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Guide

Reporting to funders: progress reports and utilisation certificates

A CSR funder needs your reports to meet its own legal duties, from its chief financial officer’s certificate to its year-end transfers. Here is what to report, when and how, including utilisation certificates, honest bad news and the final report.

SocioStory Knowledge desk

Reviewed 9 min read

At a glance9 min read

  • A company’s chief financial officer must certify that CSR money was used as the board approved (Rule 4(5)), and that certificate rests on your utilisation certificates and records.
  • Money counts as the company’s CSR spending only when you use it, so report what you have actually spent, and send your figures as at 31 March early in April.
  • A utilisation certificate shows, for one grant and period, what was received, what was spent by budget line, any interest earned and the balance left.
  • Report outcomes against the indicators in your agreement, not just activities, and raise problems as soon as you see them.
  • Photographs and stories in reports need the consent of the people in them, and must never identify a child victim or a child in care.
On this page
  1. What a CSR funder needs your reports for
  2. What to report, and when
  3. Utilisation certificates
  4. Reporting outcomes, not just activity
  5. Photos and stories with consent
  6. When things go wrong
  7. Year-end and final reports
  8. Questions people ask
  9. Sources

Reporting to a funder means telling it, regularly and honestly, what you did with its money, what changed as a result, and what went wrong. For a CSR funder it also means giving the company what it needs for its own legal duties: evidence that the money was used as its board approved, its year-end figures, details of any assets, and the data its CSR reports require.

This guide is for NGO programme and finance staff, and for the CSR teams who receive their reports. It covers what a company needs from you and why, the reports to send and when, utilisation certificates, reporting outcomes, photos and stories, reporting problems, and year-end and final reports.

What a CSR funder needs your reports for

Every report you send feeds a duty the company has under Section 135 of the Companies Act, 2013 or the CSR Rules:

The company’s dutyWhat it needs from you
Its board must satisfy itself that the money was used as approved, and its chief financial officer must certify this (Rule 4(5))Utilisation certificates and records it can rely on
Money paid to an agency counts as spent only when the agency uses it (FAQ 7.4)What you have actually spent, not what you received
Unspent money for an ongoing project goes into its Unspent CSR Account within 30 days of 31 March; other unspent money goes to a Schedule VII fund within six monthsYour figures as at 31 March, early in April
Surplus from CSR, such as interest you earn on its funds, must be used only for CSR (Rule 7(2); FAQ 3.4)The interest earned on each grant
CSR-funded capital assets must be held by an eligible NGO, the beneficiaries or a public authority (Rule 7(4))A register of assets bought, their cost and who holds them
It reports its CSR each year: totals in the annual report on CSR in its board’s report (since 20 September 2022), and project by project, with the agencies, in Form CSR-2For each project: the Schedule VII item, location, amount spent and your CSR registration number
A company with an average CSR obligation of ₹10 crore or more must have an independent agency assess its projects of ₹1 crore or more (Rule 8(3))Baseline data, records and access for the assessor

Listed companies in India’s top 1,000 also publish a Business Responsibility and Sustainability Report, whose voluntary questions include CSR projects in aspirational districts and how many beneficiaries come from vulnerable and marginalised groups. If your funder answers them, it will ask you for those numbers.

So a good report isn’t a favour to a funder. It is part of how the funder stays within the law, and the clearer it is, the easier you are to fund again. For the company’s side, see monitoring CSR projects.

What to report, and when

Your agreement should fix the reports, their format and their dates. If it doesn’t, agree a rhythm like this:

ReportWhat’s in itWhen
Progress updateActivities and spending against plan, problems, next stepsMonthly or quarterly
Tranche reportProgress against the milestone, and a utilisation certificate for the previous trancheBefore each tranche
Year-end figuresMoney received, spent and unspent as at 31 March, interest, assets boughtEarly April
Annual reportOutcomes against indicators, spending against budget, lessons, plans for next yearAfter the year-end
Final reportResults against targets, final accounts, assets and handover, what happens nextWhen the project ends

A progress report needs no more than a few pages. A simple structure:

  1. Summary: on track or not, in two sentences.
  2. Milestones and activities against the plan.
  3. Outputs and outcomes against the indicators, with the baseline and target for each.
  4. Spending against the budget, with any big difference explained.
  5. Problems and what you’re doing about them.
  6. Safeguarding incidents, reported as the agreement requires.
  7. The next period: the plan and the money it needs.

Utilisation certificates

A utilisation certificate (UC) is a statement of how a grant was spent against its approved budget over a period. It is signed by your authorised signatory and is usually certified by a chartered accountant, often your statutory auditor; your agreement will say what the company needs.

PartWhat to show
The grantFunder, agreement reference, project and the period covered
Money inOpening balance, each tranche received with its date, and interest or other income earned on the grant
Money outSpending by budget line: the budget, spent in the period, spent to date
AssetsCapital items bought, with their cost and where they are
BalanceWhat’s left, and how it will be used
CertificationThat the money was used for the purposes of the grant, with signatures and dates

Keep the grant in a separate bank account or ledger, so every figure can be traced to vouchers and bank statements.

