Form CSR-2 Filing Guide: Step-by-Step Process for FY 2025-26

Last updated: July 2026

Form CSR-2 is a mandatory annual filing for companies covered under Section 135 of the Companies Act, 2013. This guide covers applicability, the current due date position, required documents, the filing process, and recent rule changes relevant to FY 2025-26.

What Is Form CSR-2

Form CSR-2 is a web-based e-form under Rule 12(1B) of the Companies (Accounts) Rules, 2014. Every company covered by Section 135(1) of the Companies Act, 2013 must file it with the Registrar of Companies to report CSR spending, project details, committee composition, and compliance status for the year.

Who Must File

CSR applies, and CSR-2 must be filed, if a company met any one of the following thresholds in the immediately preceding financial year:

Criterion	Threshold
Net worth	₹500 crore or more
Turnover	₹1,000 crore or more
Net profit	₹5 crore or more

A few points to keep in mind:

• Applicability is assessed every year. The earlier provision allowing companies to exit CSR after three consecutive years below the threshold was omitted in 2022. A company that crosses a threshold this year becomes subject to CSR next year; if it falls below all three the following year, the obligation does not apply for that year.
• Coverage is broad. Private limited companies, public limited companies, One Person Companies, Section 8 companies, and Indian branches of foreign companies are all covered.
• Net profit is computed under Section 198 of the Act, not book profit and not taxable profit under the Income Tax Act. This distinction affects the applicability check.
• Excess CSR spend can be carried forward. If a company spends more than its 2% obligation in a year, the full excess amount can be set off against the obligation for up to the next three financial years, subject to a Board resolution and exclusion of any CSR-activity surplus. There is no percentage cap on the set-off.

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CSR-2 Due Date for FY 2025-26

The CSR-2 due date is not fixed. It is linked to the AOC-4 filing, which is due 30 days from the AGM, but the MCA separately notifies a specific CSR-2 deadline for each financial year through a provision to Rule 12(1B). In recent years, that notified date has fallen well after the AOC-4 due date.

Recent history:

• FY 2023-24: extended twice — first to 31 March 2025, then to 30 June 2025, via the Companies (Accounts) Amendment Rules, 2025 (notified 19 May 2025).
• FY 2024-25: filed under the same amendment, as a standalone submission following the same extended window.

For FY 2025-26, the MCA has not yet issued a specific notified deadline. Companies should plan to file shortly after AOC-4 — likely between late October and December 2026 — and confirm the exact date on the MCA portal closer to the filing period, since extensions are typically announced only a few weeks before the prior deadline lapses.

Documents Required

1. SRN of the filed AOC-4 / AOC-4 XBRL / AOC-4 NBFC (Ind AS)
2. Audited financial statements for the year
3. CSR Committee composition and meeting minutes
4. CSR Policy document
5. Project-wise details — location, implementing agency, amount allocated versus spent
6. CSR-1 registration numbers of implementing agencies used
7. Details of any unspent CSR amount and its transfer (Unspent CSR Account or Schedule VII fund)
8. Impact assessment report, where the average CSR obligation is ₹10 crore or more
9. Digital Signature Certificate (DSC) of the authorized signatory

Step-by-Step Filing Process

1. File AOC-4 first. CSR-2 requires the AOC-4 SRN, so this must be completed beforehand.
2. Log in to MCA21 V3 using the company’s registered credentials.
3. Locate Form CSR-2 in the e-forms directory.
4. Enter the AOC-4 SRN to link the filing to the financial statements.
5. Enter net worth, turnover, and net profit to confirm applicability.
6. Enter CSR Committee details, including composition compliance.
7. Report CSR spending project-wise — ongoing versus one-time projects, implementing agency CSR-1 numbers, amounts allocated and spent, and any unspent balance with transfer details.
8. Declare compliance status against the 2% spending requirement, with reasons for any shortfall.
9. Attach supporting documents such as board resolutions and impact assessment reports.
10. Affix the DSC of the authorized signatory.
11. Submit and retain the SRN as proof of filing.

CSR Amendment Rules, 2025 — What Changed

The Companies (Accounts) Amendment Rules, 2025 (notified 19 May 2025) introduced the following changes relevant to FY 2025-26 filings:

• Independent filing: CSR-2 no longer needs to be filed as an attachment within the AOC-4 window. It can be filed as a standalone submission after AOC-4 is on record.
• Portal migration: MCA21 V2 was decommissioned in mid-2025. Companies with an AOC-4 SRN from V2 should confirm it is recognized on V3 before filing CSR-2.
• Revised Form CSR-1: Implementing agencies now register through an updated CSR-1 form requiring 12A/80G details, a three-year track record (unless company-created), audited accounts, and certification by a CA/CS/CMA. Only agencies with a registration number issued after this update can receive fresh CSR funds, so implementing partners’ registration status should be verified before disbursement.

Penalties: CSR-2 Filing vs. CSR Spending Non-Compliance

These are governed by different provisions and should not be conflated.

Late or non-filing of Form CSR-2: No specific additional fee is prescribed, unlike AOC-4, which attracts a flat ₹100 per day. In the absence of a specific penalty, the residual provision under Section 450 applies: a penalty of up to ₹10,000, plus ₹1,000 for each day the default continues, capped at ₹2 lakh for the company and ₹50,000 for an officer in default.

Non-compliance with the CSR spending obligation (failing to spend the required 2% or not transferring the unspent amount) is penalized separately under Section 135(7):

• Company: twice the unspent amount, or ₹1 crore, whichever is lower.
• Officer in default: one-tenth of the unspent amount, or ₹2 lakh, whichever is lower.

Independent of these penalties, the transfer timelines apply regardless: unspent amounts tied to ongoing projects must move to the Unspent CSR Account within 30 days of year-end, while other unspent amounts must go to a Schedule VII fund within 6 months.

Common Mistakes to Avoid

• Filing CSR-2 before AOC-4 has been processed.
• Using CSR-1 registration numbers issued before the 2025 revision.
• Treating Section 198 net profit as equivalent to book profit or taxable profit.
• Assuming the previous year’s due date applies without checking the current notification.
• Omitting impact assessment documentation once the ₹10 crore obligation threshold is crossed.

This article is for general informational purposes and does not constitute legal or professional advice. CSR rules and due dates change through MCA notifications; please verify the current position on the MCA website or with a company secretary before making compliance decisions.