How to File Form CSR-2 with the MCA in India

Form CSR-2 filing with the MCA is the annual step where a company covered by Section 135 of the Companies Act, 2013 reports its Corporate Social Responsibility to the Registrar of Companies through a prescribed e-Form. You file it on the MCA V3 portal after the relevant Form AOC-4, using that filing's Service Request Number to link the report to the correct financial year. The form runs to 11 pages and captures the CSR obligation, the amount spent, unspent amounts, ongoing projects, committee details, and any capital asset created through CSR. The government fee is ₹200 for a company with share capital, and the due date is fixed each year by MCA notification, set at 31 December 2025 for the FY 2024-25 cycle. This guide explains who must file, the exact fields, the standalone filing route on V3, the due dates, certification, the Section 135(7) penalty exposure, and the errors that trigger resubmission.

What Is Form CSR-2 and Why It Exists

Form CSR-2 is the e-Form in which a company covered by Section 135 of the Companies Act, 2013 furnishes a report on its Corporate Social Responsibility for a financial year to the Registrar of Companies. It was introduced by the Companies (Accounts) Amendment Rules, 2022 to give CSR disclosure a single, structured, machine-readable filing rather than a free-text note in the Board Report.

Before February 2022, there was no dedicated form for CSR reporting. Section 135 required companies to annex CSR details to the Board Report and publish them on the company website, but that information sat in unstructured documents the Registrar could not easily aggregate. By inserting Rule 12(1B), the Ministry of Corporate Affairs created Form CSR-2 so every covered company reports the same data points in the same format, from the obligation amount down to project-level spend. This gives the regulator a comparable, year-on-year view of how corporate India meets its 2% commitment.

The form also tightened the link between CSR reporting and the audited accounts. CSR-2 is filed against the financial statements submitted in Form AOC-4, so the spend reported in CSR-2 must reconcile with the numbers in the accounts and the Board Report. This structure makes it far harder to overstate CSR activity or to leave a shortfall undisclosed. In the filings we handle, companies that treat CSR-2 as a simple extract of an already reconciled CSR working complete it quickly, while those that prepare the figures inside the form for the first time tend to hit validation errors and resubmissions.

Who Form CSR-2 Is For

This guide is for finance teams, directors, and founders of companies that have crossed a CSR threshold and now have to file CSR-2 for the year. It assumes the underlying CSR compliance work, the committee, the policy, the spend, and the unspent-fund transfers, is broadly in place, and focuses on getting the report filed correctly on the MCA V3 portal. For the full Section 135 compliance lifecycle, our CSR compliance guide under Section 135 covers committee formation, policy, and the annual action plan in depth.

Who Must File Form CSR-2

CSR-2 applies to exactly the same companies that Section 135 applies to. A company is covered if, in the immediately preceding financial year, it crossed any one of three thresholds. There is no need to meet all three; a single trigger brings the company within CSR and, with it, the duty to file CSR-2 for the year.

The thresholds are tested afresh each year against the latest audited financial statements, so a company can move in and out of the CSR net as its size changes. A company that crosses a limit in one year is covered for the following year, including the duty to constitute a CSR Committee, spend 2% of average net profits, and file CSR-2. If a covered company later falls below all three limits for three consecutive financial years, it ceases to be covered until it crosses a threshold again. Until then, the CSR-2 filing obligation continues for every year the company is in scope.

Coverage is entity-specific. Private limited, public limited, and one person companies are all caught if they cross a threshold, as is a foreign company with a branch or project office in India that meets the limits on its India operations. What stays outside the net are non-company structures: Limited Liability Partnerships, partnership firms, sole proprietorships, and trusts do not file CSR-2, because Section 135 is a company-law obligation. A holding or subsidiary relationship does not transfer the duty; each company tests the thresholds on its own standalone numbers and files its own CSR-2.

From AOC-4 Addendum to a Standalone V3 Filing

How CSR-2 is filed has changed since it was introduced, and getting the current route right matters as much as the data. When Rule 12(1B) first came in, CSR-2 was furnished as an addendum to Form AOC-4, AOC-4 XBRL, or AOC-4 NBFC (Ind AS). The CSR report rode along with the financial statements as a linked attachment for the same year.

