What Is Form CSR-2?
Form CSR-2 is the annual report on Corporate Social Responsibility (CSR) that every company covered under section 135 of the Companies Act, 2013 files with the Registrar of Companies (RoC). The Ministry of Corporate Affairs (MCA) describes the form on its own e-filing portal as covering "Reporting on Corporate Social Responsibility," filed "Pursuant to sub-rule (1B) of Rule 12 of Companies (Accounts) Rules, 2014."
Unlike Form AOC-4, which files a company's financial statements, CSR-2 files a single year's CSR data in structured fields: the net worth, turnover and net profit figures that decide whether CSR applies at all, the CSR committee's composition, the 2% obligation and how much of it was actually spent, and — where money was left over — where the unspent amount went. It is a disclosure form, not an obligation-creating one. The duty to spend on CSR comes from section 135 itself; CSR-2 is how a company reports that it complied, or explains what remained unspent.
Legal Basis: Rule 12(1B) of the Companies (Accounts) Rules, 2014
Form CSR-2 exists because of a single rule — Rule 12(1B) of the Companies (Accounts) Rules, 2014 — which requires companies covered by section 135(1) to file a CSR report in the prescribed form. MCA's own instruction kit for the form cites the rule directly: "Pursuant to Rule 12(1B) of Companies (Account) Rules, 2014."
How the form is actually filed has changed over time. MCA's instruction kit states that CSR-2 was filed "as an independent form for FY 2020-21, FY 2022-23, FY 2023-24 and FY 2024-25 [V2 filings]" — meaning that in those years a company first filed its AOC-4 and then, separately, returned to the MCA portal to file CSR-2 on its own. From FY 2024-25 onward, the instruction kit describes CSR-2 "as a linked form to AOC-4/AOC-4 XBRL/AOC-4 NBFC" — it is now filed together with AOC-4, as an addendum within the same filing, rather than as a second, separate submission weeks later. Where CSR-2 is filed independently, the form asks for the SRN of the AOC-4, AOC-4 XBRL or AOC-4 NBFC already filed for the company's standalone financial statements, and the instruction kit requires that SRN to be "an approved SRN ... (which is not marked as Defective)" belonging to the same company and the same financial year.
This distinction matters for FY 2025-26, the year now due for most companies. Because CSR-2 is a linked form for FY 2024-25 onward, there is no separate CSR-2 deadline to track: it is filed as part of the AOC-4 submission, so it follows AOC-4's own due date under section 137 of the Companies Act, 2013 — within 30 days of the Annual General Meeting. Filing CSR-2 independently, outside the AOC-4 process, is the exception rather than the rule for current years.
Who Must File Form CSR-2?
Applicability is not decided by Rule 12(1B) itself — it is decided by section 135(1) of the Companies Act, 2013, the same threshold test that triggers the CSR spending obligation. A company must file CSR-2 for a financial year if, in the immediately preceding financial year, it met any one of three thresholds: net worth of INR 500 crore or more, turnover of INR 1,000 crore or more, or net profit of INR 5 crore or more. MCA's instruction kit for the form puts it simply: "All companies that are required to carry out Corporate Social responsibility (CSR) activities as per the relevant rules, are required file the CSR-2 application." The full mechanics of the threshold test, the three-year net-profit average, and what happens when a company falls below the thresholds are covered in the CSR entry.
The obligation follows the company, not its country of origin. A wholly-owned Indian subsidiary of a foreign parent that crosses any of the three thresholds must file CSR-2 exactly as an Indian-promoted company would — there is no carve-out for foreign ownership, and no option to substitute a global CSR report for the Indian filing.
What Form CSR-2 Reports
The form itself is organised around the same figures section 135 uses to define the CSR obligation. Fields include:
- Net worth, turnover and net profit — the three criteria that determine CSR applicability for the year
- The CSR obligation computation — the form's own field is headed "2% of Average net profit of the company as per section 135(5)"
- CSR Committee composition — the number and category of directors on the committee
- Amount spent — against ongoing and other-than-ongoing projects, by Schedule VII category
- Unspent CSR account transfer — the form asks for the amount transferred "to Unspent CSR account as per Section 135(6)"
- Schedule VII fund transfer — for amounts moved to a fund such as the PM National Relief Fund, the field cites the "Fund specified in Schedule VII as per second proviso to Section 135(5)"
- Impact assessment details — where applicable, for companies with larger CSR obligations
Because the form draws on figures already computed for the Board's Report and the CSR annexure under section 135(4), most of the work of filing CSR-2 lies in the underlying CSR accounting, not in the form itself. A company that keeps an accurate running record of its CSR committee minutes, project-wise spending, and any unspent-account transfers should be able to populate CSR-2 largely by cross-referencing its own annual CSR report.
