CSR-1 Registration Checklist for NGOs Seeking Corporate Funding

CSR-1 Registration Checklist for NGOs Seeking Corporate Funding

A complete CSR-1 registration checklist for NGOs should cover legal eligibility, 12A/12AB and 80G status, authorised signatory details, digital signatures, supporting documents and MCA portal filing. CSR-1 registration is required for eligible implementing agencies that want to undertake CSR activities for companies in India, but it does not itself guarantee CSR funding or corporate donations.

NGOs often lose time because they treat CSR-1 as a general NGO registration. It is not. CSR-1 is a compliance filing under India’s Companies Act framework that allows an eligible organisation to receive a unique CSR Registration Number after registering on the Ministry of Corporate Affairs (MCA) portal.

This guide explains what to check before filing, what documents to prepare, how the process generally works and what an NGO should do after receiving its CSR Registration Number.

What Is CSR-1 Registration?

CSR-1 is an electronic form filed with the MCA by organisations that intend to undertake CSR activities as implementing agencies for companies.

Under the Companies Act, 2013 and the Companies (CSR Policy) Rules, companies that fall within the prescribed CSR provisions must spend on eligible CSR activities. A company may carry out these activities itself or work through an eligible implementing agency such as a Section 8 company, registered public trust or registered society.

The CSR-1 filing helps the MCA maintain a record of organisations that are eligible to implement CSR projects. Once the form is accepted, the organisation receives a CSR Registration Number.

This number may be requested by companies during their due diligence before they approve a project or release CSR funds. It is therefore an important part of an NGO’s corporate fundraising documentation.

However, CSR-1 does not mean:

• The NGO is automatically approved for CSR funding.
• The organisation will receive money from the government.
• The NGO is registered under the Foreign Contribution Regulation Act.
• The NGO is registered on NGO Darpan.
• The organisation can use donations for any activity without project-level approvals.
• A company must fund the organisation after registration.

CSR-1 is one compliance requirement among several. Companies will usually also review the NGO’s work, governance, audited accounts, project plans, impact measurement, statutory registrations and ability to submit reports.

Who Needs to File CSR-1?

An organisation generally needs CSR-1 if it wants to act as an implementing agency for CSR projects funded by companies covered by the CSR provisions.

Eligible categories commonly include the following:

• A company established by the company itself or jointly with another company to undertake CSR activities.
• A Section 8 company.
• A registered public trust.
• A registered society.
• An entity established by the Central Government or a State Government.
• Certain entities exempt under Section 10(23C) of the Income-tax Act.
• Certain entities registered under Section 12A or 12AB and approved under Section 80G of the Income-tax Act, subject to the applicable conditions.

For many independent NGOs, eligibility depends on having valid income-tax registrations and, where required, a track record of carrying out similar activities.

The exact eligibility position can depend on the organisation’s legal form, date of registration, registrations held and the nature of the proposed CSR work. Rules and MCA forms can also be updated. An NGO should therefore verify the current form instructions and, where necessary, obtain advice from a practising Company Secretary, Chartered Accountant or other qualified professional.

The three-year track record requirement

For several categories of independent implementing agencies, the rules refer to a track record of at least three years in undertaking similar activities.

This does not simply mean that the NGO has existed for three years. The organisation may need to demonstrate that it has actually carried out activities similar to the CSR project it proposes to implement.

For example, an organisation seeking CSR funding for a school education programme should be able to show relevant work in education, learning support, teacher training, scholarships or a closely related field. A general statement that the NGO has worked in “social development” may not be enough for a company’s due diligence.

Useful evidence may include:

• Annual reports.
• Project completion reports.
• Photographs and beneficiary records.
• Previous grant agreements.
• Audited utilisation statements.
• Letters from institutional donors.
• Monitoring reports.
• Publications or programme material.
• Details of locations, activities and beneficiaries.

A newly formed NGO may still be able to receive donations or grants through other routes, depending on the donor and the legal structure. But it should not assume that it qualifies to act as an independent CSR implementing agency before checking the track record requirement.

CSR-1 Registration Checklist for NGOs

Use the following checklist before beginning the MCA filing.

1. Confirm the organisation’s legal structure

Start with the organisation’s incorporation or registration documents. The name and legal form in these documents must match the information entered in the CSR-1 form.

