Corporate Social Responsibility, or CSR, is a statutory obligation under the Companies Act, 2013, specifically under Section 135. Every eligible company is required to spend a certain portion of its profits towards social development and disclose such activities annually. To strengthen transparency and monitoring, the Ministry of Corporate Affairs (MCA) introduced Form CSR-2, a dedicated reporting form that gathers granular data on CSR spending and implementation. This form supplements disclosures made in the board’s report and ensures that CSR compliance is centrally traceable through the MCA-21 portal.
With the Companies (Accounts) Amendment Rules, 2025, notified via GSR 318(E) dated 19 May 2025, the MCA has officially extended the due date for filing Form CSR-2 for the financial year 2023-24. The revised deadline is now 30 June 2025, moving three months ahead from the earlier deadline of 31 March 2025. This extension brings both relief and opportunity for companies, but also calls for proactive compliance management.
Background of CSR-2 Form Implementation
The Form CSR-2 was first introduced through the Companies (Accounts) Amendment Rules, 2022. This new form was designed to allow the MCA to collect detailed and standardized CSR data from companies across the country. Before this, CSR disclosures were primarily made in the board’s report and financial statements. However, those narrative disclosures often lacked uniformity, making it difficult for regulators and the public to analyze trends or detect non-compliance.
The CSR-2 form addresses this gap by requiring companies to electronically submit a comprehensive dataset, including details of projects undertaken, implementing agencies engaged, unspent CSR amounts, transfers to specified funds or escrow accounts, and impact assessments, if applicable. Over time, the CSR-2 has evolved, and each year the form is updated to reflect policy changes and to improve data quality.
Initially, the CSR-2 was filed separately from the financial statements. However, recent amendments require CSR-2 to be filed after the adoption of financial statements at the annual general meeting, thereby tying CSR data more closely with audited results. Companies are also required to file CSR-2 for each financial year for which CSR applicability exists, regardless of whether actual spending occurred.
Legal Amendment and Its Scope
The recent extension to the CSR-2 filing deadline arises from the Companies (Accounts) Amendment Rules, 2025. This amendment specifically modifies the fourth proviso to Rule 12(1B), which governs the due date for Form CSR-2. The extension grants eligible companies time until 30 June 2025 to submit their CSR-2 form for the financial year 2023-24. This amendment applies to companies to which the provisions of Section 135 are applicable for the specified financial year.
This change reflects the MCA’s understanding of operational challenges faced by companies during the CSR reporting cycle. Many companies align their CSR-2 data with audited financials, and the statutory audit process can often run into the first quarter of the next financial year. By extending the deadline by three months, the MCA ensures companies have sufficient time to finalize data, conduct internal checks, and generate accurate CSR disclosures.
Who Needs to File CSR-2
The requirement to file Form CSR-2 applies to companies falling under the ambit of Section 135 of the Companies Act, 2013. This includes every company having a net worth of at least ₹500 crore, turnover of ₹1,000 crore, or net profit of ₹5 crore during the immediately preceding financial year. If a company satisfies any of these conditions, it becomes subject to CSR requirements for the financial year and must file Form CSR-2.
Importantly, the obligation to file CSR-2 arises regardless of whether the company has incurred any CSR expenditure in that year. Companies with zero spending or ongoing projects are also required to disclose such information in the form. Even if a company was under CSR applicability only for a single year and does not meet the criteria in the subsequent year, it still must file the form for that applicable year.
In case a company has no CSR applicability in FY 2023-24, it is not required to file Form CSR-2 for that year. However, companies must assess this on a case-by-case basis and document the applicability decision through internal governance frameworks to establish defensible compliance trails.
Importance of the Extension
The extension of the CSR-2 deadline carries significant operational and strategic importance. Companies often struggle to synchronize CSR data with audited financial statements. Since CSR disclosures in the board’s report must align with entries in Form CSR-2, the extension gives additional time to finalize both sets of disclosures without a mismatch.
It also provides extra room for companies that are required to conduct impact assessments. According to the Companies (CSR Policy) Rules, 2014, as amended, companies with an average CSR obligation of ₹10 crore or more in the three preceding financial years are required to undertake impact assessments for projects of ₹1 crore or more. These assessments can take weeks or months and involve external agencies. The extended deadline allows completion of these assessments and inclusion of their findings in the CSR-2 form.
