CSR-1 Registration India — MCA Portal: Who Needs It and Who Does Not
You need Form CSR-1 if you are a Section 8 company, public trust, society or statutory body that wants to carry out CSR projects on behalf of a company covered by Section 135 of the Companies Act 2013. The form is filed by the implementing organisation, not by the donor. A company that runs its CSR programmes on its own does not file it, and an ordinary for-profit company cannot act as an implementing agency at all. Since 1 April 2021 the registration has to be in place before you take on any new CSR project.
The questions below are the ones raised most often in practice. The full scope of the service is on the CSR-1 Registration India — MCA Portal page.
Which of the four Rule 4(1) routes are you on?
Rule 4(1) of the Companies (CSR Policy) Rules, 2014 lists who can implement CSR for a company. Your route decides whether you need a track record and whether you need income-tax approvals, so it is worth naming it before you fill in anything.
- Set up by the donor company (alone or with other companies): a Section 8 company, registered public trust or registered society. It needs income-tax status (section 12A registration or a section 10(23C) exemption) with 80G approval, but no three-year track record.
- Set up by the Central or State Government: a Section 8 company, registered trust or registered society. The MCA's FAQ exempts these from the 12A and 80G requirement.
- A statutory body created by an Act of Parliament or a State legislature.
- Everyone else: a Section 8 company, registered public trust or registered society with income-tax status (12A or 10(23C)) plus 80G approval and an established track record of at least three years in similar activities. Most NGOs are on this route.
What is Form CSR-1 and why is it mandatory?
Form CSR-1 is the registration form under Rule 4(2) of the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended in 2021. Every entity that intends to undertake CSR activity for a company covered by Section 135 has to file it electronically and obtain a CSR Registration Number. The MCA describes the aim as building a database of implementing agencies that companies can check, with more accountability and transparency in how CSR is carried out. In practice donors look the number up before they sign anything.
In practice: The requirement applies from 1 April 2021. It was not retrospective: the MCA allowed projects approved between 22 January and 31 March 2021 to continue with an unregistered agency, but the agency had to register before any new project. Organisations that have taken corporate donations informally for years may be asked for a CSR Registration Number for the first time, as donor companies face closer scrutiny of their own CSR compliance.
Do we need 12A and 80G registration before filing CSR-1?
Yes, in most cases. The MCA's FAQ states that a Section 8 company, public trust or society must hold income-tax registration under 12A and approval under 80G to act as an implementing agency, except an entity established by the Central or State Government. Since the 2022 amendment, Rule 4(1) accepts an entity exempt under sub-clauses (iv), (v), (vi) or (via) of clause (23C) of section 10 of the Income-tax Act, 1961, or registered under section 12A. The CSR-1 form pairs either status with 80G approval, so plan to hold 80G in both cases (unless the Central or State Government established the entity). The Income-tax Act 2025 renumbers these provisions from 1 April 2026, so confirm the equivalent registration or approval for your organisation with the Income Tax Department or PNPC. A trust registered under the Income-tax Act counts as a registered public trust in states where registering public trusts is not mandatory. So 12A and 80G are not a nice-to-have on top of CSR-1; they are part of the eligibility that the form asks you to declare.
In practice: If you are a young organisation, start the 12A and 80G applications first, or together with CSR-1, and do not plan a CSR conversation around a registration you do not yet hold. If you already have them, check the validity dates before filing. A lapsed 80G certificate is a common problem that disrupts donor relationships that were otherwise working. See our note on who needs 12A and 80G for the income-tax side.
What is the process on the MCA portal for filing CSR-1?
The form is filed electronically on the MCA portal. It is signed and submitted by the entity through its authorised signatory using a digital signature certificate, and it is then verified digitally by a practising Chartered Accountant, Company Secretary or Cost Accountant. When the form is submitted, the system generates the unique CSR Registration Number automatically. You will be asked for the entity type, PAN, registration details and the income-tax approvals, with the supporting certificates attached.