Keep the relevant document ready:

• Section 8 company: Certificate of Incorporation and related MCA records.
• Public trust: Trust deed and registration certificate or order issued by the relevant authority.
• Society: Registration certificate and memorandum or rules and regulations.
• Government-established entity: Establishment notification, statute or relevant government document.
• Other eligible entity: Documents supporting the specific category under which it is filing.

Check spelling, punctuation, registered address and registration numbers. Differences between the registration certificate, PAN, income-tax records and MCA records can lead to questions or resubmission.

2. Check PAN and income-tax details

The organisation should have a valid PAN in its legal name. The PAN details should match the organisation’s statutory records.

Keep these details available:

• PAN of the organisation.
• Date of incorporation or registration.
• Income-tax jurisdiction, where relevant.
• 12A or 12AB registration details.
• 80G approval details.
• Copies of income-tax orders or certificates.
• The validity period of the applicable registrations.

The old terminology of “12A registration” is still commonly used, but many organisations now operate under registration or provisional registration under Section 12AB. Use the terminology and details shown in the current income-tax order.

For CSR-1 purposes, the NGO should not rely only on an expired or provisional document without checking whether renewal or conversion is required. Corporate donors commonly examine whether the organisation’s tax registrations are active on the date of due diligence.

3. Verify 80G status

An NGO seeking corporate donations should pay close attention to its 80G status.

An 80G approval is relevant to tax-deductible donations, but it does not by itself make an organisation eligible for CSR implementation. Depending on the organisation’s category, the rules may also require 12A/12AB registration, a minimum track record and other conditions.

Prepare:

• 80G approval or registration order.
• Current validity details.
• Any renewal, revalidation or modification order.
• PAN-linked information.
• Details of the authorised person handling tax compliance.

Do not present an old 80G certificate as current without checking its status on the income-tax portal or with the organisation’s tax adviser.

4. Check the three-year activity record

Prepare a simple internal summary of the organisation’s relevant work for the applicable period.

The summary should show:

The record should relate to the activities the organisation plans to offer to corporate partners. A company may ask for evidence beyond what is submitted in CSR-1.

5. Identify the authorised signatory

The NGO must identify the person authorised to submit the form and make declarations on behalf of the organisation.

Depending on the legal structure, this may be a director, trustee, office bearer or another authorised representative. The organisation should have an internal resolution, authorisation letter or governing-body approval supporting that person’s authority.

Keep the following ready:

• Full name.
• Designation.
• PAN or other required identity information.
• Mobile number.
• Email address.
• Board, trustee or managing committee authorisation.
• Digital Signature Certificate, where required.

The authorised signatory should use an email address and mobile number that the organisation can access after filing. Avoid using the personal email address of a volunteer who may leave the organisation.

6. Arrange a valid Digital Signature Certificate

CSR-1 is filed electronically. A valid Digital Signature Certificate (DSC) is generally required for the authorised signatory and for professional certification, as applicable.

Before filing, check:

• Whether the DSC is active.
• Whether it is registered on the MCA portal.
• Whether the signatory’s details match the records.
• Whether the correct DSC token or signing utility is available.
• Whether the browser and MCA tools support the signing process.

Digital signatures can fail because of an expired certificate, an incorrect user profile, a missing driver or mismatched PAN details. It is better to test the signing process before the final filing date.

7. Prepare governing-body details

The form may require information about directors, trustees, governing-body members or other responsible persons.

Keep a current list containing:

• Name.
• Designation.
• Identification details where required.
• PAN, where applicable.
• Address or contact information, if requested.
• Date of appointment or association, where relevant.

The information should be consistent with the organisation’s latest annual records. If a trustee or office bearer has changed, update the organisation’s internal and statutory records before submitting the form.

8. Gather registration and address proofs

Maintain a document folder with:

• Certificate of registration or incorporation.
• Trust deed, memorandum or articles.
• Rules and regulations or bye-laws.
• PAN card.
• Registered office address proof.
• 12A/12AB documents.
• 80G documents.
• Details of governing-body members.
• Authorisation or resolution.
• Previous financial statements.
• Activity reports.

The exact attachments required may vary depending on the current MCA form and the organisation’s category. Do not attach irrelevant documents merely to make the submission appear larger. Corporate donors generally prefer a clear, indexed compliance file.

CSR-1 Documents Required: Practical Preparation

The CSR-1 filing and corporate due diligence are related but not identical.

The MCA form focuses on registration and eligibility information. A corporate donor may request a much broader package before signing a CSR agreement.

