India Fortifies CSR Compliance: MCA Unveils Revised CSR-1 Form and Stricter Guidelines

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Introduction

In a pivotal move to elevate accountability and transparency within corporate social responsibility initiatives, the Ministry of Corporate Affairs issued a notification, vide no. G.S.R. 452(E), on July 7, 2025. This notification introduces critical amendments to the CSR framework under the Companies Act, 2013. These revised regulations, officially termed as Companies (Corporate Social Responsibility Policy) Amendment Rules, 2025, and slated to become effective on July 14, 2025. A central element of this update is the replacement of the existing CSR-1 e-form with a newly designed format, meticulously crafted to enhance regulatory compliance for all entities engaged in CSR activities.

The CSR-1 Form is a statutory requirement for any entity intending to undertake CSR activities on behalf of a company, as mandated by Section 135 of the Companies Act, 2013, and Rules 4(1) and 4(2) of the Companies (CSR Policy) Rules, 2014. The 2025 amendment to this form ushers in substantial changes, necessitating additional disclosures and imposing stricter eligibility criteria for organizations aspiring to implement CSR programs.

Key Changes in the 2025 Amendment:

The revised CSR-1 Form introduces mandatory additional disclosures and tightens the eligibility criteria for entities intending to carry out CSR programs.

CriteriaEarlier ProvisionsNew Provisions (2025)
Eligible Entity TypesSection 8 companies, registered public trusts and societies.Expanded to include government-established entities and those set up under Acts of Parliament/State Legislature.
Experience RequirementNot requiredEntities not incorporated by a company must now show a 3-year track record in CSR-like activities.
Professional CertificationNot mandatoryNow requires certification by CA, CS, or Cost Accountant in full-time practice.
Digital SignatureNot enforced strictlyMandatory for authorized signatories (Director, Trustee, CEO, etc.)

Conclusion

The 2025 revision of the CSR-1 Form marks a pivotal shift in India’s CSR compliance regime, signaling a stronger emphasis on accountability and ethical practices. Companies are strongly encouraged to ensure their implementing partners are registered under these new guidelines, while eligible non-profits and social enterprises must act swiftly to register through the revised mechanism. This transformative step by the MCA is poised to usher in a new era of more impactful and accountable CSR practices across India, ultimately contributing to greater societal good.

Expositor(s):  Adv. Archana Shukla