Moreover, the extension helps mitigate the risk of last-minute portal issues. The MCA-21 portal is known for congestion and technical slowdowns as filing deadlines approach. Companies often face difficulties uploading forms, running pre-scrutiny checks, or obtaining SRNs. Having an additional quarter allows companies to avoid this bottleneck and file well in advance.
Compliance and Risk Management Implications
Companies that fail to file CSR-2 within the stipulated timeframe may face penal consequences under the Companies Act, 2013. Non-compliance with CSR obligations, including reporting, can attract penalties for the company and its officers in default. While the MCA may allow condonation through Form GNL-1, such applications involve procedural delays and additional fees.
By shifting the due date, the MCA has indirectly reduced the volume of condonation applications that arise purely from data lag or reconciliation delays. The extension, therefore, re-promotess voluntary compliance and encourages companies to take ownership of their CSR disclosures.
From a governance perspective, the CSR-2 form, once filed, becomes a public document accessible to regulators and stakeholders. Any inconsistencies between this form and the disclosures in the board’s report or financial statements may raise red flags. Companies must therefore treat the form as an integral compliance output, not merely an administrative formality.
Data Preparation and Internal Coordination
To leverage the benefit of the extended deadline, companies must now focus on internal data preparation and coordination across departments. The CSR committee, finance team, and implementing agencies should collaboratively finalize project lists, expenditure breakups, and implementation details. These data points form the core of the CSR-2 disclosures.
Impact assessment reports, where applicable, must be procured and verified for accuracy. Details of transfers to the unspent CSR account or the designated Schedule VII funds also need to be captured. In case of unspent amounts, companies should keep evidence of escrow account creation or fund transfers ready, as these will be cross-verified during compliance reviews.
The directors’ report for FY 2023-24 must be aligned with CSR-2 data to avoid discrepancies. Since both are legally mandated disclosures, a mismatch can be construed as inadequate reporting. Early drafting and cross-verification of the directors’ report can help ensure consistency.
Updating Compliance Calendars and ERP Systems
With the CSR-2 deadline now pushed to 30 June 2025, companies should immediately update their compliance trackers and digital calendars to reflect the change. Many organizations rely on compliance software or ERP modules to generate filing reminders. If these systems still display the old 31 March 2025 deadline, it may lead to either premature filings or missed planning windows.
Company secretaries, legal officers, and compliance heads should ensure that updated timelines are communicated to relevant departments. This includes scheduling internal meetings for CSR-2 data review, portal readiness testing, and board-level approvals where necessary.
If companies use external service providers or consultants for CSR compliance or portal filings, they must inform them of the revised date to align service delivery schedules. Proper communication across the ecosystem reduces the risk of confusion or duplicate efforts.
Role of the Board and CSR Committee
The CSR committee plays a central role in drafting, reviewing, and approving CSR-2 data. Once internal data collection is complete, a consolidated draft of the form should be tabled in a CSR committee meeting. This helps establish a governance trail and allows committee members to raise any concerns or request clarifications.
Subsequently, the board of directors may be updated on the final CSR-2 draft and informed of the upcoming filing. While the board’s approval is not legally mandated for filing the form, noting the contents at a board meeting enhances transparency and evidences oversight.
Meeting minutes should reflect these discussions, as they can serve as supporting evidence in case of future regulatory inquiries. Companies may also retain internal audit reports or third-party validations of CSR-2 data as an added layer of compliance assurance.
MCA-21 Portal Preparedness
The MCA-21 portal periodically releases updated versions of e-forms, and companies are expected to use the latest version while filing. With the extended deadline, the MCA is likely to release a patched or updated version of the CSR-2 form specific to FY 2023-24. Companies must monitor the portal for notifications about the release.
Before final submission, companies should conduct a dry run of the CSR-2 form using the pre-scrutiny feature. This allows users to identify and fix errors in real time, thereby reducing the chance of rejections or invalid submissions. Running these checks early can prevent bottlenecks in the last week of June 2025.
