CSR and Social Governance · CSR Projects and Implementation Agency

Registration of Implementing Agencies Through Form CSR-1

Updated 11 October 2026 · Fact-checked

Form CSR-1 is the electronic form an implementing agency files with the Registrar to register for CSR work. The entity signs it and a practising CA, CS or CWA verifies it digitally. The Registrar then generates a unique CSR Registration Number. A company should fund only registered agencies.

Understand Registration of Implementing Agencies (CSR-1)

A company can spend its CSR money in two ways. It can run the project itself, or it can route the money through an implementing agency. The CSR Policy Rules list the agencies allowed: a Section 8 company, registered public trust or registered society set up by the company; one set up by the Central or State Government; an entity set up under an Act of Parliament or a State legislature; and an outside Section 8 company, trust or society with a track record of at least three years in similar activities.

Rule 4(1) requires a Section 8 company, registered public trust or registered society to hold registration under 12A and 80G. This applies whether it was set up by the company or is an outside entity. The three-year track record applies only to outside agencies. Government-established bodies and statutory bodies are separate categories under the Rule.

The CSR Policy Rules (Rule 4) say every such entity that wants to undertake CSR activity must register with the Central Government. It does this by filing Form CSR-1 electronically with the Registrar. The requirement applies from 1 April 2021.

Why electronic? Section 398 of the Companies Act, 2013 lets the Central Government require filings, and Registrar functions, to be done in electronic form in the prescribed manner. CSR-1 follows that approach. The Registrar's records then act as a public check on who is a genuine CSR implementer.

The form is signed and submitted electronically by the entity. It is then verified digitally by a Chartered Accountant, Company Secretary or Cost and Works Accountant in practice. On receipt, the Registrar registers the entity and generates a unique CSR Registration Number electronically. This number is the entity's identity for CSR purposes.

Keep two things apart. CSR-1 is filed by the implementing agency. The company's own annual CSR reporting is a separate matter and uses a different form (CSR-2). A company that carries out a project directly does not file CSR-1 for itself.

Key rules to remember

Who must register: Every entity in Rule 4(1) that intends to undertake CSR activity must register via Form CSR-1; Applies to implementing agencies, not to the company spending directly. Applicable from 1 April 2021.
Mode of filing: CSR-1 is filed electronically with the Registrar; Rests on the Section 398 approach of electronic filing in the prescribed manner.
Signing and verification: Signed and submitted by the entity + digitally verified by a CA, CS or CWA in practice; The verifier must be a practising professional.
Outcome: Registrar registers the entity and generates a unique CSR Registration Number; The number is generated electronically.
Eligible agency types: Section 8 company / registered public trust / registered society (company-established or outside): 12A and 80G required | Outside agency: also at least 3 years' track record | Government-established body | Statutory body; A Section 8 company, registered public trust or registered society must hold 12A and 80G, whether set up by the company or an outside entity. The 3-year track record applies only to outside agencies. Government-established and statutory bodies are separate categories. Check the exact wording of Rule 4(1) in your material.

How to solve Registration of Implementing Agencies (CSR-1) questions

For any question on CSR-1, first decide whether the entity needs to register at all. Then walk through eligibility, filing and the registration number. Apply the rule to the facts given.

1Identify who is carrying out the project: the company itself or an outside or related entity.
2If the company runs it directly, state that CSR-1 is not needed for the company. If an entity implements it, state that the entity must register.
3Check the entity type against Rule 4(1): Section 8 company, registered public trust or registered society, government-established body or statutory body.
4For a Section 8 company, registered public trust or registered society (company-established or outside), check 12A and 80G registration. Then check whether the entity was established by the company, the government or a statute. If it is an outside agency, check the three-year track record.
5State the procedure: electronic filing of CSR-1 with the Registrar, signed by the entity and digitally verified by a practising CA, CS or CWA.
6State the result: the Registrar generates a unique CSR Registration Number.
7Conclude with the consequence for the company's Board: it should fund only registered, eligible agencies.
8Add a practical point, such as verifying the CSR Registration Number before releasing funds.

Quickest way: Four-line CSR-1 answer

When to use it: Use it for short-note questions or when time is tight in a case question.

Who: any entity implementing CSR for a company, other than the company itself.
What: file Form CSR-1 electronically with the Registrar, from 1 April 2021.
Who certifies: the entity signs; a practising CA, CS or CWA verifies digitally.
Result: a unique CSR Registration Number, which the company checks before funding.

