A Complete Guide to CSR-1 Registration for CSR Funding in India

Corporate Social Responsibility (CSR) in India has evolved from a voluntary activity into a structured, regulated obligation for certain companies. Under the framework of the Companies Act, 2013 and the associated CSR Rules, a key requirement for organizations intending to receive CSR funds is the mandatory registration through Form CSR-1. This blog serves as a detailed guide to understanding who needs to apply, why it’s essential, the legal framework, procedural details, documentation, and practical challenges in obtaining CSR-1 registration.

Why CSR-1 Registration Is Crucial

Historically, companies had often reported difficulties in ascertaining track record and capacity of an implementation agency (AI)/NPO, to undertake CSR activities to their satisfaction. In order to aid companies, the government introduced the idea of registration of IAs with the Ministry of Corporate Affairs (MCA) so that there emerges an authentic and reliable list of implementation partners for companies to select from. Thus, to bring transparency and accountability, the MCA made it mandatory for all implementing agencies to register with the Central Government by filing Form CSR-1.

This step ensures that only verified entities receive CSR funds from eligible companies.

Without this registration, entities are not permitted to receive CSR funds from any company, regardless of their prior experience or track record. Hence, Form CSR-1 acts as a gate-keeping mechanism to prevent misuse and to streamline fund disbursal.

Legal Framework Governing CSR-1 Registration

The requirement for CSR-1 registration stems from the following:

• Section 135 of the Companies Act, 2013 – This section mandates eligible companies to spend a portion of their profits on CSR activities.

• Rule 4(1) and Rule 4(2) of the Companies (Corporate Social Responsibility Policy) Amendment Rules, 2021 – These rules specify that entities intending to carry out CSR activities must register with the Central Government via eForm CSR-1, effective from April 1, 2021.

  
  

Who Needs to Apply for CSR-1 Registration

CSR-1 registration is mandatory for the following entities wishing to act as implementing agencies for CSR activities:

1. Section 8 Companies (not-for-profit companies registered under the Companies Act)

2. Registered Public Trusts

3. Registered Societies

4. Any entity established under an Act of Parliament or a State legislature

Out of the above, section 8 Companies/registered trusts/ registered societies (except the ones set by established by Central or State Government) should be registered under section 12A or sub clause (iv), (v),(vi) or (via) of section 10(23C) and section 80G of the Income-tax Act, 1961. Further, all entities must have valid PAN.   

Contents of Form CSR-1

Form CSR-1 is a simple electronic form, but it requires precision. Key details to be filled include:

• Nature of the entity

• Date of registration/incorporation

• PAN of the entity

• Details of registration under relevant Acts (Trust Act, Societies Registration Act, Companies Act)

• Names and details of Board Members/Trustees

• DSC (Digital Signature Certificate) of the authorized person

• Certification by a practising professional (Chartered Accountant, Company Secretary, or Cost Accountant)

  
  

Documents Required for CSR-1

To file the CSR-1 Form, the following documents are generally needed:

1. PAN Card of the entity

2. Registration Certificate (under applicable law)

3. Details of Governing Body Members

4. Digital Signature Certificate (DSC) of the authorized representative

5. Professional certification by a practicing CA, CS, or CMA

Process of Filing CSR-1

1. Preparation of Documents: Ensure all statutory documents are updated and ready.

2. Login to MCA Portal: Access the Ministry of Corporate Affairs website.

3. Download CSR-1 eForm: Available under eForms section.

4. Fill in Details: Carefully enter all required information as discussed above.

5. Attach Documents and Sign: Upload the supporting documents and affix DSC.

6. Professional Certification: The form must be certified by a practicing professional.

7. Submission: Submit the form through the MCA portal.

Once submitted, the MCA verifies the information. Upon successful verification, a unique CSR Registration Number is issued.

Allotment of CSR Registration Number & Its Importance

After successful filing and approval of Form CSR-1, the MCA allots a unique CSR Registration Number to the organization. This number:

• Acts as an identifier for the implementing agency

• Must be quoted by companies when reporting CSR expenditures

• Is essential for tracking fund utilization and CSR reporting in annual reporting

This number essentially legitimizes the agency’s capacity to receive and execute CSR-funded projects.

Common Challenges in CSR-1 Registration and How to Overcome Them

While the process seems straightforward, entities may face certain hurdles:

1. Document Readiness: Incomplete or outdated documents can lead to rejection.

2. Digital Signature Issues: Ensure the DSC is valid and properly installed.

3. Lack of Professional Assistance: Errors in the form or certification may delay approval. It is advisable to consult an experienced professional for form preparation and certification.

4. Understanding MCA Portal: The portal can be technical for first-timers. Training staff or using consultants can help navigate the process smoothly.

   
   

How Can ThinkCap Advisors Help

Often, implementing agencies apply for CSR registration number without understanding the requirements of CSR law. CSR regulations impose certain restrictions on acceptance of funds by Implementing agencies. Since the allotment of CSR registration number is automatic, IAs often apply and receive without understanding their eligibility to receive funds under CSR regulations. Simply put, having a CSR registration number does not automatically allow a non-profit to receive funds. At ThinkCap, as a CSR consulting firm, we provide strategic guidance to non-profits to help them understand the nuances of CSR law so that they become eligible to receive CSR funds.

Conclusion

CSR-1 registration is more than a regulatory formality—it is a validation of an organization’s legitimacy, and readiness to partner with corporates in creating social impact. With increasing scrutiny and evolving CSR norms, having a CSR Registration Number is now indispensable for IAs in India.

As a CSR consulting services & social sector consulting firm, we advise clients to be meticulous with documentation, understand the legal framework, and seek the right professional support to ease the process and open doors to substantial funding opportunities. In an era where corporate goodwill is deeply tied to social contribution, CSR-1 registration is your non-profit’s ticket to meaningful collaborations and sustained impact.