In some cases, digital signature certificates (DSCs) used in filings may expire or face compatibility issues. Companies should ensure that authorized signatories renew their DSCs in advance to avoid submission delays due to technical failures.
Strategic Importance of Synchronizing CSR-2 with Audited Financials
A primary reason for extending the CSR-2 deadline is the alignment of CSR disclosures with the company’s audited financial statements. CSR spending is usually accounted for as part of the annual expenditure and shown either as a charge to the profit and loss account or as a liability if unspent. To avoid inconsistencies, companies need to reconcile CSR-related amounts appearing in the financials with those declared in CSR-2.
For instance, the amount shown as spent on various CSR projects must match what is reflected in the directors’ report, financial statement notes, and CSR-2. Any discrepancy may indicate weak internal controls or misstatements and attract regulatory scrutiny. Some companies also allocate overheads or administration costs to CSR activities, and these allocations must be properly explained in all reports. The extra time granted by the MCA allows companies to double-check these figures after final audit closure.
Moreover, many companies finalize their audits closer to the deadline for CSR-2 filing. Under the previous deadline of 31 March 2025, some companies were compelled to submit estimates or unaudited figures. This raises the risks of restatements or reporting errors. The extended deadline of 30 June 2025 ensures that CSR-2 filings can be based on audited numbers, promoting higher integrity and confidence in the data.
Impact Assessment Requirements and Related Timelines
Under Rule 8(3)(a) of the Companies (CSR Policy) Rules, companies with an average CSR obligation of ₹10 crore or more in the three immediately preceding financial years must conduct impact assessments of certain CSR projects. Specifically, projects with outlays of ₹1 crore or more and that have been completed at least one year before the impact assessment must be evaluated by an independent agency.
Preparing and completing such assessments is a time-intensive process involving the identification of suitable third-party evaluators, gathering of data from field sites, designing evaluation parameters, and compiling findings. The three-month extension in the CSR-2 filing deadline provides much-needed flexibility to companies to complete these studies properly and include their summaries in the form.
In practical terms, companies should begin the assessment process early in the financial year to ensure timely completion. They should also maintain communication with implementing partners, especially when third-party entities are responsible for CSR project delivery. Evaluation agencies must be briefed on the project objectives, beneficiary records, fund flow structures, and desired impact metrics. The findings of these assessments become part of the company’s long-term CSR narrative and feed into policy planning for future years.
Impact assessment is not just a compliance burden but a strategic opportunity. It helps companies measure the effectiveness of their CSR programs, gather community feedback, and refine future interventions. With the filing deadline now falling three months later, companies should leverage the time to commission high-quality impact studies and strengthen their CSR governance systems.
Reducing Compliance Stress and Penalty Exposure
The MCA’s decision to extend the filing deadline reflects a larger policy trend toward facilitating ease of doing business and promoting timely voluntary compliance. One of the indirect benefits of the extension is the reduced exposure to late fees and penalties under the Companies Act. Delayed filing of CSR-2 would otherwise necessitate a condonation application under Section 460, filed via Form GNL-1, accompanied by additional documentation and a fee.
Such condonation processes are time-consuming and often subject to discretionary approval. Companies unable to meet the original deadline due to legitimate delays in data collection or audit reconciliation would be at risk of penal consequences. By shifting the due date to 30 June 2025, the MCA has acknowledged these operational realities and given companies a cushion to avoid legal non-compliance.
In addition, compliance departments and company secretaries now have greater bandwidth to focus on form accuracy, as opposed to simply rushing for timely submission. By reducing procedural anxiety, the extension encourages deeper data scrutiny, improved documentation, and holistic compliance strategies. Companies can now run mock filings, conduct pre-scrutiny tests, and ensure their filing history remains clean and penalty-free.
Strengthening Documentation for CSR Governance Trail
One of the more nuanced outcomes of the CSR-2 filing process is the requirement to build and retain documentation to support disclosures made in the form. Since CSR-2 is now a centrally filed document, it may be reviewed not just by the MCA but also by statutory auditors, tax authorities, or civil society watchdogs.