Processing: STP and Non-STP Filing
MCA's instruction kit distinguishes how the form is processed depending on how it is filed. An independent CSR-2 filing — the pattern used for FY 2020-21, FY 2022-23, FY 2023-24 and FY 2024-25 on the earlier V2 portal — is processed in STP (Straight-Through Processing) mode, meaning it is accepted on submission without manual RoC review. A CSR-2 filed as a linked form is processed in Non-STP mode only where the purpose selected in the AOC-4, AOC-4 XBRL or AOC-4 NBFC is "Revised Financial statements u/s 130," "Revised Financial statements u/s 131," or "Filing leads to reduction in paid up share capital." Where the purpose is "Adopted Financial statements" — the ordinary annual case — the kit says CSR-2 is processed in STP mode.
Why Form CSR-2 Matters for Foreign-Invested Companies
For a foreign parent setting up or growing an Indian subsidiary, CSR-2 is easy to overlook precisely because it is a filing, not a spending decision — the spending decision under section 135 gets board attention; the annual return often does not, until it is missed. Three points are worth flagging:
- It is separate from the Board's Report. Disclosing CSR spending in the Board's Report under section 134 does not satisfy the CSR-2 filing requirement — the two are distinct obligations, filed through different mechanisms.
- The CSR figures are needed when AOC-4 is prepared. Because CSR-2 is now filed as a linked form, the company secretary or finance team preparing the AOC-4 filing needs the CSR figures ready at the same time as the financial statements — not weeks later, once the accounts are signed off.
- It sits alongside, not instead of, the MGT-7 annual return. A subsidiary that files AOC-4, CSR-2 and MGT-7 correctly but on different figures for the same CSR line invites RoC queries — the obligation and spend reported in CSR-2 should match what the Board's Report and CSR annexure disclose.
Common Mistakes
- Treating CSR-2 as optional once CSR spending is disclosed elsewhere. A company that discloses CSR spending fully and accurately in its Board's Report but never files CSR-2 has still not met its filing obligation under Rule 12(1B).
- Quoting an unapproved AOC-4 SRN on an independent filing. An independent CSR-2 must carry the SRN of an AOC-4, AOC-4 XBRL or AOC-4 NBFC that is already approved and not marked defective, and that SRN must belong to the same company and the same financial year.
- Assuming a single filing pattern across years. Because MCA has moved CSR-2 between independent and linked filing across different financial years, relying on last year's process without checking the current year's portal instructions can lead to a missed or misrouted filing.
Practical Example
Solvex Materials GmbH, a German manufacturer, owns a wholly-owned subsidiary in Gujarat. The subsidiary's net profit crossed INR 5 crore in FY 2024-25, triggering CSR applicability for FY 2025-26. At the FY 2025-26 year-end, the company's company secretary, working with the statutory auditor, finalises the CSR obligation figure alongside the audited financial statements. The AOC-4 is filed within 30 days of the AGM, and — since CSR-2 is a linked form for FY 2024-25 onward — CSR-2 is completed as part of the same filing exercise, referencing the AOC-4's own SRN, rather than as a separate step weeks later.
Frequently Asked Questions
Is Form CSR-2 the same as the CSR annexure in the Board's Report?
No. The CSR annexure required under section 135(4) and the CSR Rules is part of the Board's Report presented to shareholders. Form CSR-2 is a separate electronic filing with the Registrar of Companies, made under Rule 12(1B) of the Companies (Accounts) Rules, 2014. A company must do both — the annexure does not substitute for the RoC filing, and the RoC filing does not substitute for the annexure.
Does a company need to file CSR-2 if it had no CSR obligation for the year?
Applicability follows the same section 135(1) threshold test used for the CSR spending obligation itself: if a company did not cross any of the three thresholds in the preceding financial year, it is not covered by section 135 and has no CSR-2 filing to make for that year. The full threshold test is set out in the CSR entry.
Where is Form CSR-2 filed?
CSR-2 is filed on the MCA e-filing portal, under Company e-Filing, Annual Filings. As a linked form for FY 2024-25 onward, it is selected as a purpose within the AOC-4, AOC-4 XBRL or AOC-4 NBFC filing itself, rather than accessed as a stand-alone form the way it was in earlier years.
What information does a foreign-invested subsidiary need ready before filing CSR-2?
The subsidiary needs its net worth, turnover and net profit for the applicability test; the CSR committee's composition; the 2% obligation computed under section 135(5); the amount actually spent, by Schedule VII category; and, where relevant, the amount transferred to the Unspent CSR account under section 135(6) or to a Schedule VII fund under the second proviso to section 135(5). Most of this should already exist in the company's CSR committee minutes and annual CSR report.
What happens if a company files Form CSR-2 late or not at all?
MCA's instruction kit puts the normal fee for CSR-2 under the Companies (Registration Offices and Fees) Rules, 2014, and records no separate delay fee or filing time limit against the form itself. Because CSR-2 is now a linked form, a late CSR-2 in practice means a late AOC-4, which carries the additional fees attaching to that filing. Failing to file CSR-2 at all is a distinct compliance gap from the section 135(7) penalty for unspent CSR amounts, which is covered in the CSR entry.
See also: Corporate Social Responsibility (CSR), AOC-4 (Financial Statements Filing), and Registrar of Companies (ROC) and MCA.