Common mistakes in Registration of Implementing Agencies (CSR-1)

Saying the company must file CSR-1 for its own CSR spend.
Students confuse CSR-1 with CSR-2, the company's reporting form.
Fix: CSR-1 is filed by the implementing entity. CSR-2 belongs to the company's reporting.
Saying any NGO can implement CSR without registration.
Students focus on 12A and 80G and forget the CSR-1 step.
Fix: Tax registrations are not enough. A trust or society with 12A and 80G still needs CSR-1 and a CSR Registration Number.
Applying the three-year track record to every agency.
It is the best-known condition, so it gets over-generalised.
Fix: The track record applies only to an outside Section 8 company, trust or society. It does not apply to entities established by the company, the government or a statute. The 12A and 80G requirement is a separate condition.
Saying a Section 8 company, trust or society set up by the company need not hold 12A and 80G.
Students link 12A and 80G only with outside NGOs.
Fix: Rule 4(1) requires 12A and 80G for a Section 8 company, registered public trust or registered society, whether set up by the company or outside.
Saying anyone can verify the form.
Students forget the professional certification step.
Fix: Write that a CA, CS or CWA in practice verifies it digitally.
Omitting the date and the electronic mode.
Students treat the point as a minor detail.
Fix: Mention filing with the Registrar, electronically, from 1 April 2021. These are easy marks.

Worked examples

Example 1

Prabhat Industries Limited wants to give its CSR funds to Asha Seva Trust, a registered public trust with 12A and 80G registration. The trust was formed two years ago by local teachers and has run rural education programmes since then. It has not filed CSR-1. Advise the Board.

Show the solution

Provision: under the CSR Policy Rules, an outside trust may implement CSR only if it has 12A and 80G registration and an established track record of at least three years in similar activities.
Analysis: the trust has the tax registrations but only two years of experience. It was not established by the company or by the government.
Registration: every implementing entity must also file CSR-1 electronically and obtain a CSR Registration Number. This trust has not done so.
Conclusion: the trust is not presently eligible on two counts, the track record and the missing CSR-1.
Practical point: the Board should not release funds. It may consider the project again once the trust meets the three-year condition and holds a CSR Registration Number, or run the project directly.

Answer: The Board should not fund Asha Seva Trust now. It has only two years of track record against the three required for an outside trust, and it has no CSR-1 registration or CSR Registration Number.

Example 2

Suvidha Foundation, a Section 8 company established by Meridian Textiles Limited, will implement Meridian's CSR projects. The foundation was incorporated six months ago. Is it eligible, and what must it do before receiving funds?

Show the solution

Provision: a Section 8 company established by the company can be an implementing agency under Rule 4(1), provided it holds 12A and 80G registration.
Analysis: the foundation was established by Meridian, so it falls in the company-established category. The three-year track record condition is for outside agencies, so it does not apply here. The 12A and 80G requirement still applies, so the foundation must hold both.
Registration: the foundation must also register by filing Form CSR-1 electronically with the Registrar.
Procedure: the foundation signs and submits the form, and a practising CA, CS or CWA verifies it digitally.
Result: the Registrar registers it and generates a unique CSR Registration Number.
Conclusion: it is eligible by type and needs no track record, but funds should flow only after it holds 12A and 80G and the CSR Registration Number is generated.

Answer: Yes, it can qualify as a Section 8 company established by the company, and the three-year track record is not required. Before receiving CSR funds it must hold 12A and 80G registration, file CSR-1 and obtain a CSR Registration Number.

Exam tips

Case questions usually test whether the agency is eligible and registered. Check type, tax registrations, track record and CSR-1, in that order.
Keep CSR-1 (the agency's registration) and CSR-2 (the company's reporting) clearly apart.
Write the full procedure: electronic filing with the Registrar, signed by the entity, verified by a practising CA, CS or CWA, and a unique number generated.
Close with a practical Board action: verify the CSR Registration Number before releasing funds.

Practice questions from CSR Projects and Implementation Agency

Registration of Implementing Agencies (CSR-1) in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

CMA FinalCSR Implementation, Impact Assessment and Reporting

Registration of Implementing Agencies (CSR-1): frequently asked questions

Is CSR-1 registration mandatory for NGOs?

Yes, for an NGO that wants to implement CSR activity for a company. Every entity covered by Rule 4(1) of the CSR Policy Rules must register through Form CSR-1, from 1 April 2021. Tax registrations alone do not replace it.

How do I get a CSR Registration Number?

File Form CSR-1 electronically with the Registrar. The entity signs and submits it, and a practising CA, CS or CWA verifies it digitally. The Registrar then registers the entity and generates a unique CSR Registration Number.

Who files CSR-1, the company or the implementing agency?

The implementing agency files it. The company only needs to ensure that the agency it funds is eligible and registered. A company carrying out a project itself does not file CSR-1.

Does a company-established trust need three years of experience?

No. The three-year track record applies only to outside agencies. A trust, society or Section 8 company established by the company must still hold 12A and 80G registration and file CSR-1. An entity established by the government or a statute is a separate category and also files CSR-1.