Service 04

CSR Compliance and Advisory Services

Strategic Philanthropy & Compliance. Impact with Integrity.

Overview

With the tightening of CSR regulations, 'doing good' now requires 'doing it right.' SCORE offers a specialised wing dedicated to the legal and financial compliance of CSR activities. We ensure your social impact is measurable, your documentation is bulletproof, and your obligation is fulfilled with zero observations.

Who this service is for

CSR compliance applies to companies that cross any one of three thresholds in the preceding financial year: net worth of Rs 500 crore, turnover of Rs 1,000 crore or net profit of Rs 5 crore. In practice we work with boards and CSR committees that need a defensible process, NGOs that receive CSR funds, and groups consolidating several entities.

The obligation is not only to spend. It is to show that the money went to a permitted activity, through a verified agency, with board approval and a report that matches the ledger. That is where most observations arise.

What we do

Strategy & Policy Design

Drafting CSR policies that align with your corporate values and Schedule VII mandates.

Implementation Support

Vetting implementation agencies (NGOs/Trusts) and drafting robust tri-party agreements.

Compliance & Reporting

Assistance with Form CSR-2, CFO Certification for fund utilisation, and Impact Assessment studies.

Digital Vetting

'Green-Light' protocol — no funds released unless NGO's CSR Registration Number is verified against the MCA database.

How the engagement works

  1. Applicability and diagnostic

    We confirm the threshold test from the audited accounts and review the last two years of spending, approvals and NGO documents. The output is a gap list ranked by regulatory risk.

  2. Policy and governance

    We draft or refresh the CSR policy, the committee charter and the annual action plan, and set up an approval workflow that can be evidenced later.

  3. NGO and project vetting

    Before funds move, we check the CSR-1 registration, 12A and 80G status, FCRA position where relevant, governance documents and past utilisation. A written clearance is issued for each agency.

  4. Implementation and monitoring

    Tri-party agreements, milestone-based releases, utilisation certificates and site or document checks are set up so that monitoring is routine rather than a year-end scramble.

  5. Reporting and impact

    We prepare the board annexure, Form CSR-2, the CFO certification and, where the obligation crosses Rs 10 crore, coordinate the impact assessment and publish the required disclosures.

What you can expect

A clean CSR file answers three questions without a search: what was approved, where the money went and what changed because of it. Once that file exists, the annual report, the statutory audit and a departmental query all become easier.

Frequently asked questions

Which companies must spend on CSR?

Section 135 applies if a company had net worth of Rs 500 crore or more, turnover of Rs 1,000 crore or more, or net profit of Rs 5 crore or more in the immediately preceding financial year. Crossing any one threshold is enough; the obligation is 2% of average net profit.

What counts as CSR under Schedule VII?

Activities listed in Schedule VII, such as education, health, sanitation, environment, women's empowerment, rural development and certain national funds. The activity must be a project, not a one-off donation, and it must not benefit only employees or the promoter's family.

Can we run CSR through our own foundation?

Yes, if the foundation is a registered entity with a valid CSR-1 registration and the project meets Schedule VII. Funds must be used for the approved project, with separate books and reporting. A related foundation does not remove the need for documentation.

What is Form CSR-2 and when is it due?

Form CSR-2 is the annual CSR disclosure filed with the Registrar of Companies. It is normally filed by 30 November following the financial year end, unless the date is extended, and must reconcile with the board report and the CSR ledger.

What happens to unspent CSR money?

For an ongoing project, the unspent amount goes to the Unspent CSR Account within 30 days of the financial year end and must be spent within three years. For other projects, it is transferred to a Schedule VII fund within six months.

Do we need an impact assessment?

Impact assessment is required where the average CSR obligation is Rs 10 crore or more in the three preceding years, for projects with an outlay of Rs 1 crore or more. The cost is capped at 2% of the CSR spend or Rs 50 lakh, whichever is higher.

How do you vet an NGO before release of funds?

We verify CSR-1 registration on the MCA portal, 12A and 80G status, FCRA where foreign funds are involved, governing documents, bank details, related-party links and past utilisation. The checks are recorded and repeated at each renewal. An agency that cannot evidence these items is not cleared, whatever the project.

Can you help if we have already missed a year?

Yes. We reconstruct the record from bank statements, approvals and project documents, identify what can still be regularised, and prepare the disclosure and, where needed, a voluntary correction. Early disclosure is almost always better than waiting for an observation.

Can CSR funds be spent on our own employees' welfare?

No. CSR activities must not benefit only the company's employees or their families, and they must be separate from the normal course of business. Employee volunteering is allowed, but the spend itself has to create a public benefit under Schedule VII. We review the project design before approval.

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