CSR-1 Registration Checklist for NGOs — Implementing Agency Eligibility & Documents
CSR-1 REGISTRATION CHECKLIST — CSR IMPLEMENTING AGENCY
Entity: {{trust_name}} | PAN: {{trust_pan}} | Constitution: Registered public trust
Registered address: {{registered_address}}
A. Eligibility under Rule 4(1), Companies (CSR Policy) Rules, 2014
| Clause | Eligible entity | Conditions |
|---|
| Rule 4(1)(a) | Section 8 company / registered public trust / registered society — established by the spending company (alone or along with any other company) | Registered under section 12A and approved under section 80G of the Income-tax Act, 1961 |
| Rule 4(1)(b) | Section 8 company / registered trust / registered society established by the Central Government or a State Government | No 12A / 80G or track-record condition |
| Rule 4(1)(c) | Entity established under an Act of Parliament or a State legislature (statutory body) | No 12A / 80G or track-record condition |
| Rule 4(1)(d) | Independent Section 8 company / registered public trust / registered society (not established by the spending company or a government) | Registered under section 12A and approved under section 80G, AND an established track record of at least 3 years in undertaking similar activities |
- Drafting hint: for most independent NGOs, clause (d) applies — 12A + 80G registration and the 3-year track record are all mandatory. A newly formed NGO without three years of similar activities cannot register under clause (d).
- Drafting hint: CSR-1 registration is prospective — without a CSR Registration Number the entity cannot receive CSR funds from companies, regardless of how credible its work is.
B. Document checklist for Form CSR-1
| Sl. | Document | Status | Remarks |
|---|
| 1 | Certificate of incorporation (Section 8) / registered trust deed / society registration certificate | | |
| 2 | PAN of the entity | | |
| 3 | Section 12A registration order / URN | | |
| 4 | Section 80G approval order / URN | | |
| 5 | Proof of 3-year track record — annual reports / audited accounts / activity reports for the three preceding years (clause (d) entities) | | |
| 6 | Details of directors / trustees / office bearers — name, DIN (where applicable), PAN, email | | |
| 7 | Digital signature (DSC) of the authorised signatory | | |
| 8 | Board / governing body resolution authorising the CSR-1 filing and the signatory | | |
| 9 | Certification by a Chartered Accountant / Company Secretary / Cost Accountant in whole-time practice (the form must be professionally certified before submission on the MCA portal) | | |
On approval, the MCA system generates a CSR Registration Number — quote it in every CSR proposal, agreement and utilisation certificate.
C. CSR-1 vs CSR-2 — do not confuse the two
Form CSR-1 is the implementing agency's (NGO's) one-time registration to receive CSR funds. Form CSR-2 is the spending company's annual report on its CSR activities filed with the ROC — it is not an NGO filing. The NGO's obligations to the funding company are contractual: project reporting and utilisation certification as agreed.
D. CSR project proposal / utilisation skeleton (NGO side)
| Particulars | Details |
|---|
| Project name | |
| Implementing agency & CSR Registration Number | {{trust_name}} — |
| Schedule VII head(s) covered | ____________ [e.g. (ii) promoting education / (i) eradicating hunger, poverty and malnutrition] |
| Location(s) of implementation | ____________ |
| Project budget and funding sought | ₹ ____________ |
| Project duration / milestones | ____________ |
| Expected outcomes and measurement | ____________ |
Utilisation certificate skeleton: 'Certified that out of ₹ ____________ received from ____________ [company] towards the CSR project '', ₹ ____________ has been utilised for the purposes for which it was sanctioned, and the balance of ₹ ____________ remains unutilised as at ____________. The utilisation is in accordance with the approved project budget and books of account maintained by the entity.'
Prepared on: 31 July 2026
For {{firm_name}}
Chartered Accountants
Firm Registration No.:
_______________________________
{{engagement_partner}}
Partner | Membership No.: {{icai_membership_no}}