That changed with the MCA21 migration from the V2 to the V3 portal. As V2 filing was discontinued in mid-2025, the Ministry moved CSR-2 onto V3 as a separate web form. The Companies (Accounts) Amendment Rules, 2025 amended Rule 12(1B) to let companies file e-Form CSR-2 independently, after the relevant AOC-4 is filed, rather than strictly as an attachment to it. MCA also issued guidance, including a General Circular in June 2025, on how to file CSR-2 on V3 during the transition, including the use of a V2 AOC-4 SRN within a defined window. The practical effect for a filer today is a two-step sequence: file AOC-4, then file CSR-2 separately and quote the AOC-4 SRN.

This shift removes a long-standing pain point. Under the addendum model, a delay or error in AOC-4 could hold up the CSR report, and the linked attachment was awkward to revise. Filing CSR-2 as its own form gives it an independent SRN and a cleaner status trail on the V3 dashboard. Because the rules in this area have moved more than once, always confirm the exact filing mode and any transitional instructions for your specific year on mca.gov.in before you begin, as currently notified positions can differ from older guidance still circulating online.

The 11-Page Form: What CSR-2 Captures

Form CSR-2 is an 11-page form, and knowing its sections in advance lets you assemble the data once rather than hunting for figures field by field. The form is a structured mirror of the CSR annexure to the Board Report, so every number in it should already exist in your reconciled CSR working. The table below maps the main data blocks.

Key totals in the form auto-validate against each other, so the obligation, spend, surplus or shortfall, and transfers must reconcile to the rupee. This is by design: the regulator wants the spend reported in CSR-2 to tie back to the audited accounts referenced through the AOC-4 SRN. The single most useful preparation step is to finalise a CSR reconciliation statement, agreed with the auditors and the Board, before opening the form, so data entry becomes transcription rather than calculation.

The Net Profit and Obligation Block

The obligation block is where most numeric errors originate, because CSR net profit is not the same as accounting net profit. The 2% obligation is computed on the average net profit of the three immediately preceding financial years, with net profit calculated under Section 198 of the Companies Act, 2013. Section 198 strips out items such as profits from overseas branches and certain capital gains on the sale of undertakings, so the figure feeding the 2% can differ materially from the bottom line in the profit and loss account. Enter the three years, the average, and the resulting obligation exactly as worked in your Section 198 computation, and keep that working ready in case the figures are queried.

The Spend and Unspent Block

This block reports the prescribed 2% against the amount actually spent during the year, and then accounts for any difference. A surplus from a previous year, set off against the current obligation, is reported here, as is any shortfall. Where money was not spent, the form records the transfer of unspent amounts: to the Unspent CSR Account for ongoing projects, and to a Schedule VII fund for other unspent amounts. Administrative overheads, capped at 5% of total CSR expenditure for the year, and any impact assessment cost are reported within the spend, so they must be identified separately in your CSR ledger.

Step-by-Step: How to File Form CSR-2 on MCA V3

The full process runs across 10 steps, from confirming applicability to tracking the SRN to approval. With a reconciled CSR working in hand, most companies complete the data entry and submission within one working day, though approval and any resubmission can extend the calendar to a few days.

Before you start, confirm the previous step in the chain is done: the year's audited accounts are ready, AOC-4 is filed, and its SRN is recorded. Keep your Section 198 net profit working, the Board Report CSR annexure, agency CSR-1 numbers, and bank proof of any fund transfer open beside the form. Working from a single reconciliation statement, rather than assembling figures live, is what keeps the filing to one sitting.

Step 1: Confirm CSR Applicability for the Reporting Year

Open the audited financial statements and confirm the company crossed at least one threshold in the immediately preceding financial year: net worth of ₹500 crore or more, turnover of ₹1,000 crore or more, or net profit of ₹5 crore or more under Section 198. If a single threshold was met, Section 135 applies and CSR-2 is due for that year. Document which threshold was triggered, because that determination underpins the whole filing and should be retained with the compliance file.

Step 2: Reconcile CSR Spend, Unspent Amounts, and Projects

Build the reconciliation that the form will mirror. Compute the 2% obligation on the three-year average net profit, list spend project by project, separate ongoing projects from completed ones, and quantify any amount transferred to the Unspent CSR Account or a Schedule VII fund. Capture each implementing agency's CSR Registration Number and the details of any capital asset created. Agree this statement with the auditors and the Board so every figure entered later is already verified rather than estimated at the keyboard.