This distinction matters. An NGO may successfully file CSR-1 but still be unable to pass a company’s internal due-diligence process because its accounts, governance policies or project documentation are incomplete.

How to File CSR-1 on the MCA Portal

The filing process can change when the MCA updates its forms or portal systems. The broad process generally involves the following steps.

Step 1: Review current MCA instructions

Before starting, check the current MCA portal, form version and instruction kit. Do not rely on an old PDF, a previously completed form or an informal checklist without confirming that the requirements remain current.

The organisation should also check whether the filing is to be made through a web-based form, an electronic form or another MCA workflow.

Step 2: Create or verify the MCA user account

The person handling the filing may need an MCA login. Verify that the registered email address, mobile number and user role are active.

If a professional is assisting with the filing, decide in advance who will control the login and receive notifications. The NGO should retain access to its own MCA account and filing records.

Step 3: Enter organisation details

Enter the legal name, registration number, PAN, address, incorporation or registration date and other requested information exactly as shown in the supporting documents.

Common causes of delay include:

• Using a short name instead of the registered legal name.
• Entering the trust’s operating name instead of the registered name.
• Using an old address.
• Entering an incorrect registration number.
• Selecting the wrong entity category.
• Uploading a document for a different legal entity.

Step 4: Enter tax and eligibility details

Provide the relevant 12A/12AB and 80G information, along with details of the organisation’s eligibility category and activity track record where requested.

Review dates carefully. A registration number without the correct order date or validity information may create a mismatch during verification.

Step 5: Enter authorised signatory information

Add the authorised person’s details and attach or refer to the required authorisation. The signatory should confirm that the organisation is eligible and that the information submitted is accurate.

False declarations can create legal and compliance problems. If the organisation is uncertain about eligibility, it should resolve that question before filing rather than relying on a later correction.

Step 6: Sign and obtain professional certification

The authorised person signs the form using the DSC. The form may also require certification by a practising professional, such as a Chartered Accountant, Company Secretary or Cost Accountant, according to the applicable MCA requirements.

Professional certification is not a substitute for checking the organisation’s information. The NGO’s management remains responsible for the accuracy of its records and declarations.

Step 7: Submit and retain the acknowledgement

After submission, save:

• SRN or service request number.
• Filed form.
• Challan or payment acknowledgement, if applicable.
• Attachments.
• Certification details.
• MCA email or approval communication.
• CSR Registration Number, once generated.

Create a compliance folder with the filing year and legal name. A corporate donor may ask for the CSR-1 approval or registration number months after the original filing.

What Happens After CSR-1 Registration?

After successful filing, the organisation receives a CSR Registration Number. Share this number with prospective corporate partners as part of the compliance pack.

The number should be used consistently. Avoid creating different versions of the organisation’s name in proposals, invoices, MoUs and reports.

CSR-1 registration is only the beginning of corporate fundraising. A company may still assess:

• Whether the project fits its CSR policy.
• Whether the activity falls within Schedule VII of the Companies Act.
• Whether the NGO has relevant programme expertise.
• Whether the beneficiaries and locations are clearly defined.
• Whether the budget is reasonable and supported.
• Whether the NGO can monitor outcomes.
• Whether financial controls are adequate.
• Whether related-party or conflict-of-interest concerns exist.
• Whether reporting and utilisation requirements can be met.

Keep the compliance file updated

Review the following periodically:

• 12A/12AB status.
• 80G status.
• FCRA status, if applicable.
• Registered office address.
• Trustees, directors or governing-body members.
• Bank account details.
• Audited accounts.
• Annual returns and statutory filings.
• Board or trustee authorisations.
• CSR project records.

If a major legal detail changes, assess whether any MCA or donor update is required. The CSR-1 number should not be treated as a permanent substitute for ongoing compliance.

CSR Funding, FCRA and NGO Darpan: Do Not Confuse Them

NGOs frequently combine separate registrations in one “funding compliance” list. Each serves a different purpose.

CSR-1 and FCRA

CSR-1 is associated with implementing eligible CSR projects for companies under the Indian CSR framework.

FCRA registration or prior permission concerns the receipt and use of foreign contribution. If the source of funds is a foreign company, foreign foundation or another foreign source, the NGO must examine whether the contribution qualifies as foreign contribution and whether FCRA compliance applies.

CSR-1 does not permit an NGO to receive foreign contribution. Similarly, FCRA registration does not automatically make the organisation eligible to implement CSR projects.

