India Shortens Deadline for Filing CSR-2 Return: MCA Notification

Posted by Written by Melissa Cyrill Reading Time: 2 minutes

Companies in India that report their corporate social responsibility expenditure must note that the filing window for the CSR-2 return form for FY 2023-24 has been shortened and must be done by December 31, 2024.

The Ministry of Corporate Affairs (MCA) has tightened corporate social responsibility (CSR) compliance in India by reducing the window for submitting CSR returns. Companies are now required to file their CSR-2 return for the financial year 2023-24 by December 31, 2024.

This CSR-2 return must be filed separately from the AOC-4, which is the annual return form due within 30 days of the company’s annual general meeting (AGM). Previously, for FY 2022-23, businesses were permitted to submit their CSR-2 returns by March 31, 2024.

Find Business Support
Corporate Social Responsibility in India: A Guide for Companies in India

Experts in company law have pointed out discrepancies in some cases where CSR figures reported in financial statements (via AOC-4) did not align with the data provided in CSR-2 filings. The MCA’s move to shorten the compliance period is expected to enhance government oversight and reduce the potential for malpractice.

The revised timelines will promote greater transparency and accuracy, requiring companies to maintain distinct records for AOC-4 and CSR-2 filings.

Find Business Support
De-Risk Your Asia Business with a Company Health Check, Corporate Secretarial Services, and Professional Advisory

Earlier, the Companies (Accounts) Rules, 2014 were amended in 2022 to mandate CSR-2 as an addendum to AOC-4. However, in 2023, this was changed to require separate CSR-2 filings after AOC-4 submissions for FY 2022-23, with a deadline of March 31, 2024. The latest amendment now sets the deadline for CSR-2 filings for FY 2023-24 to December 31, 2024.

Form CSR-2, introduced in 2022, requires companies to report details of their CSR initiatives, including projects undertaken, CSR committees, spending, and unspent funds.

Ministry of Corporate Affairs notification dated September 24, 2024:

G.S.R. 587(E).—In exercise of the powers conferred by sub-sections (1) and (3) of section 128, sub-section (3) of section 129, section 133, section 134, sub-section (4) of section 135, sub-section (1) of section 136, section 137 and section 138 read with section 469 of the Companies Act, 2013 (18 of 2013), the Central Government hereby makes the following rules further to amend the Companies (Accounts) Rules, 2014, namely:—

  1. Short title and commencement. —(1) These rules may be called the Companies (Accounts) Amendment Rules, 2024.

(2) They shall come into force on the date of their publication in the Official Gazette.

  1. In the Companies (Accounts) Rules, 2014, in rule 12, in sub-rule (1B), after the third proviso, the following proviso shall be inserted, namely: —

“Provided also that for the financial year 2023-2024, Form CSR-2 shall be filed separately on or before 31st December, 2024 after filing Form No. AOC-4 or Form No. AOC-4-NBFC (Ind AS), as specified in these rules or Form No. AOC-4 XBRL as specified in the Companies (Filing of Documents and Forms in Extensible Business Reporting Language) Rules, 2015 as the case may be.”

About Us

India Briefing is one of five regional publications under the Asia Briefing brand. It is supported by Dezan Shira & Associates, a pan-Asia, multi-disciplinary professional services firm that assists foreign investors throughout Asia, including through offices in Delhi, Mumbai, and Bengaluru in India. Readers may write to india@dezshira.com for support on doing business in India. For a complimentary subscription to India Briefing’s content products, please click here.

Dezan Shira & Associates also maintains offices or has alliance partners assisting foreign investors in China, Hong Kong SAR, Dubai (UAE), Indonesia, Singapore, Vietnam, Philippines, Malaysia, Thailand, Bangladesh, Italy, Germany, the United States, and Australia.