Is CSR-2 required even if full CSR was spent?

Yes. CSR-2 is mandatory for all Section 135-covered companies regardless of whether the full obligation was spent.

What is the due date for CSR-2?

CSR-2 is due within 60 days of the AGM — the same deadline as AOC-4. For March 31 year-end companies, this is typically November 29.

CSR-2 Filing – Annual CSR Disclosure Report to ROC | NDS Avla

CSR-2 – Annual CSR Disclosure Filing With the ROC

Q: What is the impact assessment requirement?

Companies with average CSR obligation ≥ ₹10 crore and projects ≥ ₹1 crore each must get third-party impact assessments. The cost (up to 5% of CSR spend or ₹50 lakh) is a permitted CSR expense.

Mandatory Annual Report on CSR Activities — Filed as an Addendum to AOC-4 Under the Companies (CSR Policy) Amendment Rules 2021

Form CSR-2 is a standalone annual return introduced by the MCA from FY 2021–22 onwards, requiring companies subject to Section 135 of the Companies Act 2013 to separately disclose their CSR activities, spending, implementing agencies, and unspent amounts to the Registrar of Companies (ROC). It is filed as an addendum to Form AOC-4 (the Annual Financial Statement filing) and must be submitted after AOC-4 is filed, but within the same regulatory timeline.

CSR-2 transforms CSR compliance from a narrative disclosure in the Board's Report to a structured, machine-readable, publicly accessible filing on the MCA portal. This ensures that a company's CSR performance — including any shortfall in spending, transfers to unspent accounts, or transfers to PM National Relief Fund — is permanently recorded in the MCA21 database and accessible to regulators, shareholders, and the public.

Our CSR-2 Filing Services

CSR Spend Computation

Accurate calculation of the 2% CSR obligation based on average net profits of the immediately preceding three financial years — identifying eligible and ineligible expenditures to arrive at the correct prescribed CSR amount.

Project-wise CSR Data Compilation

Organising CSR project data by Schedule VII category, implementing agency (with CRN), mode of implementation, amounts committed, amounts spent, and balance unspent — in the exact format required by Form CSR-2.

Unspent Amount Reporting

Disclosure of amounts transferred to the Unspent CSR Account (for ongoing projects) and amounts transferred to Schedule VII funds — with bank account details, transfer dates, and amounts — as required in CSR-2.

Impact Assessment Disclosure

For companies with average CSR obligations of ₹10 crore or more over 3 years, impact assessment by a third-party agency is mandatory. We coordinate impact assessment reports and integrate findings into CSR-2 disclosures.

CSR-2 Filing on MCA21

Preparation and e-filing of Form CSR-2 on the MCA21 V3 portal with DSC authentication — ensuring all mandatory fields are populated and all schedule-wise annexures are correctly attached before submission.

Board Report CSR Annexure

Drafting the mandatory CSR annexure to the Board's Report (as required under Rule 9 of the Companies (CSR Policy) Rules 2014) — covering CSR policy, committee details, spending summary, and reasons for unspent amounts.

Key Information Disclosed in CSR-2

CSR-2 Section	What Is Disclosed
Basic Company Details	CIN, company name, financial year, CSR applicability basis
CSR Committee	Composition of CSR Committee or confirmation that Board handles CSR functions
CSR Obligation	Average net profit of preceding 3 years and 2% obligation amount
CSR Activities	Project name, Schedule VII item, implementing agency CRN, mode, location, amounts allocated and spent
Unspent CSR	Amounts in Unspent CSR Account — ongoing project details, amounts, timelines
Transfers to Schedule VII	Amount and date of transfer to PM National Relief Fund or other eligible funds
CSR Amount Spent Details	Capital vs. revenue expenditure split, administrative overhead details
Impact Assessment	Whether impact assessment was conducted; external agency name; report details

⚠️ CSR-2 must be filed after AOC-4 but is due by the same deadline as AOC-4 (60 days from AGM, or November 29 for companies with March 31 financial year-end). Late filing of CSR-2 attracts the same late fees as AOC-4 — ₹100 per day with no maximum cap.

Frequently Asked Questions

Is CSR-2 required even if the company spent the full 2% CSR obligation?

Yes. CSR-2 is mandatory for all companies to which Section 135 applies — regardless of whether they have fully spent the 2% obligation, underspent, or overspent. The form captures the CSR story for the year: how much was obligated, what was spent, on what projects, through which agencies, and what (if anything) remains unspent. It is an accountability document, not just a penalty trigger.

What is the due date for filing CSR-2?

CSR-2 is filed as an addendum to AOC-4. The due date is the same as AOC-4 — within 60 days of the AGM. For companies with a financial year ending March 31 and an AGM deadline of September 30, CSR-2 is typically due by November 29 (60 days from September 30). Companies that extend their AGM date or receive ROC extensions for AOC-4 should confirm the applicable CSR-2 deadline for that year.

What is the impact assessment requirement in CSR-2?

Companies with an average CSR obligation of ₹10 crore or more over three years, and whose CSR projects individually have outlays of ₹1 crore or more, must conduct impact assessments through independent third-party agencies. The impact assessment report for projects completed in the financial year must be submitted along with CSR-2. The cost of such assessments — up to 5% of CSR expenditure or ₹50 lakh, whichever is lower — is a permitted CSR expense.

Can CSR-2 be revised after filing?

Unlike some ROC forms, MCA does not currently provide a straightforward revision mechanism for CSR-2 once filed. Material errors should be addressed by filing a fresh CSR-2 (if the MCA portal permits resubmission for the relevant financial year) or by seeking specific ROC guidance. This underscores the importance of getting the CSR-2 data — particularly amounts, agency CRNs, and project details — precisely right before submission. Our team thoroughly verifies all data points before filing.

Need Help Filing Your Annual CSR-2 Return?

Our CSR compliance specialists prepare and file CSR-2 accurately — with complete data compilation, spend reconciliation, unspent amount disclosures, and MCA portal submission. Avoid late fees and ROC scrutiny with timely, error-free CSR-2 filing.

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