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Microlesson · 5-min read

CSR Implementation and Reporting

# CSR Implementation & Reporting

## CSR Implementation Modes

The Board of Directors (BOD) must ensure CSR activities are undertaken through one of the following routes:

### Route 1: By the company itself

The company directly executes the CSR activities.

### Route 2: Through an eligible entity

The company may implement CSR through:

(a) Section 8 company / registered public trust / registered society that is:

  • A charitable entity established by the company (alone or jointly with another company),
  • Established by Central Government / State Government, or
  • A charitable entity having 3 years' experience in undertaking similar activities.

(b) Statutory body established by an Act of Parliament / State Legislature.

> Registration requirement: Such entities must register with the Central Government by filing Form CSR-1 (verified by a CA / CS / CMA) with the ROC. A CSR Registration Number is generated on submission.

## Local Area Preference

The company shall give preference to the local area where it operates while spending on CSR.

## Collaboration and International Engagement

PermittedConditions
Collaboration with other companiesCSR committee of each company must be in a position to report separately on its projects/programmes
Engaging international organisationsOnly for designing, monitoring & evaluation of CSR projects, and for capacity building of own personnel

## CSR Reporting

### (A) Annual Reporting on CSR

  • The Board Report of a company required to constitute a CSR Committee shall include an Annual Report on CSR.
  • In case of a foreign company, the balance sheet shall contain the Annual Report on CSR.

### (B) Impact Assessment

Applicable to companies having an average CSR obligation of ≥ ₹ 10 crores in the preceding 3 financial years.

Key requirements:

  • Impact assessment must be done through an independent agency.
  • Applies to CSR projects with outlays ≥ ₹ 1 crore and which were completed at least 1 year before the assessment.
  • The Impact Assessment Report must be placed before the BOD and annexed to the Annual Report on CSR.

### Booking of Impact Assessment Expenditure

The company may book impact assessment expenditure as CSR expenditure of the FY up to the higher of:

  • 2% of CSR expenditure of the FY, or
  • ₹ 50 lakhs.

## Quick Reference Table

ParticularsThreshold
Impact assessment triggerAvg. CSR obligation ≥ ₹ 10 crores in last 3 FYs
Project outlay needing impact assessment≥ ₹ 1 crore
Project completion requirementAt least 1 year before assessment
Cap on impact assessment expenditure (as CSR)Higher of 2% of CSR expenditure or ₹ 50 lakhs

Worked example

### Example 1

Example 1: Local benefit not qualifying as CSR

A Ltd. sponsors school fees of its employees' children under a 'CSR welfare initiative'.

Analysis: Since the activity benefits the company's own employees (an internal stakeholder group), it does not qualify as CSR. CSR must benefit the public/community at large — not those connected with the company.

Conclusion: Such expense cannot be claimed as CSR spending.

### Example 2

Example 2: Impact Assessment Applicability

B Ltd. has the following average CSR obligation over the preceding 3 FYs:

  • FY1: ₹ 8 crores
  • FY2: ₹ 12 crores
  • FY3: ₹ 10 crores
  • Average = ₹ 10 crores

It completed a CSR project of ₹ 1.5 crores 14 months ago.

Analysis:

  • Average CSR obligation ≥ ₹ 10 crores → Impact assessment required.
  • Project outlay (₹ 1.5 cr) ≥ ₹ 1 cr → Covered.
  • Completed > 1 year ago → Eligible for assessment.

Conclusion: B Ltd. must conduct impact assessment through an independent agency.

⚠️ Common exam mistakes

  • Treating activities exclusively benefiting employees or directors as eligible CSR — they are NOT.
  • Forgetting that the impact assessment trigger is based on the average CSR obligation of preceding 3 FYs, not the current year.
  • Confusing the project outlay threshold (≥ ₹ 1 crore) with the company-level CSR obligation threshold (≥ ₹ 10 crores avg).
  • Forgetting that an international organisation can only be engaged for design, monitoring, evaluation, and capacity building — NOT for execution of the CSR activity.
  • Missing the requirement that Form CSR-1 must be verified by a CA / CS / CMA before filing.
  • Applying the impact assessment expenditure cap as flat 2% instead of 'higher of 2% or ₹ 50 lakhs'.
Bare-Act text Section 135 and Schedule VII · Companies Act, 2013 and Companies (CSR Policy) Rules, 2014 · click to expand
Section 135 read with Companies (Corporate Social Responsibility Policy) Rules, 2014 — governs CSR implementation, reporting and impact assessment.
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