For example, disclosures related to implementing agencies must be backed by copies of registration certificates, trust deeds, or section 8 company approvals under CSR norms. Transfer of unspent amounts must be evidenced through bank statements showing the creation of escrow accounts or deposit into Schedule VII funds. Similarly, in-kind contributions must be valued and disclosed accurately based on third-party valuation or accounting records.
CSR committees and boards must approve CSR policies and implementation plans, and meeting minutes reflecting these approvals must be maintained. Decisions to alter the CSR program during the year, such as withdrawing funds from a project or reallocating budget, must also be documented. These governance trails are critical in case of audits or enforcement action.
The extension to 30 June 2025 gives companies more time to compile this documentation. Legal teams can create compliance files with board resolutions, budget approvals, committee minutes, auditor confirmations, impact assessment reports, and financial reconciliations. These documents may not be submitted along with the form,, but must be available for inspection if required by regulators.
MCA’s Role in Portal Enhancement and Version Control
With each financial year, the MCA typically releases a revised version of the CSR-2 e-form, reflecting changes in statutory provisions or technical enhancements. For FY 2023-24, companies should monitor announcements from the MCA regarding the release of the applicable form version. Once released, the new CSR-2 version must be downloaded and used for filing. Older versions are generally disabled for current-year filings.
The MCA-21 portal is the digital interface through which CSR-2 must be filed. This portal incorporates several validation and pre-scrutiny rules, including mandatory field checks, logical validations, digital signature verification, and automatic calculation functions. Companies must ensure that data is entered in the format prescribed, failing which the form will not be accepted.
With the extended deadline, companies should plan internal testing and dry runs of the CSR-2 form well before the last week of June 2025. Running pre-scrutiny checks on the portal allows users to identify incomplete fields, calculation errors, or DSC compatibility issues. Many companies maintain test environments to prepare draft forms before official submission.
Companies should also assign portal access rights to the appropriate signatories and verify that their DSCs are valid for the period in question. Expired or revoked DSCs may delay submission. Keeping multiple DSCs ready and updating MCA login credentials can further streamline the filing process.
Preparing the Directors’ Report in Line with CSR-2
The directors’ report for FY 2023-24 plays a key role in setting the context for CSR activities and must be aligned with the disclosures made in Form CSR-2. While the board’s report uses a narrative style and covers qualitative aspects of CSR, Form CSR-2 captures detailed quantitative and project-specific data. Any mismatch between the two could create credibility concerns.
For example, the amount spent on each project, reasons for underspending, and the nature of implementing agencies must be consistently described. If the directors’ report claims that all CSR obligations were discharged in full, but Form CSR-2 shows a shortfall or transfer to unspent funds, this could raise questions during audit or review.
Additionally, the annexure to the directors’ report must include the prescribed CSR format, as mandated by the Companies (CSR Policy) Rules. Companies should ensure that this annexure is finalized only after the CSR-2 draft is prepared. Both documents should be reviewed side-by-side to ensure data harmony.
The extension of the CSR-2 deadline until 30 June 2025 allows companies to complete this harmonization exercise thoroughly. Many companies now incorporate CSR disclosures into the annual report design, which is circulated to shareholders and uploaded on the company website. Ensuring alignment across the directors’ report, CSR-2, and the website version of CSR statements strengthens stakeholder trust.
Managing Group-Level CSR Compliance
Large corporate groups with multiple subsidiaries or associate companies often face challenges in managing CSR compliance across the group structure. While CSR obligations apply at the individual legal entity level, many groups adopt a central CSR strategy and then allocate budgets or projects across entities. This requires meticulous data segregation and reporting discipline.
Each eligible company must file its Form CSR-2, even if the parent company has coordinated the CSR activities on behalf of the group. In such cases, inter-company transactions must be disclosed with care, and double counting of expenditure must be avoided. Implementing agencies working with multiple group entities must provide separate impact reports and fund utilization certificates.
The extended filing period gives such conglomerates more time to sort out inter-entity allocations and confirm that each legal entity’s CSR spend is accurately reported. Shared service teams managing CSR functions for the group must allocate sufficient time for data gathering, report drafting, and internal sign-offs.
