CSR-2 Reporting — What Every CSR-Eligible Company Must File

CSR-2 Reporting — What Every CSR-Eligible Company Must File

As CSR spending scaled up across corporate India, the MCA introduced Form CSR-2 to capture far more granular data than the earlier one-page annexure to the Board's Report — project-wise spend, implementing agencies, unspent amounts, and set-off details. For any company covered under Section 135(1), understanding CSR-2 is now just as important as understanding the CSR obligation itself.

Every company that is covered under Section 135(1) — i.e., meets the net worth, turnover or net profit thresholds triggering CSR applicability — must file Form CSR-2 for the relevant financial year, regardless of whether it actually made any CSR expenditure that year.

•      Details of the CSR Committee's composition and meetings.

•      Average net profit for the preceding 3 financial years and the resulting 2% obligation.

•      Amount spent, project-wise, along with implementing agency details (whether through own CSR arm or a registered implementing agency).

•      Details of ongoing projects, including amounts transferred to the Unspent CSR Account.

•      Details of any amount transferred to a specified fund (like PM CARES Fund) for non-ongoing project shortfalls.

•      Details of any capital assets created or acquired through CSR spend and their registered ownership.

Unlike other annual filings that go alongside AOC-4 in the same filing session, CSR-2 has typically been notified as a separate filing exercise with its own due date, often falling after the AOC-4 due date to allow the CSR data to be compiled once the annual accounts are finalised. Over the past few years, the MCA has extended the CSR-2 due date multiple times — for instance, for FY 2023-24 the deadline was pushed in stages, ultimately to 30 June 2025, reflecting the practical challenges companies faced compiling detailed CSR data. Companies should always check the latest MCA circular for the applicable due date for the relevant financial year rather than assuming a fixed date.

•      Assuming CSR-2 filing is optional if the company had no CSR obligation for the year, when a nil filing may still be expected.

•      Waiting for the AOC-4 due date to also complete CSR-2, missing the separately notified CSR-2 deadline.

•      Providing inconsistent project-wise figures between the Board's Report annexure and the CSR-2 filing.

•      Failing to update implementing agency CSR-1 registration status before relying on them for a project.

Q1. Is CSR-2 filed along with AOC-4 or separately?

It is filed as an addendum, typically after the AOC-4 filing window, on a separate timeline notified by the MCA — companies must track this date independently rather than assuming it aligns with the AOC-4 due date.

Q2. Do companies with no CSR spend in a year still need to file CSR-2?

Yes, if the company is covered under Section 135(1), CSR-2 must be filed even if the CSR obligation was nil-spent or set off against excess spend from prior years, since it also captures details of unspent amounts and set-offs.

Q3. Has the CSR-2 deadline changed recently?

Yes, the MCA has extended CSR-2 filing deadlines multiple times over recent years in response to industry feedback; companies should check the latest circular on the MCA portal for the exact due date applicable to their financial year.

Q4. Is CSR-2 filed on the V2 or V3 MCA portal?

As part of the broader migration of company forms to the MCA V3 portal, companies should verify the current filing platform for CSR-2 each year, as forms have progressively moved from V2 to V3.

Q5. Is CSR-2 applicable to a company that has never had a CSR obligation?

No, CSR-2 filing applies specifically to companies covered under Section 135(1) that meet the applicability thresholds for the relevant financial year; companies that have never crossed the thresholds are not required to file it.

Q6. Can CSR-2 be revised after filing if an error is discovered?

Companies should promptly consult the current MCA guidance/helpdesk on the specific correction mechanism available, as revision processes for CSR-2 can change and should be verified for the relevant filing cycle.

Q7. Does CSR-2 require an auditor's certification?

CSR-2 largely relies on data already reflected in the audited financial statements and Board's Report; companies should ensure the CSR Committee/Board has reviewed and approved the figures before filing, consistent with the source documents.

CSR-2 has turned CSR reporting from a narrative paragraph into a data-rich, project-level disclosure that regulators can analyse at scale. Companies covered under Section 135 should maintain detailed, project-wise CSR records throughout the year rather than scrambling to reconstruct them at filing time.