New CSR-1 e-form to tighten CSR compliance

With effect from 1^st April 2021, CSR-1 registration was made mandatory by the Ministry of Corporate Affairs (MHA) 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 shall come into effect from 14^th July 2025) has now substituted the existing e-form CSR-1.

The new e-form CSR-1 requires more details than the existing one.

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

• 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;
• Company established under Section 8, registered under section 12A and approved under section 80G of the Income Tax Act, 1961 or;
• 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;
• Registered Public trust, registered under section 12A and approved under section 80G of the Income Tax Act, 1961 or;
• 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;
• Registered society, registered under section 12A and approved under section 80G of the Income Tax Act, 1961 or;
• Company established under section 8 or registered Trust or registered Society established by the Central Government or State Government or;
• Entity established under an Act of Parliament or State Legislature or;
• 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.’

Details of entity

Using the drop-down option in the e-form, the entity must select whether it is a Section 8 Company or Trust or Society or Others and in case of a Section 8 company, enter CIN and for trust, society or others enter registration number, date of incorporation, address, E-mail ID of the entity, OTP for E-mail Id and PAN of the entity.

Authorized representatives’ details

Applicant must also disclose details of all Directors/Board of Trustees/Chairman/CEO/ Secretary/Authorized Representatives of the entity) with details of name, designation (e.g. Trustee, Chairman, Director, CEO etc.), Director Identification Number (DIN) or PAN and email ID of each authorized representative of the entity.

Upload

Copy of the Certificate of Registration as also the PAN of the Entity must be uploaded.

Declaration

The person signing the e-form must declare that he/she is authorized by the entity vide resolution number ………. Dated ………….. (DD/MM/YYYY) to sign the e-form and also declare that the particulars given in the e-form are true and in agreement with the documents maintained by the Entity.

Signed Digitally

The application must be digitally signed by:

• one Director in case of Section 8 company; or
• one of the Trustee/CEO in case of Registered Public Trust; or
• Chairperson/CEO/ Secretary in case of Registered Society; or
• Authorized Representative in case of Entity established under an Act of Parliament or State Legislature.

DIN of the director or DIN or PAN of the Trustee or CEO or Chairperson or Secretary or authorised representative of the Entity digitally signing the e-form must be provided.

Certificate by practicing professional

The e-form must be certified by either a Chartered accountant (in whole time practice) or Cost accountant (in whole time practice), Company secretary (in whole-time practice) and such practising professional must disclose whether he/she is an associate or fellow and provide his/her Membership number and Certificate of Practice number.

The practicing professional must declare that he/she has been duly engaged for the purpose of certification of the e-form and that he/she certifies that he/she has gone through the provisions of the Companies Act, 2013 and Rules thereunder for the subject matter of this e-form and matters incidental thereto and that he/she has verified the above particulars [including attachment(s)] from the original/certified records maintained by the Company/ applicant which is subject matter of this e-form and found them to be true, correct and complete and no information material to this e-form has been suppressed.

The practicing professional must also certify that:

1. The said records have been properly prepared, signed by the required officers/ authorized representatives of the entity and were found to be in order;
2. All the required attachments have been completely and legibly attached to this e-form;
3. It is understood that he/she shall be liable for action under section 448 of the Companies Act, 2013 for wrong certification, if any found at any stage.