Launch offer — 25% off with code LAUNCH-25 See plans →
Microlesson · 5-min read

CSR Unspent Amount Transfer – Section 135(5) and Schedule VII

## CARO Clause: Transfer of Unspent CSR Amount under Section 135(5)

### Background: Section 135(5), Companies Act 2013

Every qualifying company must spend at least 2% of the average net profits of the immediately preceding three financial years on Corporate Social Responsibility (CSR) activities listed in Schedule VII to the Companies Act.

---

### Two Scenarios — What the Auditor Checks

#### Scenario A: Non-Ongoing Projects

> Has the company transferred any unspent CSR amount (for non-ongoing projects) to a Fund specified in Schedule VII within 6 months of the expiry of the financial year?

#### Scenario B: Ongoing Projects

> Has any unspent amount relating to ongoing projects been transferred to the designated Unspent CSR Special Account?

---

### Key Distinction at a Glance

Project TypeTransfer DestinationDeadline
Non-ongoing projectFund specified in Schedule VII (e.g., PM CARES, Clean Ganga Fund)Within 6 months of FY end
Ongoing projectSpecial Unspent CSR Account opened by the companyBefore the end of the FY (transfer within specified timelines)

---

### Schedule VII

Schedule VII lists the specific categories of activities eligible for CSR spending, such as eradicating hunger, promoting education, healthcare, environmental sustainability, and contribution to national relief funds.

---

### Auditor's Procedure

1. Compute total CSR obligation for the year (2% of average net profits).

2. Verify actual CSR spend and classify each project as ongoing or non-ongoing.

3. Identify any unspent amounts.

4. Check transfer to correct destination within the prescribed deadline.

5. Report non-compliance in CARO.

Worked example

### Example 1

A company's CSR obligation for FY 2023–24 is ₹50 lakh. It spent ₹35 lakh on a completed road-construction project (non-ongoing). The unspent ₹15 lakh should have been transferred to a Schedule VII fund by 30 September 2024 (6 months after 31 March 2024). The auditor finds the transfer was made on 15 November 2024 — beyond the deadline. The auditor must report this non-compliance in CARO.

### Example 2

A company has an ongoing school-construction CSR project spanning two financial years. Unspent amount at year-end = ₹20 lakh. The auditor verifies that ₹20 lakh has been deposited into the company's Unspent CSR Special Account as required. Compliance confirmed — no adverse CARO remark needed.

⚠️ Common exam mistakes

  • Applying the 6-month deadline rule to ongoing projects — the 6-month transfer to Schedule VII funds applies only to non-ongoing projects; ongoing project balances go to the Unspent CSR Account.
  • Computing CSR obligation on current-year net profit instead of the average of the preceding three financial years.
  • Failing to verify the specific Schedule VII fund selected is a recognised eligible fund.
  • Overlooking the distinction between 'spent on CSR activities' and 'transferred to Unspent CSR Account' — unspent amounts transferred to the account are not treated as 'spent' until deployed.
Bare-Act text Section 135(5) · Companies Act, 2013 · click to expand
The Board of every company shall ensure that the company spends, in every financial year, at least two per cent of the average net profits of the company made during the three immediately preceding financial years, in pursuance of its Corporate Social Responsibility Policy.
Now that you've read this — what's next?
Move from understanding → mastery in 3 clicks. Each option below picks up from this lesson's topic.
Start 15-min diagnostic