The MCA substituted Form CSR-1 with effect from 14 July 2025. Entities that already hold a valid registration number do not have to re-apply or re-file; the new form is for agencies that are new or not yet registered.
In practice: The form is unforgiving about mismatches. The entity name on the registration certificate, the PAN and the income-tax certificates should read identically. We check these before submission: name, address or PAN mismatches between attached documents are a primary cause of rejection. Confirm the current form version and portal steps on the MCA site or with PNPC before you start, as the portal changes from time to time.
What to have ready before you file
Prepare these before anyone opens the form, and check that each is current, not just present:
- The registration certificate: certificate of incorporation for a Section 8 company, or the trust or society registration certificate.
- The governing document as it stands today: MoA and AoA, trust deed, or society rules and regulations, including any amendments.
- The entity's PAN, matching the legal name on the registration certificate exactly.
- The 12A and 80G certificates, and evidence they are in force.
- The FCRA registration certificate, if you receive foreign contributions.
- A board resolution or equivalent authorising the signatory, plus the signatory's digital signature certificate.
- Audited accounts and activity reports for the last three years. These are not attachments to the form itself, but they are the evidence for the track-record route and the first thing a donor will ask for.
Common mistakes and how to avoid them
- Treating the income-tax approvals as optional. Under Rule 4(1) and the CSR-1 form, 12A or 10(23C) status together with 80G is a condition for most entities. Get them first.
- Assuming a registration number equals funding. The number is public and donors can verify it, but they still read your accounts, filings and governance. A number with lapsed underlying registrations is a liability.
- An objects clause that does not map to Schedule VII. CSR money can only be spent on Schedule VII activities. If your trust deed or MoA is vague or drifts far from those heads, fix it before a donor reviews it.
- Mixing funds. Keep each donor's programme money separately accounted for and never mix CSR money with general or foreign-contribution funds.
- Filing before the compliance record is clean. Overdue annual filings for a Section 8 company, a missed income-tax return or an overdue FCRA return will surface in donor due diligence even after the number is allotted.
What is the mandatory impact assessment requirement, and does it apply to us?
This obligation falls on the donor company, not the implementing organisation. Under Rule 8(3), impact assessment is compulsory only when both conditions are met: the company's average CSR obligation over the preceding three financial years is at or above the prescribed level, and the project's outlay is at or above the prescribed level and it was completed at least a year earlier. In other cases it is voluntary. It has to be done by an independent agency. Implementing organisations with larger programmes should still expect to cooperate with assessors and to maintain the programme data, beneficiary records and project documentation they need.
In practice: We help implementing organisations set up monitoring and evaluation records from the start of a programme, because data that was not collected at the time cannot be recreated for an assessor later.
What documents does a donor company typically ask for before releasing CSR funds?
Standard CSR partner due diligence documentation requested by mid- to large-cap donor companies typically includes: CSR-1 Registration Number and MCA certificate; valid 12A registration certificate; valid 80G registration certificate; PAN of the implementing entity; last 3 years' audited financial statements; ITR filings for the last 3 years; FCRA registration certificate (if applicable); activity / annual reports for the last 3 years; details of governing body (Board / Trustees / Managing Committee); bank account details for fund transfer; signed copy of CSR Policy of the implementing organisation; and CVs of key programme staff. Some donor companies also require a background check or site visit before the first fund transfer.
In practice: We prepare a standard due diligence pack for implementing organisations that covers these requests. Having it ready before you approach donors, rather than compiling documents after a donor expresses interest, removes the most avoidable delay in the process. The CSR-1 documents note goes through the pack in more detail.
Can an implementing organisation receive CSR funds from multiple companies simultaneously?
Yes. The registration belongs to the entity, not to a particular donor, so one CSR-registered organisation can receive funds from several companies for concurrent or different programmes. Each donor company and programme should be accounted for separately, and each donor will expect its own utilisation certificate and may want its own project reporting format. The organisation's accounting and governance systems have to be able to handle multi-donor, multi-project complexity.