Companies should also ensure that they do not cross-subsidize CSR obligations across entities. Each company must independently meet its Section 135 requirement and not rely on excess spending by another group company to offset its shortfall. Auditors will specifically review such instances and may flag non-compliance if obligations are not met individually.
Training and Sensitization of Internal Teams
One often-overlooked benefit of the extended timeline is the opportunity it offers for internal training and sensitization. Filing Form CSR-2 requires coordinated inputs from various departments, including finance, legal, secretarial, CSR, and IT. Each team must understand the form’s structure, data fields, and reporting logic.
By organizing internal workshops or webinars, companies can train key personnel on updates to the CSR-2 form, changes in applicability, and steps for portal submission. Cross-functional training ensures that information flow is streamlined and dependencies are reduced. For instance, the finance team must know how CSR expenses are classified, while the secretarial team must be familiar with board and committee approvals required.
Additionally, implementing agencies or NGO partners may be engaged to provide documentation or certification needed for CSR-2 filing. Aligning their deliverables with internal timelines helps avoid last-minute delays. With the extended deadline, companies can take a more structured approach to such stakeholder coordination.
Handling Unspent CSR Amounts and Related Reporting
Under Section 135(5) and 135(6) of the Companies Act, if a company fails to spend its CSR obligation within the financial year, it must either transfer the unspent amount to a Schedule VII fund within six months from the end of the financial year or deposit the unspent amount for ongoing projects into a separate unspent CSR account within thirty days. These transfers are mandatory and must be evidenced through bank documents and financial entries.
Form CSR-2 requires companies to report the details of such unspent amounts, including the exact amount, the reason for not spending it, the destination of the transfer, and proof of action taken. This means companies must carefully track all instances of unspent funds and maintain documentation such as bank deposit slips, fund transfer confirmations, escrow account statements, and resolutions approving such transfers.
Where ongoing projects are involved, the company must ensure that the transferred amount remains earmarked and utilized within three financial years, failing which it must be moved to a Schedule VII fund. The CSR-2 form requires detailed reporting of the timeline, current status, and progress of such projects. With the deadline extended to 30 June 2025, companies now have more time to collect accurate and complete information about such transfers and include it in the CSR-2 form.
It is also important to note that any misstatement or false reporting of unspent amounts may lead to legal consequences under the Companies Act, including penalties for misreporting and director liability. Companies should involve their internal auditors or statutory auditors to verify the accuracy of these disclosures before submitting the form.
Monitoring MCA Clarifications and Circulars
During the filing season, the Ministry of Corporate Affairs may release clarifications, FAQs, or circulars to help companies navigate changes in the CSR-2 form or resolve common queries. These communications may address technical issues in the form, clarify interpretation of CSR applicability rules, or provide guidance on reporting of complex transactions.
Companies should actively monitor MCA updates and ensure that relevant circulars are circulated to legal, secretarial, and finance teams. These updates often contain critical information about filing timelines, acceptable documentation, or interpretation of the law. Ignoring such circulars may lead to avoidable errors or incorrect filings.
In some cases, the MCA may also clarify pits positionn on issues such as overlapping CSR projects across years, treatment of excess CSR spend from earlier years, or recognition of in-kind contributions. Staying updated with these positions helps companies align their CSR-2 disclosures with regulatory expectations and avoid non-compliance.
If a company is unsure about how to interpret a specific CSR rule about its projects, it may consider seeking a professional opinion or engaging legal counsel. The CSR-2 form has been designed with structured fields, and ambiguity in interpretation may not be accommodated in the form’s design. Therefore, a conservative and well-documented approach is always advisable.
Integrating CSR-2 with Annual Compliance Programs
Form CSR-2 filing should be seen as part of the broader annual compliance program of the company. It is closely linked to the filing of Form AOC-4, MGT-7, and DIR-8, all of which form part of the annual reporting framework. Aligning the CSR-2 filing with these filings ensures that all statutory submissions reflect the same data and narrative.
For example, if the board’s report mentions that a certain CSR project was implemented in partnership with a particular NGO, the same should appear in CSR-2 with matching expenditure and timelines. Any variation across forms may lead to audit remarks or even MCA inquiries in the future.
