Last reviewed: 24 September 2026. Since 1 April 2021, a company cannot count money given to an NGO as valid CSR spend unless that NGO is registered with the MCA on Form CSR-1 and holds a CSR Registration Number. NGOs that have run programmes for years, with strong 12A/80G standing, are still routinely turned away by corporate CSR desks simply because nobody filed this one additional registration.
Why this exists
Before April 2021, companies could route CSR spend to any NGO with minimal formal verification, which made it hard for the MCA to track where CSR money actually went and easy for shell or low-credibility entities to receive corporate funding. Form CSR-1 registration – and the CSR Registration Number it produces – gives every implementing NGO a traceable identity that companies must cite in their own CSR disclosures (Form CSR-2), closing that gap.
Who is eligible
| Entity type | Core condition |
|---|---|
| Section 8 company | Registered under Section 8 of the Companies Act 2013, with 12A and 80G registration under the Income-tax Act |
| Registered public trust | Registered as a public trust, with 12A and 80G registration |
| Registered society | Registered under the Societies Registration Act (or state equivalent), with 12A and 80G registration |
| Entity established by the funding company/group, or by government | Same entity types as above, but the 3-year track record requirement is waived where the implementing entity was itself set up by the company (or its holding/subsidiary/associate) undertaking the CSR spend, or by Central/State government, or under an Act of Parliament/State legislature |
The general rule requires an established track record of at least three years in undertaking similar activities. This is a genuine filter: a newly formed NGO, however well-intentioned, cannot register on CSR-1 and start receiving CSR funds immediately unless it falls into one of the waiver categories above.
The filing itself
- File Form CSR-1 electronically on the MCA portal, with the entity's PAN, registration details, and 12A/80G registration references.
- The form is digitally signed by an authorised person of the entity (director, trustee, chairman, CEO, or similar, depending on entity type) and, separately, certified by a practising Chartered Accountant, Company Secretary or Cost Accountant.
- On approval, the MCA issues a unique CSR Registration Number, which the NGO then shares with any company considering funding it.
Worked example. A registered public trust running education programmes for eight years, holding valid 12A and 80G registration, applies for CSR-1 well before approaching corporate donors for the next financial year's CSR budget cycle. With the registration number in hand before outreach begins, the trust can be listed as an eligible implementing agency in a funding company's CSR disclosures without delay. Contrast this with a trust that only discovers the requirement after a company has already earmarked funds – the registration itself is quick, but processing time still means funds cannot flow until the number is issued.
Common mistakes
- Assuming 12A and 80G registration alone is sufficient – CSR-1 is a separate, additional registration specifically for CSR fund eligibility.
- Applying for CSR-1 only after a company has already committed funds, causing an avoidable delay in disbursement.
- Not keeping the entity's other filings (annual returns, FCRA if applicable, 12A/80G renewal status) current – a lapsed underlying registration can complicate an otherwise straightforward CSR-1 application or later scrutiny.
- Overlooking that this is entity-specific: if an NGO restructures (for example, converts from a trust to a Section 8 company), the new entity needs its own fresh CSR-1 registration.
- Letting the underlying 80G approval lapse without noticing – a CSR-1 registration sitting on top of an expired 80G status is a real, if under-checked, exposure.
What this does not replace
CSR-1 registration does not substitute for 12A/80G registration, which remains the foundation for both income-tax exemption and donor deduction eligibility generally. It also has nothing to do with FCRA registration, which governs foreign contributions specifically. An NGO actively fundraising from multiple channels – individual donors, corporate CSR, and potentially foreign sources – typically needs all of these registrations maintained in parallel, each serving a different funding channel.
Frequently asked questions
Can a brand-new NGO register for CSR-1 immediately after incorporation?
Generally no, unless it falls under a waiver category (set up by the funding company/group or by government). The standard rule requires an established track record of at least three years undertaking similar activities before CSR-1 registration.
Does CSR-1 registration ensure an NGO will receive CSR funding?
No. CSR-1 makes an NGO eligible to receive CSR funds; it does not create any entitlement or introduce it to donor companies. Registration is a precondition, not a funding mechanism in itself.
How long does CSR-1 approval typically take?
Processing time varies with MCA workload and the completeness of the application; applying well ahead of an anticipated funding cycle, rather than after a company has already committed funds, avoids unnecessary delay.
Is CSR-1 a one-time registration or does it need periodic renewal?
It does not have a routine periodic renewal cycle like an annual filing, but the entity should keep its underlying registrations (12A, 80G, incorporation status) current, since these are the foundation the CSR-1 registration relies on.
Does a Section 8 company need CSR-1 even if it is the company's own CSR arm?
Yes, the entity still needs CSR-1 registration to be a valid recipient, though where it was established by the funding company or its group, the three-year track record condition is waived.
Where can a company verify an NGO's CSR Registration Number before funding it?
Companies typically request the CSR Registration Number directly from the NGO as part of due diligence before committing CSR funds, and reference it in their own CSR disclosures; there is no substitute for asking the NGO to produce its CSR-1 approval directly.
We handle CSR-1 registration alongside your 12A/80G and FCRA compliance.
NGO & Section 8 Compliance ROC Filing Services Talk to usThis article summarises the CSR-1 registration requirement, in force since 1 April 2021, as understood on the date of review. General information, not advice on your specific facts – confirm details against the current forms/portal and consult us or your tax advisor before acting. CA Somesh Chandak & Associates, FRN 158694W.