Company · Annual rhythm
Did CSR just become mandatory for us?
The short answer
CSR becomes mandatory when any one threshold is met in the preceding financial year: net worth of ₹500 crore, turnover of ₹1,000 crore, or net profit of ₹5 crore. The company must adopt a CSR policy, constitute a CSR committee (or have the board act where exempt), and spend 2% of average net profits. Implementing agencies need CSR-1 registration before receiving funds; the annual CSR-2 report is filed with (or as an addendum to) AOC-4 — the CSR-2 form page carries the current window.
What gets filed with MCA
Filed before receiving CSR contributions. The CSR-1 registration is required for every CSR implementing entity from April 1, 2021.
Section 135(1), Companies Act 2013; Rule 4(1), Companies (CSR Policy) Rules 2014
Filed with AOC-4 (within 30 days of AGM), or by March 31 where CSR-2 is filed separately as an addendum.
Section 135(9), Companies Act 2013; Rule 12(2), Companies (CSR Policy) Amendment Rules 2021
The paperwork nobody tells you about
Statutory formats that never touch the MCA portal — but an ROC inspection or due diligence will ask for every one of them.
CSR committee (or board, where committee exempt) and policy adopted; 2% of average net profits spent
Section 135, Companies Act 2013
The sequence
- 1Check whether any Section 135 threshold was crossed in the preceding financial year
- 2Constitute the CSR committee and adopt the CSR policy
- 3Register implementing agencies via CSR-1 before any CSR contribution is received
- 4Execute CSR spend and file CSR-2 with AOC-4 or by 31 March as an addendum
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Questions founders actually ask
What triggers CSR compliance?
If net worth exceeds ₹500 crore, turnover exceeds ₹1,000 crore, or net profit exceeds ₹5 crore in the preceding financial year — any one is enough.
When is CSR-1 required?
Every CSR implementing entity must be registered through CSR-1 before receiving CSR contributions. This has been mandatory since 1 April 2021.
When do we file CSR-2?
CSR-2 is filed as part of, or as an addendum to, the AOC-4 filing. MCA has notified separate standalone windows in some years — the CSR-2 form page linked above always carries the current position.
Reviewed by Harun Raaj, Chartered Accountant
Founder, Harun Raaj & Associates. Last verified 2026-08-24 against MCA V3 records and ICSI reference material. Form-level deadlines and penalties live on the linked form pages and update there.