Companies that follow a structured compliance calendar should incorporate the new 30 June 2025 deadline for CSR-2 and align internal review processes accordingly. This includes scheduling CSR committee meetings, planning document finalization, and conducting form testing well before the deadline.
It is also beneficial to assign internal ownership for the CSR-2 filing. This may be led by the company secretary or the CSR head, with support from finance and legal. A cross-functional approach ensures accountability and promotes quality control over the submitted data.
Handling Third-Party Implementing Agencies
Many companies fulfill their CSR obligations through third-party implementing agencies, which include trusts, societies, and Section 8 companies. These agencies are responsible for executing projects on the ground and reporting fund utilization and project outcomes to the donor company.
Form CSR-2 requires detailed disclosures about each implementing agency used during the financial year. This includes registration number, legal structure, registration under Section 12A and 80G of the Income Tax Act, and whether the agency is registered on the CSR portal. Accurate data about these agencies must be gathered, verified, and uploaded into the form.
With the extended deadline, companies have more time to collect and validate this information. Agreements with implementing agencies should include clauses mandating timely data sharing and audit support. Agencies should also provide utilization certificates, project status reports, and impact data that support the company’s CSR-2 disclosures.
It is important to confirm whether the implementing agency has received funds during the financial year and whether these funds have been fully spent or carried forward. In case of multi-year projects, the implementing agency must report on milestones achieved during the relevant year, and companies must verify this information before filing.
Failing to report implementing agency details accurately may expose the company to scrutiny regarding the authenticity and effectiveness of its CSR program. The CSR-2 form is designed to capture full traceability of fund flow and project execution, and errors in this section may raise red flags.
Addressing Multi-Year and Ongoing Projects
Many CSR projects are not completed within a single financial year and instead span multiple years. In such cases, companies must identify the project as an ongoing project under the CSR Policy Rules. The amount earmarked for such projects must be transferred to the Unspent CSR Account within thirty days from the end of the financial year.
CSR-2 contains specific fields to report ongoing projects, including details of the financial commitment, actual expenditure during the year, and amount remaining in the unspent account. Companies must also disclose whether the project has been completed, is in progress, or has been discontinued.
The extended deadline to 30 June 2025 provides additional time to assess the status of these projects and update data accordingly. Project documentation, vendor agreements, milestone completion certificates, and beneficiary records should be reviewed to confirm current progress. This helps ensure that CSR-2 filings are both complete and accurate.
Companies must also ensure that unspent balances for ongoing projects are used within three years, failing which they must be transferred to a Schedule VII fund. CSR-2 serves as an annual checkpoint to track whether this three-year window is being adhered to.
Proper classification of a project as ongoing requires board approval and must be supported by a clear implementation schedule. Failure to meet these criteria may disqualify the project from being treated as ongoing, which can lead to penalties for unspent obligations.
Linking CSR-2 Data to Sustainability and ESG Reporting
Many companies are increasingly integrating CSR reporting with their broader Environmental, Social, and Governance (ESG) disclosures. Although CSR-2 is a statutory filing under the Companies Act, the data within it can serve as a base for ESG metrics, sustainability indices, and integrated reporting frameworks.
CSR expenditure, beneficiary numbers, impact stories, and project locations reported in CSR-2 can be aligned with disclosures made in business responsibility reports, sustainability reports, and integrated annual reports. For companies pursuing ESG ratings, the quality and integrity of CSR data become even more critical.
The extension until 30 June 2025 allows companies to use CSR-2 preparation as a foundation for enhanced non-financial reporting. Companies may choose to develop dashboards, impact maps, and sector-level analytics that go beyond the form’s requirements. These insights can help stakeholders, including investors and regulators, understand the company’s social footprint.
Moreover, aligning CSR-2 with ESG ensures that the company’s narrative remains consistent across regulatory and voluntary disclosures. If the company claims in its ESG report to have impacted a certain number of beneficiaries through its CSR programs, this should be supported by data in the CSR-2 form.
By using the extended timeline strategically, companies can create synergy between statutory compliance and reputation management, making CSR-2 more than just a regulatory obligation.