Step 3: File Form AOC-4 First

Because CSR-2 is anchored to the financial statements, file Form AOC-4, AOC-4 XBRL, or AOC-4 NBFC (Ind AS) for the same financial year before you touch CSR-2. On successful filing, the portal generates a Service Request Number (SRN); note it precisely. This SRN is the key that ties CSR-2 to the correct year's audited accounts, so an AOC-4 that is still pending or in resubmission will block a clean CSR-2 filing.

Step 4: Access Form CSR-2 on the MCA V3 Portal

Log in to the V3 portal at mca.gov.in with your registered credentials. After the V2 to V3 migration, CSR-2 is a standalone web form, so search for Form CSR-2 within the CSR filings rather than looking for an AOC-4 attachment. The form opens with the CIN, company name, and registered office pre-filled from MCA master data. Verify these details before entering anything, because a stale registered office or a mismatched CIN should be corrected at source first.

Step 5: Enter the SRN of AOC-4 and the Financial Year

In the opening section, enter the SRN of the AOC-4 filed for the reporting year and confirm the financial year of the CSR report. The form uses the SRN to bind the disclosure to the right accounts, so accuracy here is non-negotiable. Re-check the SRN character by character against the AOC-4 acknowledgement; a single wrong digit is one of the most common reasons a CSR-2 fails validation at submission.

Step 6: Complete the Net Profit and CSR Obligation Fields

Enter the net profit for each of the three preceding financial years, the average, and the prescribed 2% obligation, all from your Section 198 working. Then enter the amount actually spent during the year and any surplus carried from a prior year or shortfall for the current year. The form auto-validates these totals, so they must reconcile exactly with your CSR statement and the Board Report. If a validation error appears, the fix is almost always in your underlying numbers, not in the form.

Step 7: Disclose Committee, Projects, and Unspent Amounts

Record the CSR Committee composition and meetings, the Rule 9 website link where the CSR Policy and projects are published, and project-wise spend with locations. Enter ongoing project details, the amount moved to the Unspent CSR Account within 30 days of year end, and any amount transferred to a Schedule VII fund within 6 months. Where CSR created or acquired a capital asset, enter its nature, cost, address, pin code, and registered owner. Every entry should trace back to your reconciliation and supporting proof.

Step 8: Attach Supporting Documents

Attach the documents the form calls for in PDF, which can include the impact assessment report where a project required assessment, along with any optional supporting material. Keep each file within the portal's size limit and make sure the attached content matches the figures entered on the form. Inconsistency between an attachment and a field is a frequent trigger for a resubmission notice, so a quick cross-check before signing saves a round trip with the Registrar.

Step 9: Affix DSC, Certify, and Submit

Affix the Class 3 Digital Signature Certificate of an authorised director. Where certification is required, a practising Tax Professional or Compliance Professional signs digitally to confirm the CSR figures and disclosures. Run the validation check, clear any errors, and submit. Pay the government fee of ₹200 for a company with share capital through the MCA payment gateway; the fee can vary with authorised capital, and a company without share capital pays a separate flat fee under the Fees Rules.

Step 10: Track the SRN to Approval and Retain Records

On submission, the portal issues an SRN for the CSR-2 filing. Track it under My Applications on the V3 portal. CSR-2 is taken on file by the Registrar; if a resubmission notice is raised, correct the flagged fields within the time allowed and re-submit under the same SRN. Download the filed form and the acknowledgement, and store them with the Board Report and CSR ledger so the year's compliance is fully evidenced for any later inspection.

Pre-Filing Checklist for Form CSR-2

Because CSR-2 binds to the audited accounts and auto-validates several fields, the cleanest filings are the ones where every input is settled before the form is opened. Run through this checklist in order; each item maps to a field or a linkage the form will test.

1. Threshold confirmed: verify the company crossed net worth ₹500 crore, turnover ₹1,000 crore, or net profit ₹5 crore in the immediately preceding financial year.
2. Section 198 working ready: compute net profit for the three preceding years, the average, and the 2% obligation, agreed with the auditors.
3. AOC-4 filed: file Form AOC-4 for the year first and record its SRN exactly from the acknowledgement.
4. Spend reconciled: tie project-wise spend, administrative overheads, and impact assessment cost to the CSR ledger and the Board Report annexure.
5. Transfers evidenced: confirm the Unspent CSR Account transfer within 30 days, and any Schedule VII fund transfer within 6 months, with bank proof.
6. Agency numbers collected: gather the CSR Registration Number from each implementing agency's Form CSR-1.
7. DSC and certification arranged: ensure an authorised director's Class 3 DSC and the required professional certification are in place before submission.

