Last reviewed: 17 September 2026. If your company crossed a net-worth, turnover or profit threshold last year, a CSR obligation may already be running — and Form CSR-2 is where that obligation gets reported to the Registrar. It is easy to file AOC-4 on time and still miss CSR-2 because it follows a separate, later timeline. Here is what CSR-2 covers, who must file it, how it relates to AOC-4, and the two very different penalty risks involved.
What is Form CSR-2?
Form CSR-2 is prescribed under Rule 12(1B) of the Companies (Accounts) Rules, 2014. It is a reporting form on Corporate Social Responsibility (CSR) — the CSR Committee's composition, the CSR obligation computed for the year, the amount actually spent, and how any gap between the two was handled. It is filed as an addendum to Form AOC-4 (or AOC-4 XBRL, or AOC-4 NBFC for NBFCs), not as an independent annual return the way MGT-7 or AOC-4 itself are. A company that has no CSR obligation for a year does not need to file CSR-2 for that year.
Who must file CSR-2: the applicability thresholds
Section 135(1) of the Companies Act, 2013 fixes CSR applicability by reference to the immediately preceding financial year. Meeting any one of the three conditions below is enough to bring a company under CSR obligations, and therefore under the CSR-2 filing requirement.
| Criterion (preceding FY) | Threshold |
|---|---|
| Net worth | Rs 500 crore or more |
| Turnover | Rs 1,000 crore or more |
| Net profit | Rs 5 crore or more |
A company meeting any one of these thresholds must spend at least 2% of its average net profit of the preceding three financial years on CSR activities, constitute a CSR Committee (a lower-profit exemption applies where the mandated spend is under Rs 50 lakh), put a CSR Policy in place, and report on all of this every year — with CSR-2 being the vehicle for that report.
How CSR-2 relates to AOC-4: two filings, two timelines
This is where companies most often trip up. AOC-4 (the financial statements filing) is due within 30 days of the AGM, in the ordinary course. CSR-2, however, is filed separately and generally later — companies file their main AOC-4 first, and then file CSR-2 by a due date notified independently by the MCA for that filing season. Our detailed guide to AOC-4 and MGT-7 due dates and penalties covers the standard annual filing timeline; CSR-2 sits alongside that timeline but does not share its deadline. Treating CSR-2 as "done" simply because AOC-4 was filed on time is a common and avoidable mistake.
If your company has pending AOC-4 or MGT-7 filings from an earlier year, note that a reduced-fee window such as the one covered in our MCA CCFS-2026 pending ROC returns guide is specific to those forms — it does not automatically extend to CSR-2, so each form's own due date and fee exposure needs to be checked independently.
What CSR-2 actually reports
Beyond a simple yes/no on CSR applicability, CSR-2 requires companies to report:
- Composition of the CSR Committee (or confirmation that one is not required).
- The average net profit computation used to arrive at the 2% obligation.
- The prescribed CSR amount for the year, and the amount actually spent.
- Any set-off of excess CSR spent in an earlier year against the current year's obligation.
- Amounts carried forward to an "Unspent CSR Account" for ongoing projects, or transferred to a specified fund for other shortfalls.
- A break-up between ongoing multi-year projects and one-off (non-ongoing) projects.
- Reasons for any shortfall in CSR spending for the year.
When is CSR-2 due? Be careful with assumed dates
Unlike AOC-4's fixed 30-days-from-AGM rule, CSR-2's due date is notified separately by the MCA for each filing cycle, and it has genuinely moved in recent years rather than following a predictable calendar slot. As one concrete example, the CSR-2 due date for FY 2023-24 was extended to 30 June 2025, well after the corresponding AOC-4 filings were already done. Given this pattern of extensions, we deliberately do not state a fixed CSR-2 due date for FY 2025-26 in this article — instead, always check the current MCA circular or the MCA portal for the live due date before planning around a specific calendar date.