Preparing for Auditor Review and Statutory Compliance
Statutory auditors are increasingly reviewing CSR-2 filings as part of their audit scope. Although CSR-2 is not submitted to the auditor directly, the information in the form must align with audited financials and board disclosures. Auditors may examine CSR policies, approvals, expenditure records, and unspent amount transfers to ensure consistency.
Any inconsistency between the CSR-2 form and audit documentation may be flagged in the auditor’s report or CARO (Companies Auditor’s Report Order) disclosures. With the due date extended to 30 June 2025, companies should use this time to share draft CSR-2 forms with auditors and seek confirmation that figures reconcile with the final audit.
It is also prudent to document the auditor’s review and maintain internal audit trails that evidence compliance. Internal audit teams may conduct sample checks of CSR projects, verify fund flows, and evaluate alignment with board approvals. This adds a layer of comfort before final submission.
Some companies also prepare CSR compliance certificates signed by the company secretary or compliance officer to confirm the accuracy of CSR-2 data. While not mandatory, these certificates serve as internal controls and may be used during regulatory inspections.
Preparing for an auditor review is not a one-time exercise. It requires continuous collaboration between CSR, finance, and compliance teams to ensure all records are up to date and can support every number filed in the form.
Managing Communication with the CSR Committee
The CSR committee has a statutory role in overseeing CSR planning, monitoring, and disclosures. One of its responsibilities is to ensure that the company is compliant with all CSR-related provisions, including the timely and accurate filing of Form CSR-2.
The extended deadline to 30 June 2025 should be used to schedule a formal meeting of the CSR committee to review the draft CSR-2 form, assess compliance status, and confirm alignment with the approved CSR policy. This review can also cover project effectiveness, learnings from impact assessments, and policy improvements.
Companies should prepare a detailed presentation or report for the CSR committee summarizing financials, project progress, beneficiary impact, and budget utilization. This not only informs the committee but also creates a documented governance trail of compliance with Section 135.
The meeting minutes should reflect the review of the CSR-2 draft and any comments or concerns raised by the committee. These minutes serve as a record that the company has taken reasonable care to ensure accuracy and completeness of the filing.
The CSR committee may also use the extended filing window to recommend strategic improvements to next year’s CSR plan, based on insights from the current filing. This continuous improvement loop enhances the credibility and value of the company’s CSR strategy.
Regulatory Coordination and the Role of Stakeholders
The implementation of the CSR-2 form filing extension highlights the importance of cross-functional coordination between various internal departments and external agencies. Within a company, the secretarial team acts as the primary compliance custodian, tracking regulatory updates and ensuring the company’s filings are timely and accurate. Their role becomes even more crucial when amendments like the CSR-2 extension are notified, requiring recalibration of internal deadlines and reporting workflows.
The CSR committee of the board must remain aligned with these updates. As the governing body responsible for CSR activities and disclosures under Section 135 of the Companies Act, it is expected to oversee data finalization, monitor the accuracy of impact assessment reports, and ensure that any unspent CSR amounts are appropriately treated and documented. Their meetings must include specific references to CSR-2 filing progress, especially as the deadline nears.
Similarly, the finance department plays a pivotal role in reconciling CSR spending figures with audited financials. It is not uncommon for discrepancies to arise if CSR expenditures are recorded differently in internal books versus how they are reflected in the Directors’ Report or CSR-2. This department must work closely with both secretarial and CSR committee representatives to validate spending, impact assessments, and escrow arrangements.
For companies that engage implementing agencies, their prompt submission of utilisation certificates, impact metrics, and unspent fund breakdowns is essential. The company must ensure contracts with these agencies include clauses for timely data reporting in line with CSR-2 compliance requirements.
Finally, statutory auditors and internal auditors should also be looped into the CSR-2 preparation process. While CSR-2 is a self-certified form, alignment with the audited financial statements boosts confidence in the numbers and reduces the likelihood of discrepancies that could raise regulatory queries. Internal audit reviews of CSR data before CSR-2 filing further enhance governance and data integrity.
