Form CSR-2 Filing Guide 2026: Applicability, Due Date & Penalty

CSR-2 Filing 2026: Applicability, Due Date and Penalty

A company can spend every rupee of its CSR budget correctly, document every project, and still end up facing a penalty, simply because the annual CSR report never got filed. Form CSR-2 exists precisely to close that gap between doing the CSR work and telling the Registrar of Companies about it in a standardised, project-level format the Ministry can actually aggregate.

Here's what the form covers, which companies fall within its scope, how it sequences against AOC-4, and where the confusion with CSR-1 usually creeps in.

What is Form CSR-2.

Form CSR-2 is the annual report on Corporate Social Responsibility that companies covered under Section 135(1) of the Companies Act, 2013 file with the Registrar of Companies. It was introduced through the Companies (Accounts) Amendment Rules, 2022, dated 29 October 2022, and sits under Rule 12(1B) of the Companies (Accounts) Rules, 2014.

Unlike the CSR narrative in the Board's Report, which reads more like a summary, CSR-2 captures the same information as structured, machine-readable data broken down by project. That distinction matters to the Ministry, since project-level data can be aggregated across thousands of companies in a way a free-text annexure never could.

Which companies must file CSR-2

Section 135(1) sets three thresholds, and crossing any single one in the immediately preceding financial year brings a company within scope. There's no need to meet all three at once.

Once a company crosses any of these, it has to spend at least 2% of its average net profit from the preceding three financial years on CSR, under Section 135(5), and that same company also becomes obligated to file CSR-2.

Do companies with zero CSR spend still need to file

Yes. A company that meets a Section 135 threshold has to file CSR-2 even in a year where it spent nothing on CSR. The form itself has fields for reporting a shortfall against the 2% obligation and the reasons behind it, so having nothing to report isn't the same as having nothing to file. Skipping the return on the assumption that zero spend means zero paperwork is one of the more common ways companies land in default.

CSR-1 versus CSR-2

These two forms get confused often enough that it's worth stating plainly: they're filed by different parties for entirely different reasons.

CSR-1 is what an NGO or trust files before it can legally receive CSR grants. The rules governing that side tightened under the Companies (Corporate Social Responsibility Policy) Amendment Rules, 2025, which made CSR-1 a fully web-based form requiring 12A/80G certificates, a documented three-year track record (unless the implementing agency was created by the company itself), audited accounts, and mandatory certification by a CA, CS, or CMA. Only agencies holding a registration number issued after that mid-2025 change can receive fresh funding, though older pre-2025 registrations remain valid until updated for new projects. This matters for the spending company too, since routing money to an agency without a current CSR-1 registration puts the company's own compliance at risk.

CSR-2, by contrast, is the spending company's own annual disclosure and doesn't involve the implementing agency's registration status directly, beyond the fact that project-level data in CSR-2 needs to line up with a properly registered recipient.

CSR-2 due date

CSR-2 follows AOC-4 rather than the AGM date directly, and it has to be filed separately after the financial statements are on record, not as an attachment to AOC-4. For FY 2024-25, the Ministry set the deadline at 31 December 2025, to be filed after the applicable AOC-4, AOC-4 XBRL, or AOC-4 NBFC (Ind AS) had already gone through.

That FY 2024-25 window has now closed. For FY 2025-26, no separate extension had been notified as of this writing, so the working assumption is that CSR-2 will again follow shortly after the company's AOC-4 filing, which itself falls within 30 days of the AGM. Companies should watch for a fresh MCA circular closer to the AOC-4 season later in 2026, since the Ministry has adjusted this deadline through separate notifications in more than one recent year.

A related point worth knowing: the MCA21 portal migration from V2 to V3 also affected CSR-2 filing mechanics. A June 2025 circular clarified how companies that had filed AOC-4 on the older V2 system could still complete their CSR-2 using that SRN during a defined transition window on V3, before the V2 platform was retired.

What information CSR-2 actually reports

The form moves from company-level financials down to individual project data:

• Net worth, turnover, and net profit for the financial year, along with the SRN of the AOC-4 already filed
• CSR Committee composition, the number of meetings held, and which directors attended
• The average net profit calculation and the resulting 2% obligation under Section 135(5)
• Project-wise details: name, the relevant Schedule VII item, location, duration, amount allocated, and amount actually spent
• Amounts transferred to the Unspent CSR Account or to a Schedule VII fund, along with reasons for any shortfall
• Whether any capital asset was created or acquired through CSR spending during the year

Penalty for not filing CSR-2

There's no CSR-specific penalty written into the CSR rules for a missed CSR-2 filing. Instead, it falls under the general penalty provision, Section 450 of the Companies Act, which is a separate and distinct consequence from what applies when a company simply fails to spend its CSR budget.

The important thing to understand is that these two penalties are independent of each other. A company that spends its entire CSR budget correctly but never files the CSR-2 return can still be penalised under Section 450, purely for the filing default, regardless of how clean its actual CSR spending was.

How to file CSR-2 on the MCA portal

1. File Form AOC-4, or the applicable XBRL or NBFC variant, for the financial year and note down the SRN it generates.
2. Log in to the MCA21 V3 portal and open the CSR-2 web form under the company's filings.
3. Enter the company identifiers along with the AOC-4 SRN, which the portal uses to link the CSR report to the already-filed accounts.
4. Complete the financial thresholds, CSR Committee details, and the 2% obligation calculation under Section 135(5).
5. Add each CSR project individually, with its Schedule VII item, location, allocation, and amount actually spent.
6. Affix the Digital Signature Certificate of an authorised director or officer and submit before the applicable deadline.

Common mistakes companies make with CSR-2

• Treating CSR-2 as the same form as CSR-1, when one is the implementing agency's registration and the other is the spending company's annual report
• Assuming the three Section 135 thresholds are cumulative, when meeting any single one triggers the obligation
• Skipping CSR-2 in a year of zero CSR spend, when the form still needs to be filed along with the reasons for the shortfall
• Attempting to file CSR-2 before AOC-4, when the AOC-4 SRN is a required field that can't be completed without it
• Confusing the Section 450 filing-default penalty with the Section 135(7) spending-default penalty, and only addressing one of them
• Routing CSR funds to an implementing agency whose CSR-1 registration lapsed or predates the 2025 tightening, without checking its current status

Frequently asked questions

Is CSR-2 the same as the CSR disclosure in the Board's Report?

No. The Board's Report covers CSR activities in narrative form, while CSR-2 is a separate, fully e-filed return on standardised fields, structured as project-level data the MCA can aggregate across companies.

Does a company with no profit have to file CSR-2?

Only if it crossed one of the three Section 135 thresholds in the preceding financial year. A genuine net loss, combined with net worth and turnover below the respective thresholds, keeps a company outside the obligation entirely.

Can CSR-2 be revised after it's submitted?

The MCA21 portal doesn't offer a routine revision option once CSR-2 is filed. Errors typically need professional review and, where the portal permits it, a fresh filing or correction, so accuracy on the first attempt, especially the AOC-4 SRN and spend figures, matters.

Is CSR-2 linked to AOC-4 every year?

Yes. It's filed separately but only after AOC-4, because the AOC-4 SRN is a mandatory field. There's no way to complete CSR-2 before the financial statements are on record.

Who signs Form CSR-2?

A director or authorised signatory signs it digitally using a valid Digital Signature Certificate. The web form itself doesn't mandate certification by a practising company secretary or chartered accountant, though a professional review before submission is a sensible precaution given the penalty exposure.