If your NGO will carry out CSR projects on behalf of a company, it must be registered with the Central Government on Form CSR-1 first. The requirement has applied since 1 April 2021 and comes from rule 4(2) of the Companies (Corporate Social Responsibility Policy) Rules, 2014. Without a CSR registration number, a company cannot route its CSR spending through you, however good your work is.
CSR-1 does not give an NGO money, and it is not a certificate of quality. It is a registration on the MCA portal that tells companies and the Registrar that you are a permitted implementing agency. If you would rather have the form handled, our CSR-1 filing service prepares it, arranges the signatures and files it on MCA.
Who has to file Form CSR-1
The 2021 amendment to the CSR Rules lets a company carry out its CSR work itself or through one of four kinds of entity. Rule 4(2)(a) then says every entity covered by that list that intends to undertake any CSR activity must register by filing CSR-1 electronically with the Registrar.
| Rule 4(1) | Type of entity | Extra condition |
|---|---|---|
| (a) | Section 8 company, registered public trust or registered society, set up by the company alone or with other companies | Must hold 12A and 80G registration |
| (b) | Section 8 company, registered trust or registered society set up by the Central or a State Government | None stated |
| (c) | Any entity established under an Act of Parliament or a State legislature | None stated |
| (d) | Section 8 company, registered public trust or registered society set up by others | Must hold 12A and 80G registration and have an established track record of at least three years in undertaking similar activities |
Most independent NGOs fall under row (d). That is where the three-year test bites.
Who does not need it
- The company itself, when it runs CSR projects directly with its own staff.
- Projects approved before 1 April 2021. The rule’s proviso says the registration requirement does not affect CSR projects or programmes approved before that date.
- An NGO that only takes ordinary donations from companies, outside their CSR spend. CSR-1 is about acting as an implementing agency for CSR.
Reading the eligibility conditions carefully
The three-year track record
The rule asks for a track record “in undertaking similar activities”, not just three years since incorporation or registration. A society registered in 2021 that only began its health programme last year may meet the age test on paper but struggle to show three years of similar work. Keep annual reports, photographs, beneficiary records and audited accounts that tie each year to the activity you will propose to companies.
The track record condition does not appear in rows (a), (b) and (c). A foundation set up by a company for its own CSR, for example, does not need to wait three years, though it still needs its income tax registrations.
12A and 80G after the Income-tax Act, 2025
The CSR Rules still refer to registration “under section 12A and 80G of the Income Tax Act, 1961”. From 1 April 2026 that Act has been replaced by the Income-tax Act, 2025, where registration of a non-profit sits in section 332 and donor approval in section 354. Check the current rule wording with your adviser. In practice, an NGO should hold both the registration and the donor approval under whichever Act was in force when they were granted, and keep the orders ready to upload.
How the filing works on MCA
- Get the signatory’s digital signature ready. The form has to be signed digitally by the right person for your structure (see below).
- Fill in the entity details. Nature of the entity, whether it was set up by a company, CIN or registration number, date of incorporation, address, email (verified by OTP) and PAN.
- Add the people in charge. Directors, trustees, chairperson, CEO or secretary, with DIN or PAN.
- Attach the documents. The form in the 2021 notification asks for a copy of the certificate of registration and a copy of the entity’s PAN. Keep the 12A and 80G orders and the board or trustee resolution authorising the signatory at hand as well.
- Get professional certification. Rule 4(2)(b) requires the form to be verified digitally by a chartered accountant, company secretary or cost accountant in practice.
- Submit. Under rule 4(2)(c), a unique CSR registration number is generated by the system on submission.
| Your structure | Who signs Form CSR-1 |
|---|---|
| Section 8 company | One director |
| Registered public trust | One of the trustees or the CEO |
| Registered society | Chairperson, CEO or secretary |
| Entity under an Act of Parliament or State legislature | Authorised representative |
What companies will ask for after you register
The CSR registration number goes into the company’s annual report on CSR, project by project. So expect the company’s CSR team to ask for it, along with your 12A and 80G orders, audited accounts and a project proposal. CSR spending is an obligation under section 135 of the Companies Act, 2013, and rule 4(5) of the CSR Rules requires the company’s board to satisfy itself that the funds were used as approved, so utilisation certificates and progress reports are part of the relationship, not an extra.
Frequently asked questions
Our trust is two years old. Can we file CSR-1 now?
If you were set up by others (row d), the rule needs a three-year track record in similar activities, so wait until you can show it. The other rows do not carry that condition.
Do we need CSR-1 to receive a donation from a company?
Only if the company is spending it as CSR through you as an implementing agency. A general donation outside CSR does not depend on CSR-1.
Can a private trust file CSR-1?
The rule refers to registered public trusts, so a private family trust does not fit the categories.
Complianto (complianto.in), operated by Mentorcorp Private Limited, is a private consultancy and is not affiliated with any government body. We do not issue official documents. We charge a professional fee for application assistance and advisory services. Applicants can apply directly to the government without our fees via the official portals: MCA (mca.gov.in), Income Tax (incometax.gov.in), GST (gst.gov.in), MSME (udyamregistration.gov.in), FSSAI (foscos.fssai.gov.in), Startup India (startupindia.gov.in), and IP India (ipindia.gov.in).
This article is general information, not legal or tax advice.