In practice: We set up project-wise fund accounting from day one, with a project code for each donor programme, receipts and expenditure tracked at project level and donor-specific utilisation reports available on demand. That is what separates an organisation that can grow beyond one donor from one that cannot.
Can we start operating a CSR programme before the CSR-1 registration number is allotted?
Not for a new CSR project. Since 1 April 2021 an implementing agency has to be registered before undertaking new CSR projects for a company. The only relief in the MCA's FAQ is for projects approved between 22 January and 31 March 2021, which could continue with an unregistered agency. In practice, the registration should be done before, or at the same time as, signing the CSR funding agreement.
In practice: We sometimes see a corporate CSR team that wants to deploy money before its financial year-end. Raise the registration in the first conversation, not in the last week. File as soon as your documents are in order and the signatory's digital signature certificate is valid.
What happens if a donor company transfers CSR funds to an entity without a CSR-1 number?
That is the donor's problem first and yours second. The Board of the donor company has to ensure its CSR is carried out through the entities listed in Rule 4(1), and those entities must be registered. Money sent to an unregistered agency is exposed to being treated as not properly spent on CSR. If the company then falls short of its obligation, Section 135(5) and (6) of the Companies Act require the unspent amount to be moved to a special Unspent CSR Account within 30 days of the financial year-end for ongoing projects, or to a Schedule VII fund within six months for other projects, and penalties can follow for the company and its officers in default. Whether a particular payment qualifies is for the donor's own advisers to decide.
In practice: We advise donor companies to check the CSR-1 number of every proposed partner on the MCA portal before the funding agreement is executed and before any transfer, and we tell implementing organisations to expect that check.
Is there a minimum amount below which CSR-1 registration is not required?
The rules do not set a minimum grant size. Rule 4(2) requires every entity that intends to undertake CSR activity under Rule 4(1) to register, without a threshold. If a company routes any amount to an outside organisation and counts it as CSR expenditure, the recipient should be registered.
In practice: Some small corporate gifts are made outside the CSR framework, as a charitable donation, a sponsorship or an employee welfare contribution, and the donor does not treat them as CSR. Those do not need the registration in the recipient. Where the donor is claiming the amount as CSR, it does.
CSR-1 versus the neighbouring things people confuse it with
- CSR-1 versus 12A and 80G. These are income-tax approvals granted by the Income-tax Department. CSR-1 is a company-law registration on the MCA portal. You need both in most cases.
- CSR-1 versus the donor's CSR reporting. The donor company files the details of its CSR activities with the MCA annually. That is the donor's filing and it will quote your CSR Registration Number, so an error in your registration surfaces in their return.
- CSR-1 versus FCRA. FCRA governs foreign contributions, is administered by the Ministry of Home Affairs and has nothing to do with the MCA registration. See who needs FCRA registration.
What has changed recently
Two changes are worth knowing about. Besides the form change described above, in May 2026 the MCA amended the CSR rules and Schedule VII to allow companies to subscribe to zero coupon zero principal instruments issued by not-for-profit organisations on the Social Stock Exchange, with the responsibility for executing and evaluating the project sitting with the issuing organisation. That is a separate route with its own rules, and it does not replace CSR-1 for ordinary implementing arrangements.
Where this sits in the wider engagement
CSR-1 Registration India — MCA Portal rarely arrives on its own. The statutory basis and the current requirements are set out on the CSR-1 Registration India — MCA Portal service page, and the related services are grouped under Business Setup. If you are still choosing an entity type, read who should form a Section 8 company first, and for the full picture see the CSR-1 guide.
What PNPC does
PNPC Global has practised since 1986 across India and the UAE. On CSR-1 Registration India — MCA Portal we take the work end to end — reviewing the facts, preparing and filing what is required, and dealing with the authority through to closure.