CORAA

NGO as CSR Implementing Agency Compliance Checklist

The three prerequisites a company checks before routing CSR funds to an NGO — CSR-1 registration, the three-year track record, and the utilisation reporting the implementing NGO actually owes back.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Prerequisite
Form CSR-1 registration (Rule 4(2))
Track record
Minimum 3 years in similar activity
Owes the company
Utilisation certificate + progress reporting
Eligible forms
Section 8 company / registered public trust / registered society
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Your firm — letterhead
Appears at the top of the document as the audit firm letterhead.
Used as the letterhead block.
Engagement details
The client and period this document is for.
Auto-printed in the audit report and annexure header.
The 12A / 12AB / 10(23C) registration / URN issued by Income-tax department.
The previous year for which Form 10B is being filed.
AY corresponding to the previous year above.
What’s inside

An excerpt from the template.

NGO AS CSR IMPLEMENTING AGENCY COMPLIANCE CHECKLIST

Entity: ___ · PAN: ___ · Year ended: ___

Companies subject to Section 135 CSR obligations may route their CSR spend through an implementing agency rather than undertaking projects directly. The Companies (CSR Policy) Rules prescribe specific prerequisites an NGO must meet to be an eligible implementing agency, and specific reporting obligations back to the contributing company. This checklist tests the NGO's side of that compliance.

A. CSR-1 Registration Prerequisite

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About this template

What you’re downloading, and when to use it.

This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

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Common questions

FAQs.

Can any registered NGO receive CSR funds from a company?
No — only an entity that has filed Form CSR-1 with the Registrar of Companies and obtained a CSR Registration Number is eligible to act as a CSR implementing agency under the Companies (CSR Policy) Rules. An otherwise well-established, 12A/12AB-registered NGO still cannot lawfully receive CSR funds routed through this mechanism without that specific CSR-1 registration.
Does the NGO need to prove a specific number of years of activity?
Yes — CSR-1 eligibility generally requires the entity to have an established track record of at least three years in undertaking similar activities to what it will implement, and this is a condition the company sponsoring the CSR project is expected to have satisfied itself of before signing on. An NGO that recently changed its area of activity, or is newly formed, may not meet this test even if otherwise properly registered.
What happens if the NGO doesn't spend all the CSR funds received in the year?
Unspent CSR amounts trigger obligations primarily on the CONTRIBUTING COMPANY side (transfer to a specified unspent-CSR bank account and, for ongoing projects, further transfer within the prescribed timeline under Sec 135(6)) — but the implementing NGO still needs to report the unspent position accurately and promptly so the company can meet its own statutory deadlines. A delay or gap in the NGO's utilisation reporting can cause the company to miss its own compliance window.
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