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Company law · CSR Rules

CSR-1 Registration for NGOs — Become a CSR Implementing Agency

A Section 8 company, trust or society that wants to run CSR projects for companies must first register with the Central Government in Form CSR-1. Rule 4 of the Companies (CSR Policy) Rules, 2014 has required this since 1 April 2021. The form is verified by a practising professional and generates a CSR registration number on submission.

Rule 4, CSR Policy RulesCSR registration number12A & 80G (now Sections 332 & 354)Verified by a practising CA or CS
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What it is

CSR-1 registration is how a non-profit becomes eligible to carry out corporate social responsibility work on behalf of companies. Once the form is filed, the system issues a unique CSR registration number. It is the number you give companies that want to route their CSR funds through you.

The law sits in Section 135 of the Companies Act, 2013 and Rule 4 of the Companies (Corporate Social Responsibility Policy) Rules, 2014. Rule 4(1) lists who can implement CSR for a company. Rule 4(2) requires every such entity that intends to undertake CSR activity to register by filing Form CSR-1 electronically with the Registrar, with effect from 1 April 2021.

Who it applies to

You run an independent NGO

A Section 8 company, registered public trust or registered society, registered under section 12A and approved under section 80G, with an established track record of at least three years in similar activities.

A company set you up

A Section 8 company, registered public trust or registered society established by a company, alone or with other companies, and holding 12A and 80G registration. No three-year track record is needed.

You are a government or statutory body

A Section 8 company, trust or society established by the Central or State Government, or any entity established under an Act of Parliament or a State legislature. Rule 4(2) covers these entities too.

Why it matters

Receive CSR funds from companies

A company that meets the Section 135(1) thresholds must spend at least 2% of its average net profits of the three preceding financial years on CSR. When it does not run projects itself, it works through an implementing agency that qualifies under Rule 4(1).

Quote one number everywhere

The system generates your CSR registration number. Quote it in proposals and agreements so the company’s CSR team has it on record.

Register once, for every donor

You file CSR-1 once. The same number serves every company that later funds you.

Which entities qualify under Rule 4(1)

ClauseEntity12A and 80G needed?Track record
4(1)(a)Section 8 company, registered public trust or registered society established by the company, alone or with other companiesYes (or exemption under section 10(23C))Not required
4(1)(b)Section 8 company, registered trust or registered society established by the Central or State GovernmentNoNot required
4(1)(c)Any entity established under an Act of Parliament or a State legislatureNoNot required
4(1)(d)Section 8 company, registered public trust or registered societyYes (or exemption under section 10(23C))At least three years in similar activities

Independent NGOs fall under clause (d), so the three-year record and income-tax registrations come first.

Say two Faridabad auto-component makers set up a joint Section 8 foundation last year. It falls under clause (a). It needs 12A and 80G, but not three years of history, because the companies themselves established it.

12A and 80G under the Income-tax Act, 2025

Rule 4(1) still refers to section 12A, section 80G and section 10(23C) of the Income Tax Act, 1961. From 1 April 2026, the Income-tax Act, 2025 replaced the 1961 Act. Registration of charitable organisations now sits in section 332, and approval to receive deductible donations sits in section 354.

Rule 4(1) refers toIncome-tax Act, 2025
Section 12A / 12AB registrationSection 332 registration (Form 104 provisional, Form 105 regular)
Section 80G approvalSection 354 approval
Section 10(23C) exemptionSection 332 registration

Section 8(1) of the General Clauses Act, 1897 says that when a law is repealed and re-enacted, references to the old provision are read as references to the new one. Valid registrations held on 1 April 2026 also continue until their original expiry under section 536(2) of the new Act. So an NGO with a live 12AB registration and 80G approval, or with section 332 registration and section 354 approval, meets this condition.

Here is the catch: the word that matters is live. A registration that lapsed or was cancelled before 1 April 2026 does not revive, so the NGO must apply afresh under section 332 before it can file CSR-1.

Documents required

From the entity

  • Registration certificate, with trust deed, society bye-laws or memorandum and articles
  • PAN of the entity
  • Registration number, date of registration, address and email
  • NGO Darpan ID, if you have one

From the income-tax file

  • 12A / 12AB registration order or section 332 registration
  • 80G approval or section 354 approval
  • Or the section 10(23C) exemption order, where that applies

From the people who run it

  • Details of directors, trustees or office bearers and the chief executive
  • Digital signature certificate of the person signing for the entity
  • For clause (d): annual reports or accounts showing three years of similar work

How it works

1

Find your clause in Rule 4(1)

We check who set up your entity and how long it has worked in the field. That decides whether you need 12A and 80G, and a three-year record.

Picture a Faridabad skill-training trust that a local manufacturer wants to fund from its CSR budget. Before the agreement is signed, the trust needs CSR-1 on file and its registration number in hand.