Form CSR-2 Due Dates: A Moving Target

The CSR-2 due date is not a fixed calendar date; it is set each year by an MCA notification and has shifted repeatedly through extensions. The constant is the link to AOC-4: CSR-2 follows the financial statements for the same year. The table below traces the notified positions so far, which is the clearest way to see the pattern.

Two practical lessons follow from this history. First, do not rely on a date you remember from a prior year; CSR-2 deadlines have been extended more than once, and the gap between cycles has not been uniform. Second, because the form is now filed after AOC-4 rather than bundled with it, plan the two filings in sequence with a buffer between them. For the current cycle, treat the AOC-4 timeline as the anchor and confirm the exact CSR-2 date, as currently notified, on mca.gov.in. Where a deadline is genuinely unclear, file early against the AOC-4 date rather than wait for an extension that may not arrive.

Fees and Costs of Filing CSR-2

The government fee for CSR-2 is modest; the real cost of CSR sits in the spend itself, not the report. CSR-2 attracts the standard MCA filing fee for documents under Section 403 and the Companies (Registration Offices and Fees) Rules, 2014. For a company having a share capital, the common fee is ₹200, while a company without share capital pays a separate flat fee. Additional fees apply for delayed filing, scaling with the length of the delay.

The meaningful financial exposure is not the ₹200 fee but the consequences of getting the CSR position wrong. A late or defective CSR-2 adds fees and signals a compliance gap, while a genuine failure to spend or transfer CSR funds triggers the Section 135(7) penalty, which is far larger. Listed professional amounts, where a firm assists with the filing, are charges for the assistance and reconciliation work; the government fee is paid to the MCA at actuals. Seen against the size of the CSR obligation itself, careful, on-time filing is inexpensive insurance.

Penalties: Late Filing and Section 135(7)

It helps to separate two different exposures that people often blur. One is the filing default, missing or delaying CSR-2 itself. The other is the spend-and-transfer default, failing to spend the 2% or to move unspent money to the right account, which is what Section 135(7) targets directly.

A late or non-filed CSR-2 is a reporting default. It attracts additional fees that grow with the delay, and persistent non-filing can draw penalties on the company and its officers under the general default provisions of the Companies Act. The form being a few days late is rarely catastrophic on its own, but it is a visible gap, and it compounds if the underlying CSR position is also weak.

The heavier consequence lives in Section 135(7), which penalises a failure to transfer unspent CSR amounts. If a company does not transfer the unspent amount to a Schedule VII fund or the Unspent CSR Account as required, the company is liable to a penalty of twice the amount required to be transferred, or ₹1 crore, whichever is less. Every officer in default is liable to one-tenth of that amount, or ₹2 lakh, whichever is less. The penalty was made civil rather than criminal by the Companies (Amendment) Act, 2020, but it remains substantial, and CSR-2 is the document that puts any shortfall on the record.

A Worked Example: One CSR-2 Filing

A concrete example shows how the pieces fit. Take a company reporting CSR-2 for FY 2024-25. Its net profit under Section 198 for the three preceding years was ₹6 crore, ₹9 crore, and ₹12 crore, giving an average of ₹9 crore. The 2% obligation is therefore ₹18 lakh. During the year the company spent ₹13 lakh through a registered implementing agency on education and healthcare projects under Schedule VII, leaving a shortfall to account for.

Of the ₹5 lakh not spent, ₹3 lakh related to an ongoing project running across two years. That ₹3 lakh was transferred to the company's Unspent CSR Account in a scheduled bank within 30 days of the year end, to be spent within three financial years. The remaining ₹2 lakh did not relate to any ongoing project, so it was transferred to a Schedule VII fund within 6 months of year end. CSR-2 reports the ₹18 lakh obligation, the ₹13 lakh spent, the ₹3 lakh in the Unspent CSR Account, and the ₹2 lakh fund transfer, with the implementing agency's CSR Registration Number against the project spend.