Reporting outcomes, not just activity

Funders want to know what changed, not only what you did. “48 sessions held” is an output; “girls reading a Class 3 text rose from 31% to 47%” is an outcome. Report both, against the indicators in your agreement:

  • Give the baseline, the target and the method for each indicator, and say who collected the data.
  • Break numbers down by gender, age, disability or social group where the agreement asks and where it doesn’t risk identifying anyone.
  • Count each person once, and say how you counted.
  • Say what you can and can’t attribute. Some change would have happened anyway; claim what your data supports.
  • Use outside records where you can, such as school attendance registers or health centre data, which carry more weight than your own counts.

See choosing indicators and baselines and evaluation.

Stories and photographs make reports come alive, and funders often reuse them in their own reports and on their websites. Two rules protect the people in them:

  • Consent first. Anyone who can be identified should understand where their story or photo will appear, agree to it, and be able to change their mind. For children, a parent or guardian consents. If the company may reuse the material, make sure the consent covers that use.
  • Never identify children at risk. Indian law forbids identifying a child victim of a sexual offence (section 23 of the POCSO Act, 2012), and any child in need of care and protection, child in conflict with the law, or child victim or witness (section 74 of the Juvenile Justice Act, 2015). Blur children’s faces by default.

Don’t stage photographs, use captions that respect people’s dignity, and remove location data from image files before you share them. Never use an AI-generated image as if it showed your work. See consent, photos and dignity.

When things go wrong

Every project hits problems: floods close a centre, a key person leaves, a price doubles. Funders forgive problems; they rarely forgive surprises.

  • Report early, before the next report is due, with what happened, what it affects and what you propose.
  • Ask before you move money. Moving money between budget lines usually needs the funder’s written approval, and the company may need to record the change in its own plan.
  • Report serious incidents at once. A safeguarding concern goes to the authorities as the law requires, and then to the funder within the time your agreement sets. A suspected fraud goes to the funder straight away.
  • Don’t hide underspending. If you won’t use a tranche by 31 March, say so in February, so the company can plan its year-end.

Year-end and final reports

At the year-end, send the company your figures as at 31 March early in April: money received, spent and unspent, interest earned and assets bought. The company has until 30 April to move unspent money for ongoing projects into its Unspent CSR Account, so it needs your numbers in the first weeks of April. The MCA’s FAQs don’t say how money left with an agency at the year-end should be treated, so your agreement should say whether it carries forward, for an ongoing project, or is returned.

The final report closes the grant. Include:

  • results against every target, and what you learned, including what didn’t work;
  • total spending against budget, with a final utilisation certificate;
  • the asset register and handover papers for anything passing to a gram panchayat, a school or a community group;
  • what happens to any unspent money or interest, as the agreement says;
  • what happens to participants’ personal data: kept, handed over or deleted, as agreed;
  • how the work will continue, and a thank-you to the people who made it happen.

Keep your records for as long as the law and your agreement require; auditors and impact assessors may ask for them years later. See also accounts and audit for NGOs.

Questions people ask

What is a utilisation certificate for a CSR grant?

A utilisation certificate (UC) is a statement of how a grant, or one tranche of it, was spent against its approved budget over a period. It shows the money received, interest earned, spending by budget line, any assets bought and the balance. The company relies on it for its chief financial officer’s certificate that the money was used as the board approved.

Who signs a utilisation certificate?

The NGO’s authorised signatory signs it, and it is usually certified by a chartered accountant, often the NGO’s statutory auditor. The grant agreement should say exactly who must sign and certify it.

How often should an NGO report to a CSR funder?

As the grant agreement says. A common pattern is a progress update every month or quarter, a utilisation certificate before each new tranche, year-end figures in early April, an annual report on outcomes and a final report when the project ends.

What happens to unspent CSR money with an NGO at the end of the year?

Money an NGO hasn’t used by 31 March doesn’t count as the company’s CSR spending for that year, and the company must deal with its own unspent amount by the legal deadlines. The MCA’s FAQs don’t say how a balance left with an agency should be treated, so the agreement should say whether it carries forward for an ongoing project or is returned.

Can a CSR funder use photos of the people we work with?

Only if the people in them, or a parent or guardian for a child, have consented to that use. A child victim, or a child in need of care and protection, must never be identifiable. Agree in writing how the company may use your photos and stories.

Sources

  1. Frequently asked questions on CSR (General Circular 14/2021) · Ministry of Corporate Affairs
  2. The Companies Act, 2013 (Section 135 and Schedule VII) · India Code, Ministry of Law and Justice
  3. General Financial Rules, 2017, updated to 31 July 2024 (Rule 238 and Form GFR 12-A) · Department of Expenditure, Ministry of Finance
  4. The Protection of Children from Sexual Offences Act, 2012 · India Code, Ministry of Law and Justice

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