2

Confirm your income-tax registrations

We check that your registration and approval are valid, and when each one expires. In practice, we settle this before any form is drafted, because an expired registration changes the whole plan.

3

Arrange the DSC and gather the papers

The person signing for the entity needs a digital signature certificate. We collect the registration papers and details of the people who run the entity.

4

File CSR-1 on the MCA portal

We prepare Form CSR-1. The entity signs it, and a practising Chartered Accountant, Company Secretary or Cost Accountant verifies it digitally, as Rule 4(3) requires.

5

Share your CSR registration number

The system generates the number on submission. We add it to your proposal templates for companies.

Timelines

File before your first CSR project

Rule 4(2) requires registration by an entity that intends to undertake CSR activity. File CSR-1 before you sign your first CSR project with a company.

Get the number on submission

Under Rule 4(4), the unique CSR registration number is generated by the system automatically when the form is submitted.

Renew income-tax registration six months early

Section 332 registration has to be renewed at least six months before it expires. Keep it alive, because Rule 4(1) depends on it.

What happens if you skip it

Companies cannot route CSR through you

Rule 4(2) requires registration before an entity undertakes CSR activity. Without a CSR registration number, a company cannot use you as its implementing agency.

A lapsed registration breaks eligibility

Clauses (a) and (d) depend on income-tax registration and approval. If those lapse, you no longer fit Rule 4(1).

Face tax on accreted income

Under section 352 of the Income-tax Act, 2025, failing to renew registration in time can trigger tax on accreted income at the maximum marginal rate.

Frequently asked questions

What is Form CSR-1?

Form CSR-1 is the registration form an entity files with the Central Government to undertake CSR activities for companies. Rule 4(2) of the Companies (CSR Policy) Rules, 2014 made it compulsory from 1 April 2021. It is filed electronically with the Registrar on the MCA portal. On submission, the system generates a unique CSR registration number, which companies use to identify you as an implementing agency. You file it once.

Who must file CSR-1?

Every entity listed in Rule 4(1) that intends to undertake CSR activity must file CSR-1. That covers Section 8 companies, registered public trusts and registered societies, whether set up independently, by a company or by the government, and entities set up under an Act of Parliament or a State legislature. A company that spends its CSR money directly does not file CSR-1. Unsure of your clause? We can map it in one call.

Is 12A and 80G registration compulsory for CSR-1?

For most NGOs, yes. Clauses (a) and (d) of Rule 4(1) require registration under section 12A and approval under section 80G, or an exemption under section 10(23C). Clause (a) covers entities set up by a company; clause (d) covers independent NGOs. Entities set up by the Central or State Government under clause (b), and statutory bodies under clause (c), do not need them. Check your clause first; the documents follow from it.

Does the new Income-tax Act change the 12A and 80G condition?

Not in substance. Rule 4(1) still cites the Income Tax Act, 1961, but from 1 April 2026 registration sits in section 332 and donation approval in section 354 of the Income-tax Act, 2025. Under section 8(1) of the General Clauses Act, 1897, references to repealed provisions are read as references to the re-enacted ones. Valid registrations held on 1 April 2026 continue until their original expiry, so your existing certificates still count.

Does an NGO need a three-year track record to file CSR-1?

Only an independent NGO under clause (d) needs it. Rule 4(1)(d) asks for an established track record of at least three years in undertaking similar activities. A foundation set up by a company under clause (a) needs 12A and 80G but no track record, and government or statutory bodies need neither. A Palwal society that began running a village library in 2024 is still short. It should keep its records tidy and file once it crosses three years.

Who signs and verifies Form CSR-1?

The entity signs it, and a practising professional verifies it. Rule 4(3) requires CSR-1 to be signed and submitted electronically by the entity and verified digitally by a Chartered Accountant, Company Secretary or Cost Accountant in practice. So the person signing for the NGO needs a valid digital signature certificate. As a CA and CS firm, we prepare the form and carry out the professional verification.

How is the CSR registration number issued?

Automatically, on submission. Rule 4(4) says that on submission of Form CSR-1, a unique CSR registration number is generated by the system. There is no separate approval order to wait for. Quote the number in your proposals and agreements with companies. Once issued, it serves every CSR partner you work with.

Which companies have to spend on CSR?

A company with net worth of ₹500 crore or more, turnover of ₹1,000 crore or more, or net profit of ₹5 crore or more in the preceding financial year. Section 135(5) then requires it to spend at least 2% of its average net profits of the three immediately preceding financial years. If the amount does not exceed ₹50 lakh, the board does the CSR committee’s work. Either way, an implementing agency it works through must hold a CSR registration number.

Pricing

What it costs

Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.

Ready to begin?

Tell us who set up your NGO, when, and which income-tax registrations you hold, and we will get your CSR registration number issued.