Two points stand out. First, because both transfers were made correctly and on time, the company faces no Section 135(7) penalty despite spending below the obligation in the year; the law accepts a disclosed, properly parked shortfall. Second, the figures in CSR-2, ₹18 lakh, ₹13 lakh, ₹3 lakh, and ₹2 lakh, must match the Board Report CSR annexure and the audited accounts to the rupee. Had the company simply reported ₹18 lakh as spent to avoid showing a gap, the mismatch with the accounts would have invited a notice. The honest, reconciled filing is the safe one.

Common Errors and How to Resolve Them

A handful of issues account for most CSR-2 problems, and each has a clear fix once the underlying rule is understood.

Wrong or Missing AOC-4 SRN

The most common failure is an incorrect AOC-4 SRN, or attempting CSR-2 before AOC-4 is filed. Because CSR-2 binds to the financial statements through that SRN, it cannot validate without the right one. File AOC-4 first, copy the SRN exactly from the acknowledgement, and paste it into CSR-2. If AOC-4 is still in resubmission, clear that first, since its SRN status affects the linkage.

Figures That Do Not Reconcile

Validation errors on the obligation or spend almost always mean the numbers in the form do not match the audited accounts or the Board Report. The fix is in the source data, not the form: confirm the Section 198 net profit working, the average, and the spend ledger, then re-enter. A reconciliation statement agreed with the auditors before filing prevents most of these errors entirely.

Resubmission Notice From the Registrar

Where the Registrar seeks a resubmission, the notice specifies the fields or attachments to correct. Address each point precisely, ensure attachments match the entered figures, and re-file under the same SRN within the time allowed. Treat the notice as a checklist; partial fixes lead to a second notice and further delay.

Treating CSR-2 as Optional in a Shortfall Year

Some companies wrongly believe that if they did not spend the full 2%, filing CSR-2 can wait. CSR-2 is a reporting obligation regardless of spend, and a shortfall year is exactly when the disclosure and the unspent-fund transfers matter most. File on time, disclose the shortfall, and evidence the transfer to the Unspent CSR Account or a Schedule VII fund.

How CSR-2 Fits the Wider Compliance Calendar

CSR-2 does not stand alone; it is one entry in a company's annual filing calendar that runs off the audited accounts and the AGM. Sequencing it correctly avoids a last-minute scramble and keeps the linked filings consistent.

For a covered company, the cleanest approach is to plan CSR-2 as part of the post-audit, post-AGM filing run rather than as an afterthought. The ROC annual filing cycle, the annual return filing process, and CSR-2 all draw on the same audited numbers, so reconciling once and filing in sequence is far more efficient than treating each form in isolation. Companies that also have frequent resolutions or structural changes should fold event-based ROC compliance into the same calendar so nothing is missed.

Keeping CSR-2 Consistent Year on Year

Because CSR-2 is now an annual fixture, consistency across years is its own discipline. Carry forward the prior year's reconciliation format, track ongoing project balances in the Unspent CSR Account from one CSR-2 to the next, and ensure surpluses set off against a later year's obligation are reported correctly. A company that maintains a rolling CSR tracker, rather than rebuilding the numbers each year, files CSR-2 faster and presents a coherent multi-year record that withstands scrutiny. For broader corporate housekeeping, our private limited company compliance support keeps the annual obligations aligned.

Related Resources

• CSR Compliance Guide Under Section 135: the full Section 135 lifecycle, committee, policy, and spend.
• How to Apply for CSR Funding as an NGO: the implementing-agency side, including CSR-1 registration.
• How to File the Annual Return: the related annual ROC filing that runs off the same accounts.
• ROC Annual Filing: assistance with AOC-4, MGT-7, and the annual filing run.
• Corporate Compliance Services: end-to-end assistance for company-law filings with the MCA.

Summary

Filing Form CSR-2 with the MCA is the annual step that puts a covered company's Corporate Social Responsibility on the public record under Section 135 and Rule 12(1B). Confirm applicability against the net worth, turnover, and net profit thresholds, reconcile the 2% obligation and spend, file Form AOC-4 first, then file CSR-2 as a standalone form on the V3 portal quoting the AOC-4 SRN. The government fee is ₹200 for a company with share capital, the due date is fixed each year by MCA notification and was 31 December 2025 for FY 2024-25, and the heavier Section 135(7) penalty attaches to unspent-fund defaults rather than the filing itself. Reconcile the figures to the audited accounts, disclose any shortfall honestly with the correct transfer, and confirm the current due date and filing mode on mca.gov.in before you begin.