Form CSR-2: the annual CSR filing

Form CSR-2 is the yearly CSR report that every company covered by Section 135 files with the Registrar of Companies, under Rule 12(1B) of the Companies (Accounts) Rules, 2014. It is linked to the company’s financial statements filing on Form AOC-4 and filed after it, and it records the company’s CSR obligation and spending project by project, including where each project ran and which implementing agency, by CSR registration number, carried it out.

It gives the Ministry of Corporate Affairs (MCA) a project-by-project view of each company’s CSR. The MCA’s FAQs say compliance is monitored through companies’ disclosures on its MCA21 portal (FAQ 2.6), and the data feeds the national CSR statistics. It complements the annual report on CSR, which goes in the board’s report and gives the same figures in summary.

This guide is for company secretaries, CSR and finance teams who prepare the filing. It explains who files and when, walks through the current form part by part, and covers the checks to run before filing, common errors and the penalties.

What CSR-2 is, and who files it

The rule was inserted by the Companies (Accounts) Amendment Rules, 2022, dated 11 February 2022. It applies to every company that meets one of the Section 135 tests, whatever it spent. A company that spent exactly its obligation, one that spent more, one with no CSR committee because its obligation is ₹50 lakh or less: all of them file. See which companies must spend on CSR.

When it is due

CSR-2 follows the financial statements. A company normally holds its annual general meeting within six months of the year-end, files its financial statements on AOC-4 within 30 days of the meeting, and then files CSR-2, quoting the service request number (SRN) of that AOC-4. For a 31 March year-end, the meeting is due by 30 September, so AOC-4 typically falls due by the end of October and CSR-2 follows it.

The MCA has, however, set separate deadlines more than once:

The current version of the form

The versions of the annual filing forms for the MCA’s new V3 system, including CSR-2, were notified by the Companies (Accounts) Second Amendment Rules, 2025 (G.S.R. 357(E), 30 May 2025). The new CSR-2 went live with the V3 roll-out on 14 July 2025, and the MCA describes it as an e-form linked to AOC-4.

A few features of the current form are worth knowing:

• It asks for the SRN of the AOC-4 filed for the company’s standalone financial statements, so AOC-4 must be filed first.
• Ongoing projects carry a project ID, which the form uses to track their spending across years.
• It expects a valid CSR registration number for every project run through an implementing agency.
• It is signed digitally by a director (or a resolution professional or liquidator) who has been authorised by a board resolution, quoting the resolution’s number and date. The notified form has no separate certificate by a practising professional.

What the form asks, part by part

Parts 5 to 9 mirror items 5, 6 and 9 of the annual report on CSR. Part 10 needs care: spending from an earlier year’s Unspent CSR Account belongs there, not in part 7 with this year’s spending. Our guides to net profit for CSR, unspent CSR money and capital assets explain the rules behind those parts.

Before you file: a checklist

• AOC-4 filed, and its SRN to hand.
• The board-approved annual report on CSR, so the figures in CSR-2 match it.
• A complete project register: each project’s Schedule VII item, location by state and district, whether it is in the local area, duration, spending and, for ongoing projects, the project ID.
• Implementing agencies’ CSR registration numbers, checked: an agency must be registered on Form CSR-1 to undertake CSR activity. See Form CSR-1.
• Utilisation certificates showing what each agency actually spent by the year-end.
• Bank statements for the Unspent CSR Account and receipts for any transfers to Schedule VII funds, with dates.
• Capital asset details as recorded in the revenue records.
• A board resolution authorising the director who will sign, and that director’s digital signature certificate.

How the data appears publicly

The MCA publishes CSR data from companies’ filings on the National CSR Portal and its Corporate Data Management pages, by company, state and development sector. In October 2026, the MCA’s data page said its CSR data was “as on 31st March, 2026 (FY 2024-25)”. The government’s latest published national total is ₹34,908.75 crore of CSR spending in 2023-24 (Press Information Bureau, 10 February 2026).

Three things to know when you use the data, or when you check how your own filing looks:

• “Development sectors” aren’t Schedule VII items. The portal sorts spending into about 29 reporting categories, while Schedule VII has 13 items.
• “PAN India” spending isn’t assigned to any state, so state totals add up to less than the national figure.
• Figures change. Late and revised filings keep raising past totals, so always quote the date a figure was reported.

Researchers, journalists and NGOs looking for CSR partners use this data. Our guide to India’s CSR in numbers explains what it can and can’t tell you.

Common errors

• Filing before AOC-4, or quoting the wrong SRN.
• Figures that don’t match the annual report on CSR or the notes to the accounts.
• The wrong Schedule VII item, or one project split across items to fit a category.
• “PAN India” used loosely for projects that ran in named districts.
• Missing or wrong CSR registration numbers, or an agency that isn’t registered on CSR-1.
• Counting money paid to an agency as spent when it hasn’t been used: only money the agency has actually used counts (FAQ 7.4).
• Mixing up years: spending from an earlier year’s Unspent CSR Account reported as this year’s.
• Transfer dates after the deadlines without the deficiency shown.
• Capital assets recorded without the owner’s details, or held by an owner the rules don’t allow.

Penalties for not filing, or filing wrongly

Rule 12(1B) doesn’t set a penalty of its own. Where the Companies Act provides no specific penalty for breaking the Act or its rules, Section 450 applies: a penalty of ₹10,000, and ₹1,000 for each further day the default continues, up to ₹2 lakh for the company and ₹50,000 for each officer in default. The MCA’s FAQs say that CSR defaults other than those under Section 135(5) and (6) are dealt with under Section 134(8) or Section 450 (FAQ 8.4). For one person companies, small companies, start-ups and producer companies, Section 446B limits the penalty to half the amount otherwise specified, so a Section 450 penalty is at most ₹1 lakh for the company and ₹25,000 for each officer in default.

The form itself warns that Sections 448 and 449 of the Act punish false statements and false evidence. And CSR-2 is often where a bigger problem shows: a company that didn’t move unspent money on time faces the separate penalties in Section 135(7), of twice the amount it should have transferred or ₹1 crore, whichever is less. See penalties for breaking the CSR rules. If you have missed a filing, take advice and file as soon as you can.