The NGO should identify the actual source of funds, the contracting entity and the bank account through which money will be received before accepting a grant.

CSR-1 and NGO Darpan

NGO Darpan is a separate government platform associated with information about voluntary organisations. Some government departments, donors and corporate foundations may request an NGO Darpan ID during their due diligence.

An NGO Darpan registration does not replace CSR-1. If a company asks for both, the organisation should provide both separately.

CSR-1 and 80G

80G approval may help donors claim applicable tax benefits, subject to the law and documentation. It is not a permission to conduct CSR activities and does not guarantee funding.

The organisation should issue donation receipts and maintain records according to applicable tax requirements. CSR grants may also be governed by a detailed agreement rather than a simple donation receipt.

Common Mistakes in CSR-1 Registration

Filing under the wrong legal entity

A trust may operate a brand name that differs from its registered name. Filing using the brand name instead of the legal name can create inconsistencies.

Use the exact entity that will sign the CSR agreement, receive the funds and implement the project.

Treating CSR-1 as a funding application

CSR-1 is a registration and eligibility filing. It is not an application for a grant.

The NGO still needs a credible proposal, budget, implementation plan and reporting system.

Ignoring the activity track record

A broad list of objectives in the trust deed does not prove that the organisation has carried out similar activities. Maintain evidence of actual work and explain how it relates to the proposed CSR project.

Using expired tax documents

Old 12A, 12AB or 80G documents can create problems during company due diligence. Check current validity and keep renewal or revalidation records.

Not checking the bank account

The account receiving CSR funds should be held in the legal name of the organisation and used with proper financial controls. Avoid receiving project money in a personal account or in an account belonging to an informal programme group.

Weak project records

Companies often require budgets, utilisation certificates, invoices, attendance records, photographs, beneficiary data and progress reports. Begin maintaining these records before the first CSR grant, not after an audit query.

Promising tax benefits or outcomes carelessly

An NGO should not promise that a donor will receive a particular tax treatment or that a project will achieve a fixed social outcome. Use careful, evidence-based language and refer tax questions to the donor’s adviser.

Frequently Asked Questions

Is CSR-1 registration compulsory for every NGO?

No. CSR-1 is relevant to eligible entities intending to undertake CSR activities as implementing agencies for companies. An NGO that only receives ordinary individual donations or grants outside the CSR framework may not need CSR-1 for that purpose, but it should assess its position before accepting a CSR project.

Can a new NGO file CSR-1 without three years of experience?

The answer depends on the organisation’s legal category and the applicable CSR rules. For several independent implementing-agency categories, a track record of at least three years in similar activities is relevant. A new NGO should not assume that incorporation alone is enough; it should obtain professional advice based on its structure and proposed role.

Does CSR-1 guarantee corporate funding?

No. CSR-1 only supports the organisation’s eligibility and compliance profile. Companies still select projects based on their CSR policy, geography, thematic priorities, due diligence, budgets and internal approval process.

Is FCRA registration required to receive CSR funding?

Not automatically. CSR funding from an Indian company may not be foreign contribution merely because the company has foreign shareholders or an international group connection. However, the source and legal character of the money must be examined carefully; CSR-1 cannot replace FCRA registration or prior permission where FCRA applies.

Can an NGO use CSR-1 for donations from individuals?

CSR-1 is not a general donation registration. Individual donations are governed by other tax, accounting and receipt requirements. The NGO may mention its CSR-1 status in its institutional profile, but it should not represent the number as approval for all types of fundraising.

What should an NGO do if its CSR-1 filing has an error?

First, identify whether the error concerns a minor data mismatch, an attachment, professional certification or the organisation’s underlying eligibility. Save the filing acknowledgement and review the current MCA correction or resubmission process. For material errors, consult a practising professional before making another submission.

Where to Start

Begin by confirming the legal entity that will implement the project and receive the funds. Then collect the registration certificate, PAN, 12A/12AB and 80G records, governing-body details, activity evidence, authorisation and digital signature information.

Next, verify the three-year similar-activity requirement where it applies, review the latest MCA instructions and prepare a separate corporate due-diligence folder containing audited accounts, annual reports, policies, project proposals and reporting formats.

Govindani Infotech can help with document organisation, website and digital systems used by NGOs; CSR-1 eligibility and statutory filing should be confirmed with a qualified compliance professional. For support with your organisation’s digital requirements, talk to the team on WhatsApp; service pricing is confirmed there after understanding the requirement.