants, and often asked for | It shows you registered on the portal, nothing more |
| FCRA registration, with validity, or a note that you have none | Matters if any foreign contribution is involved | Since 22 June 2026 it names the purposes and states it covers. See what FCRA is |
| Registration of a child care institution, if you run one | Required by section 41 of the Juvenile Justice Act, 2015 | Needed for any residential care of children in need of care and protection |
The CSR Rules, and Form CSR-1, still use the Income-tax Act, 1961’s section numbers, 12A and 80G. Since the Income-tax Act, 2025 came into force on 1 April 2026, send your section 332 and section 354 orders (Form 107, which carries a 16-digit registration number, or Form 106 for provisional registration), or your old orders (such as Forms 10AC and 10AD) while they’re valid. See income-tax registration for NGOs.
Money
| Document | Why it’s asked for | Watch out for |
|---|---|---|
| Audited accounts for the last three years, with the auditor’s report | Your size, stability, sources of income and spending | Signed, with the auditor’s membership number and date |
| Income-tax returns and audit reports for the same years | Shows you meet your tax conditions | Returns and audit reports for 2025-26 and earlier are under the 1961 Act (ITR-7, Form 10B or 10BB) |
| Main funders over three years, with amounts | Shows how much depends on one funder | Explain any sudden jump in income |
| Current year’s budget | Shows the grant’s size against your whole budget | A first grant above about half your annual spending will draw questions |
| Cancelled cheque or bank letter | Confirms the account is in the organisation’s name | Never a personal account |
For larger grants, expect requests for the auditor’s management letter and for budget against actual spending on past grants.
Governance and policies
| Document | Why it’s asked for | Watch out for |
|---|---|---|
| Board list, with roles, backgrounds and any family or business relationships | Independence, skills and possible conflicts with the company’s people | Declare any link with the company’s directors or staff |
| Conflict-of-interest policy, and records of declarations | Shows conflicts are managed | Related-party payments must be disclosed and approved |
| Safeguarding or child protection policy | Essential for any work with children or vulnerable adults | A named lead, training and a route to report to the police, as section 19 of the POCSO Act requires |
| Prevention of sexual harassment (POSH) policy | An Internal Committee is required with 10 or more employees | Keep the committee’s annual report on file |
| Finance and procurement policy | Every grant | Delegated limits, two signatures for large payments, cash limits |
| Whistle-blowing and grievance policy | Every grant | A route outside management |
| Data protection and consent policy | Any project that collects personal data | Plan for the DPDP Act duties that apply from 13 May 2027 |
See policies every NGO should have.
Programme and track record
| Document | Why it’s asked for | Watch out for |
|---|---|---|
| Annual reports for the last three years | What you did, for whom and with what result | Real numbers, with their sources |
| Reports on similar past projects, grant letters or completion letters | Supports the three-year track record in similar activities that Rule 4(1)(d) requires | Cover the full three years |
| Results data, and how you measured it | Outcomes, not just activities | Baselines and methods, not round numbers |
| References | Someone outside the NGO who has seen the work | Another funder and a government officer or school head |
| Photos and stories | Shows the work | Consent recorded for each identifiable person; nothing staged |
Where companies check documents
| Item | Where a CSR team checks it |
|---|---|
| Section 8 company | The MCA portal’s company master data: status, directors and filings |
| Trust or society | The Charity Commissioner or Registrar of Societies, where records are online |
| Tax registrations | The approval orders, and the Income Tax Department’s e-filing portal |
| CSR-1 | The MCA’s records, and the National CSR Exchange Portal |
| NGO Darpan ID | ngodarpan.gov.in |
| FCRA | fcraonline.nic.in, which lists registered, cancelled and ceased organisations |
| Audited accounts | The signed report, and the auditor’s membership of the ICAI |
Expect to be asked about anything that doesn’t match. A Darpan ID or a CSR-1 number shows only that you’re registered; neither is an assessment of your work, so the company will also look at your accounts, programme and governance.
Keeping a ready data room
A data room is one folder with every document a funder might ask for, kept up to date. To build one:
- Scan each document as a clear PDF, including every page and signature.
- Name files the same way every time, such as “AshaTrust_PAN.pdf” and “AshaTrust_Audit_2025-26.pdf”.
- Add a one-page index listing each document, its date and its expiry.
- Update it the day anything changes: a new board member, a renewed registration, the latest audit.
- Share it as one link, with access you can withdraw, rather than 30 email attachments.
Keep a calendar of expiry dates. Income-tax registrations and donor approvals are granted for fixed periods, and renewal applications are due at least six months before expiry. FCRA registration lasts five years, and the renewal window opens six months before it ends.
What to keep private
A CSR team needs to know who runs your organisation, but it rarely needs everyone’s identity documents.
- Board members’ PAN, Aadhaar and home addresses: send them only when a funder genuinely needs them, through a secure link, and use a masked Aadhaar, which shows only the last four digits, where a copy is required.
- Beneficiaries’ personal data: share totals and anonymised data, not lists of names, phone numbers and addresses, unless the agreement requires it and people have agreed. Under the Digital Personal Data Protection Act, 2023 and its Rules, a child’s data needs verifiable consent from a parent or guardian, and the main duties for organisations apply from 13 May 2027. See data protection for NGOs.
- Staff CVs: share them with the person’s agreement, without details the funder doesn’t need.
- Never publish anyone’s personal documents, birth dates, phone numbers or home addresses on your website or in reports. Publishing your registration numbers and audited accounts is fine, and many funders welcome it.
Common mistakes
- Expired registrations, or a renewal application filed late.
- A CSR registration number that belongs to another organisation.
- Objects that don’t cover the project, with no registered amendment.
- Unsigned or unaudited accounts.
- Policies copied from another NGO, with its name still in them.
- Aadhaar copies emailed to anyone who asks.
Questions people ask
- What documents are required for CSR funding?
Usually the NGO’s registration certificate and founding document, PAN, income-tax registration and donor approval orders, CSR-1 registration number, NGO Darpan ID, three years of audited accounts and tax returns, annual reports, a board list, key policies, FCRA status and bank details. Larger grants also need references, reports on past projects and sometimes board minutes.
- Do I need CSR-1 registration before applying for CSR funds?
You need a CSR registration number before you can implement a company’s CSR project, so register on Form CSR-1 before you start approaching companies. Companies check that the number is in your organisation’s name and PAN.
- Are old 12A and 80G certificates still valid under the new Income-tax Act?
Yes. Registrations under sections 12A, 12AA and 12AB and approvals under section 80G of the 1961 Act carry over under the Income-tax Act, 2025 until they expire. Renew them in Form 105 at least six months before expiry, as section 332 registration and section 354 approval.
- Why do CSR teams ask for three years of audited accounts?
Three years of accounts show an NGO’s size, stability, sources of income and how it spends its money, and what its auditor has said. They also help show the three-year track record in similar activities that independent implementing agencies need under Rule 4(1)(d) of the CSR Rules.
- Should an NGO share its board members’ Aadhaar with a CSR team?
Only if the funder genuinely needs it. Share it through a secure link rather than open email, and use a masked Aadhaar, which shows only the last four digits, where a copy is required.
Sources
- Frequently asked questions on CSR (General Circular 14/2021) · Ministry of Corporate Affairs
- The Companies Act, 2013 (Section 135 and Schedule VII) · India Code, Ministry of Law and Justice
- Guide to Income-tax Act, 2025 forms (March 2026) · Income Tax Department
- Voluntary Action Cell and NGO Darpan · NITI Aayog
- Digital Personal Data Protection Rules, 2025 (press release) · Press Information Bureau
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