CSR-1 Registration: How a Section 8 Company Becomes Eligible for CSR Funds

For many NGOs, corporate social responsibility (CSR) funding is one of the biggest sources of grants. But a company can't simply hand its CSR money to any charity. The implementing agency has to be eligible under the CSR rules and registered with the Ministry of Corporate Affairs in Form CSR-1. This guide explains who can register, what's needed, and how a Section 8 company gets ready to receive CSR funds.

Why CSR-1 Matters

Since April 2021, every entity that carries out CSR activities on behalf of a company has to be registered with the MCA through Form CSR-1. On filing, the entity gets a unique CSR registration number. Companies check this number before releasing funds, and report it in their own CSR disclosures. Without it, a company can't count its spending through your NGO towards its CSR obligation.

Who Can Register

The entities that can act as CSR implementing agencies include:

• A Section 8 company, registered public trust or registered society that's registered under the income-tax provisions for charitable institutions (commonly known as 12A) and for donor deductions (80G), and has a track record of at least three years in similar activities.
• A Section 8 company, trust or society set up by a company, alone or with others, to carry out its CSR.
• Certain entities set up by the central or state government or under a law of Parliament or a state legislature.

For most independent NGOs, the first category applies, which means you need both 12A and 80G registration and a three-year track record before you can register.

What You Need

• The NGO's PAN and registration details, such as the certificate of incorporation and Section 8 licence.
• Its 12A and 80G registration details.
• Details of its directors, trustees or office bearers, with their PANs.
• A DSC of an authorised person to sign the form.
• Certification of the form by a practising chartered accountant, company secretary or cost accountant.

How to File

1. Check eligibility, especially the 12A and 80G registrations and the three-year track record.
2. Prepare the details and documents above.
3. Fill in Form CSR-1 on the MCA portal, sign it with the authorised person's DSC, and have it certified by a practising professional.
4. Submit the form. Once it's processed, the CSR registration number is generated.

There's no government fee for the form.

After Registration

Getting a CSR-1 number makes you eligible, but companies look for more before they fund a project:

• A clear project proposal with outcomes, budget and timelines.
• Audited financial statements and a track record of similar work.
• Strong governance, with a board, policies and proper books of account.
• The ability to provide utilisation certificates and progress reports.
• For larger projects, readiness for impact assessments.

Keep the details on your CSR-1 registration up to date, and keep 12A and 80G valid, since a lapse can affect your eligibility.

Common Mistakes

• Applying before getting 12A and 80G, or before the three-year track record.
• Mismatched names or PANs between the MCA, income tax and CSR records.
• Accepting CSR money without a written agreement setting out the project and reporting terms.
• Mixing CSR funds with other funds instead of tracking them separately.

Getting Help

Think Filing gets Section 8 companies, trusts and societies registered in Form CSR-1, keeps their tax registrations valid, and prepares the utilisation certificates companies ask for.

Sources

• Companies Act, 2013 and the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended.
• MCA guidance on Form CSR-1.