The Board of Directors may discharge CSR obligations through any of the following modes:
### Mode 1: Directly by the Company itself
The company itself implements its CSR projects/programmes.
### Mode 2: Through an Implementing Agency
The Board may undertake CSR through:
1. A Section 8 Company, OR
2. A Registered Public Trust, OR
3. A Registered Society
### Conditions for Implementing Agencies
The implementing entity must be either:
(a) Established by the company itself (alone or with another company), OR
(b) Established by the Central Government / State Government (under any Act), OR
(c) Any entity established under an Act of Parliament or State Legislature, OR
(d) Any other Section 8 company / Public Trust / Society which has an established track record of at least 3 years in undertaking similar activities.
### CSR Registration Requirement
Every implementing entity that intends to undertake CSR activity must register itself by filing Form CSR-1 with the ROC (Registrar of Companies).
On registration, a unique CSR Registration Number is generated.
This requirement is mandatory before the entity can be used as an implementing agency by any company.
Worked example
### Example 1
Example 1: ABC Ltd wishes to route its CSR spending through 'XYZ Trust', a 2-year-old public trust set up by an unrelated promoter. Permitted? — No, an external public trust must have a track record of at least 3 years.
### Example 2
Example 2: ABC Ltd sets up its own Section 8 Company in April 2025 to implement CSR. Can it use this entity in 2025 itself? — Yes, a Section 8 company established by the company itself does not require the 3-year track record condition.
### Example 3
Example 3: A trust set up under a special State legislature Act wants to implement CSR for PQR Ltd. Track record required? — No, entities established under any Act of Parliament/State legislature are exempt from the 3-year track record condition.
### Example 4
Example 4: A registered society (eligible) is selected by ABC Ltd as implementing agency but has not filed Form CSR-1. Can ABC Ltd transfer CSR funds to it? — No, Form CSR-1 filing and CSR Registration Number are mandatory.
⚠️ Common exam mistakes
Forgetting the 3-year track record condition for external Section 8 companies / trusts / societies.
Skipping CSR-1 filing for the implementing agency — without the unique CSR Registration Number, the agency is ineligible.
Confusing implementing agencies set up BY the company (no track record needed) with EXTERNAL agencies (3-year track record needed).
Assuming any trust will do — the trust must be a REGISTERED PUBLIC trust, not a private trust.
Bare-Act text Rule 4 — CSR Implementation · Companies (CSR Policy) Rules, 2014 · click to expand
The Board shall ensure that the CSR activities are undertaken by the company itself or through (a) a company established under section 8 of the Act, or a registered public trust or a registered society, established by the company, either singly or along with any other company; or (b) a company established under section 8 of the Act or a registered trust or a registered society, established by the Central Government or State Government; or (c) any entity established under an Act of Parliament or a State legislature; or (d) a company established under section 8 of the Act, or a registered public trust or a registered society, having an established track record of at least three years in undertaking similar activities. Every entity, covered above, who intends to undertake any CSR activity, shall register itself with the Central Government by filing the form CSR-1 electronically with the Registrar.