CSR-2 Filing
Annual CSR Report — MCA Portal Filing, Due Date & Penalty

Form CSR-2 is the annual CSR annual report disclosure that every company with obligations under Section 135 of the Companies Act, 2013 must file on the MCA portal. CSR-2 filing is not a supplementary or optional compliance — it is a mandatory submission that forms part of the company's annual compliance record. It discloses how much the company was required to spend on CSR, how much it actually spent, which projects it implemented, which implementing agencies it used, and what happened to any unspent amount. A company that skips its filing or files it with incorrect information is treated as non-compliant, and the penalty is both financial and reputational.

At N D Savla & Associates, we manage the complete CSR-2 annual report filing MCA process for companies across Mumbai and India. We compute the correct Section 198 net profit, calculate the 2% CSR obligation, review all CSR project details and implementing agency CSR-1 registration numbers, prepare the filing accurately, and submit it before the CSR-2 form due date India. Our CSR overview page covers the full Section 135 framework, and our CSR-1 registration services help implementing agencies get registered before your funds are transferred.

The CSR-2 form due date India is 31st December following the relevant financial year end. For most companies on an April–March financial year, CSR-2 for FY 2024-25 must be completed by 31st December 2025. Missing this date triggers late fees that compound daily, and persistent non-filing opens the company and its officers to adjudication proceedings by the Registrar of Companies.

CSR-2 filing is the formal annual disclosure mechanism under Section 135 of the Companies Act, 2013. Before the 2021 amendment, companies included CSR disclosures in their Directors' Report, but there was no standalone MCA form. The introduction of Form CSR-2 as a separate, mandatory disclosure created a dedicated, verifiable record of every company's CSR compliance that the Ministry of Corporate Affairs can review independently.

The requirement applies to all companies that meet the Section 135 threshold — net worth of Rs. 500 crore or more, turnover of Rs. 1,000 crore or more, or net profit of Rs. 5 crore or more in any preceding financial year. Once a company crosses any one threshold, it must file CSR-2 for every subsequent year the obligation continues. There is no exemption even in years where actual CSR expenditure is zero — the non-spending must be disclosed and explained.

CSR-2 Filing as Part of Annual ROC Compliance

Form CSR-2 is submitted as a linked form to the company's annual return (MGT-7 or MGT-7A) and financial statement filing (AOC-4). The filing must be consistent with the CSR disclosure in the Directors' Report — any discrepancy is a compliance red flag. Our annual filings team coordinates both the Directors' Report CSR section and the standalone CSR-2 filing to ensure they align precisely before submission.

The CSR-2 form due date India is 31st December of the year immediately following the financial year to which the filing relates. For companies on an April–March financial year: FY 2023-24 was due by 31st December 2024; FY 2024-25 is due by 31st December 2025; FY 2025-26 will be due by 31st December 2026. The filing window opens after the annual return and financial statements are filed, and CSR-2 is submitted as a linked addendum. Companies should not wait until the last week — the MCA portal can be congested in December, and last-minute errors are hard to fix under deadline pressure.

Late Filing Fees After the Due Date

Once the due date passes without a successful submission, late fees begin at Rs. 100 per day for each day of delay, on top of the normal filing fee. For a company that delays by 90 days, this can translate into Rs. 9,000 in late fees alone — before considering the risk of ROC scrutiny that prolonged non-filing triggers.

The MCA designed Form CSR-2 to give a complete picture of the company's Section 135 compliance. Every filing must include:

• Composition of the CSR committee — names of directors, whether independent, and dates of committee meetings during the year.
• Link to the CSR policy published on the company website.
• Details of the impact assessment framework, if applicable (mandatory for companies with a CSR obligation above Rs. 10 crore).
• Average net profit for the preceding three financial years, computed under Section 198.
• Prescribed CSR spending amount for the year — 2% of the average Section 198 net profit.
• Amount actually spent during the financial year on CSR activities.
• Project-wise details — name, Schedule VII category, location, implementing agency name and CSR-1 registration number, amount allocated, amount disbursed.
• Amount transferred to the Unspent CSR Account and the reason for non-spending.
• Details of prior year unspent CSR amounts and their current status.
• Whether the disclosure is certified by a practising CA or CS, where applicable.

Every item must match the corresponding entry in the Directors' Report CSR section. Inconsistencies between the two on the MCA portal are a common trigger for ROC notices — our team cross-verifies both documents before submission.

The penalty operates on two levels. The first is the late filing fee on the MCA portal — Rs. 100 per day from the day after the due date until actual filing. The second, more serious level is the adjudication risk under Section 86(5) of the Companies Act, 2013, which provides for prosecution of officers in default for non-filing of required MCA forms. For companies that have also failed to meet their CSR spending obligation under Section 135, the penalty for non-spending is entirely separate and can reach up to Rs. 1 crore for the company plus personal penalties on officers.

ROC Scrutiny Triggered by Late or Missing Filing

The Registrar of Companies tracks CSR-2 compliance and follows up on missing submissions. A company meeting the Section 135 threshold that fails to file on time may receive an ROC notice asking for the filing and an explanation. Repeated failure, or filing with materially incorrect information, can escalate to compounding proceedings before the NCLT — where the penalty is substantially higher than the standard late fee.

Impact Assessment for Large CSR Spenders

Companies whose CSR obligation for a year exceeds Rs. 10 crore must conduct an impact assessment through an independent agency and include the report in their disclosure and filing. Introduced by the 2021 amendment, this adds a verification layer for large companies. The cost of impact assessment — up to 5% of total CSR expenditure subject to a maximum of Rs. 50 lakh — is also an eligible CSR expense.

The same errors recur across CSR-2 drafts, either causing MCA portal rejection or creating problems during ROC scrutiny:

• Incorrect Section 198 net profit — using accounting profit instead of the Section 198 computation, understating the CSR obligation.
• Missing CSR-1 registration numbers — a mandatory field that, if blank, flags the related spending as potentially invalid.
• Mismatch with the Directors' Report — amounts, project names, or agency details differ between the two documents.
• Unspent CSR Account balance not disclosed — often omitted by companies that did not fully spend, which the ROC treats as a material omission.
• Due date missed because annual return not filed first — CSR-2 cannot be linked without a filed annual return.
• Impact assessment report not included — for companies with a CSR obligation above Rs. 10 crore.

We provide end-to-end support for companies across Mumbai and India, beginning 60 to 90 days before the due date to allow adequate time for review and correction. We start by computing the Section 198 net profit, calculating the 2% obligation, and reconciling it against actual CSR spending during the year. We then collect and verify all project-wise data, confirm CSR-1 registration numbers for every implementing agency, and check that the Unspent CSR Account is correctly set up and funded where required.

Once the data is verified, we prepare the CSR disclosure section for the Directors' Report in parallel with the CSR-2 form, ensuring they are consistent, then file on the MCA portal with the company's authorised signatory's DSC and provide the SRN as confirmation. For companies that have not met their CSR obligation and need guidance on the Unspent CSR Account or remedial options, our company compliance team and MCA services team work together to assess the best path forward. Reach out through our consultation page for an immediate assessment.