New CSR-1 E-Form to tighten CSR Compliance

New CSR-1 E-Form to tighten CSR Compliance

ACS Tejal Jayant Waje
ACS Tejal Jayant Waje

With effect from 1st April 2021, CSR-1 registration was made mandatory by the Ministry of Corporate Affairs (MCA) for various entities (e.g., trust, society or Section 8 company) seeking to implement CSR projects funded by companies mandated under Section 135 of the Indian Companies Act 2013 to carry out CSR activities. The Companies (Corporate Social Responsibility Policy) Amendment Rules, 2025 (which came into effect from 14th July 2025) have now substituted the existing e-form CSR-1.

The MCA has introduced a new web-based CSR‑1 e‑Form, effective July 14, 2025, under Notification G.S.R. 452(E) dated July 7, 2025. This replaces the old PDF-based form and significantly enhances compliance for entities implementing CSR initiatives. This move brings greater transparency and accountability in corporate social responsibility (CSR) spending across India.

A Refreshed Approach to CSR Entity Registration

The new e-form requires the entity applying for registration as a ‘CSR implementing agency’ to disclose whether it is:

  1. Company established under Section 8, exempted under sub-clauses (iv), (v), (vi) or (via) of clause (23C) of section 10 and approved under section 80G of the Income Tax Act, 1961 or;
  2. Company established under Section 8, registered under Section 12A and approved under Section 80G of the Income Tax Act, 1961 or;
  3. Registered public trust, exempted under sub-clauses (iv), (v), (vi) or (via) of clause (23C) of section 10 and approved under section 80G of the Income Tax Act, 1961 or;
  4. Registered Public trust, registered under section 12A and approved under section 80G of the Income Tax Act, 1961 or;
  5. Registered society, exempted under sub-clauses (iv), (v), (vi) or (via) of clause (23C) of section 10 and approved under section 80G of the Income Tax Act, 1961 or;
  6. Registered society, registered under section 12A and approved under section 80G of the Income Tax Act, 1961 or;
  7. Company established under section 8 or registered Trust or registered Society established by the Central Government or State Government or;
  8. Entity established under an Act of Parliament or State Legislature or;
  9. Whether the Entity is established by any company or group of companies. If yes, then provide the details of such company or companies with details of Company Identification Number (CIN) and if not to disclose whether the entity has an established track record of three years in undertaking similar activities.

In short, the above are the different types of entities eligible for CSR-1 registration with MHA as ‘CSR implementing agencies.’

The revised form captures a wide array of entity-specific information, apart from the Nature and type of entity: 

1. Details on whether it is established by a company or group of companies

2. A track record of at least three years (if not company-established)

3. Date of incorporation and registered address

4. PAN and email authentication via OTP

5. Names and identification of directors, trustees, or authorized representatives

This detailed information helps to ensure that entities undertaking CSR activities meet legal and ethical standards and have a verifiable history of such work.

Strengthened Accountability Through Digital Signatures and Certification

One of the major additions is the enhanced declaration and verification protocol. The form must be digitally signed by an authorized person depending on the type of entity—such as a director, trustee, CEO, or representative. Further, the form must be certified by a practicing professional—a chartered accountant, cost accountant, or company secretary—who is accountable under Section 448 of the Companies Act, 2013, for any false certification.

This level of professional validation introduces greater accountability and reduces the risk of misuse of CSR funds.

Implications for Companies and Implementing Agencies

For companies, these changes emphasize the importance of due diligence when selecting implementing partners. Companies must ensure that entities they collaborate with are properly registered through the updated CSR-1 form.

For implementing agencies, this amendment signifies the need to streamline internal documentation, maintain legal registrations (like 80G and 12A), and ensure compliance readiness by July 14, 2025.

Organizations that are already registered for undertaking CSR activities with a valid Registration Number are not required to reapply or refile the form.  Interpretations from Legal Forums suggest that existing Unique Identification Numbers (UIN) remain valid.

The form is only applicable to new or unregistered implementing agencies seeking CSR registration. 

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