Policy Impacts and Industry Response
The policy extension has been welcomed by most industry bodies and compliance professionals, who see it as a pragmatic decision by the Ministry of Corporate Affairs. In recent years, as CSR regulations have evolved to mandate greater transparency, detailed disclosures, and impact assessments, the associated workload has increased significantly. The CSR-2 filing process has emerged as a central reporting mechanism, consolidating key CSR performance metrics, financial details, and compliance confirmations.
By extending the deadline to 30 June 2025 for FY 2023-24, the government has allowed companies to synchronise their CSR disclosures with the finalisation of financials and Directors’ Reports, which typically conclude around May or June. This move aligns with the natural cycle of board approvals and annual general meeting preparations. It also eliminates the previous dissonance where CSR-2 was due before many companies had even finalised their audit reports.
Another factor influencing the extension is the increased number of companies crossing the CSR applicability threshold. With business recovery post-pandemic and the economic expansion across sectors, more entities now meet the net worth, turnover, or profit criteria under Section 135. Many of these first-time CSR-eligible companies are still building internal frameworks and data collection systems. The additional quarter offers them space to put those systems in place without immediate exposure to penalties or condonation filings.
The extension also benefits companies facing delays in completing third-party impact assessments. For companies spending more than ten crore rupees on CSR, the mandatory assessment report is a prerequisite for CSR-2 completion. As these assessments require time for data gathering, stakeholder interviews, and report validation, the three-month window allows companies to complete them without compromising quality or rushing service providers.
Risks of Non-Compliance and Forward Strategy
Despite the relief granted through the extended deadline, companies must remain aware of the compliance risks associated with CSR-2 filing. Missing the 30 June 2025 deadline can trigger a range of regulatory and reputational consequences. Form CSR-2 is now a mandatory e-form, and any delay in filing will require condonation via Form GNL-1, which not only adds to compliance costs but also increases scrutiny by the Registrar of Companies.
Furthermore, failure to file Form CSR-2 on time could reflect negatively on the company’s compliance history, affecting investor confidence, credit ratings, and regulatory trust. Companies undergoing corporate actions such as mergers, acquisitions, or listing processes may also face complications if their CSR-2 filings are missing or non-compliant, as due diligence teams regularly inspect such regulatory filings.
To avoid such risks, companies are advised to adopt a structured forward strategy. This includes setting internal cut-off dates for data collection well before the statutory deadline, running CSR-2 test filings through the MCA-21 portal, and maintaining board-level documentation of CSR-2 approval. A clear delegation of responsibility across departments, ideally mapped within the ERP system or internal compliance trackers, is essential for smooth execution.
Another important aspect is documentation readiness. Companies must retain board minutes, committee reports, utilisation certificates, impact assessments, and any escrow bank documentation securely, as they may be called upon for inspection. This is particularly important for companies that file condonation requests or are subject to regulatory scrutiny due to past delays or discrepancies.
To further enhance compliance, companies should consider periodic compliance audits specific to CSR filings. These can help identify gaps in documentation, disclosure mismatches between the Directors’ Report and CSR-2, and challenges in impact assessment integration. Such proactive audits not only mitigate risk but also demonstrate a company’s commitment to ethical and transparent governance.
Conclusion
The extension of the CSR-2 filing deadline to 30 June 2025 by the Ministry of Corporate Affairs represents a strategic step that aligns with the practical realities of CSR reporting and financial finalisation. It offers companies much-needed flexibility in compiling accurate, audit-aligned data and completing third-party impact assessments. However, this extension should not be viewed as an opportunity for delay but as a cushion for quality and governance enhancement.
Companies must use this time wisely to update compliance calendars, streamline interdepartmental workflows, engage early with auditors and implementing agencies, and prepare a high-quality, defensible CSR-2 form. The form is more than a compliance checkbox, it is a public record of a company’s commitment to responsible business conduct. With heightened stakeholder attention to social impact and ESG performance, filing CSR-2 accurately and on time is both a statutory and reputational priority.
As CSR continues to gain prominence in India’s corporate landscape, regulatory compliance through mechanisms like CSR-2 will remain under close watch. The companies that treat this as an opportunity to improve data integrity, transparency, and governance will likely emerge as leaders in sustainable business practices.