Two different penalties — do not conflate them
CSR-2 carries two entirely separate sources of penalty exposure. Confusing them leads companies to either under-react to a genuine CSR shortfall or over-react to an ordinary filing delay.
| Delay in filing the CSR-2 form | Shortfall in actual CSR spending | |
|---|---|---|
| Legal basis | Section 403 (additional-fee ladder for MCA e-forms) | Section 135(7) |
| What triggers it | Filing the CSR-2 addendum after its notified due date | Not spending the mandated 2% CSR amount and not validly carrying it forward or transferring it |
| Who bears it | The company, via escalating additional fees on the e-form | The company: twice the unspent amount or Rs 1 crore, whichever is less. Every officer in default: one-tenth of the unspent amount or Rs 2 lakh, whichever is less |
In short: filing CSR-2 late is a form-compliance lapse with an additional-fee consequence. Not spending the required CSR amount (without a valid carry-forward or transfer) is a substantive lapse under Section 135(7) with its own, separate penalty on the company and its officers. A company can face one, the other, or both in the same year.
Who is not covered: the three-year exit rule
CSR applicability is not permanent once triggered. If a company stops meeting all three thresholds in Section 135(1) — net worth, turnover and net profit — for three consecutive financial years, it is no longer required to comply with the CSR provisions: no CSR Committee, no 2% spend, no CSR-2 filing, until it meets the criteria again in a subsequent year. This is genuinely useful for a company whose profit or turnover has declined, since the obligation does not lapse after a single lower-profit year — it takes three consecutive years below threshold.
Common mistakes companies make with CSR-2
- Assuming CSR-2 shares the same due date as AOC-4 and missing the separately notified CSR-2 deadline.
- Filing CSR-2 based on the current year's profit figures instead of the average net profit of the preceding three financial years.
- Not distinguishing "ongoing project" unspent amounts (which can be carried forward) from other shortfalls (which must be transferred to a specified fund within six months).
- Treating a one-year dip below the Section 135(1) thresholds as an automatic exemption, when the exemption requires three consecutive years below threshold.
- Confusing the CSR-2 late-filing fee with the CSR-shortfall penalty and addressing only one of the two exposures.
Frequently asked questions
Is Form CSR-2 a separate annual return, like AOC-4 or MGT-7?
No. CSR-2 is not a standalone annual return. It is filed as an addendum to Form AOC-4 (or AOC-4 XBRL / AOC-4 NBFC, as applicable) under Rule 12(1B) of the Companies (Accounts) Rules, 2014, and reports specifically on a company's CSR obligation and spending for the year.
Which companies are required to file CSR-2?
A company must comply with CSR provisions, and therefore file CSR-2, if in the immediately preceding financial year it had a net worth of Rs 500 crore or more, or a turnover of Rs 1,000 crore or more, or a net profit of Rs 5 crore or more, per Section 135(1) of the Companies Act, 2013. Meeting any one of these three thresholds is enough to trigger the requirement.
What is the due date for filing CSR-2?
CSR-2 is filed after the main AOC-4 for the year, on a date separately notified by the MCA — it is not fixed to the standard 30-days-from-AGM timeline that applies to AOC-4. In recent years this date has been extended more than once; for example, the CSR-2 due date for FY 2023-24 was pushed to 30 June 2025. Always confirm the live due date from the current MCA circular before relying on any specific date.
What happens if CSR-2 is filed late?
A delay in filing CSR-2 is treated like a delay in the underlying financial-statement filing and attracts additional fees under Section 403, on the same escalating fee ladder that applies to other MCA e-forms such as AOC-4 and MGT-7. This late-filing fee is separate from any penalty relating to an actual CSR spending shortfall.
Is there a separate penalty if a company does not spend the required 2% on CSR?
Yes, and it is distinct from the CSR-2 filing fee. Under Section 135(7), if the mandated CSR amount is not spent (and not validly transferred to an unspent CSR account or a specified fund), the company can be penalised twice the unspent amount or Rs 1 crore, whichever is less, and every officer in default can be penalised one-tenth of the unspent amount or Rs 2 lakh, whichever is less.
If a company crosses the CSR threshold only once, must it keep complying every year?
Not indefinitely. A company that stops meeting the Section 135(1) thresholds for three consecutive financial years is not required to comply with the CSR provisions — including constituting a CSR Committee and spending 2% of average net profit — until it meets the criteria again in a later year.
Can unspent CSR money be carried forward instead of being treated as a shortfall?
Yes, subject to conditions. Unspent amounts relating to an ongoing project can be transferred to a special "Unspent CSR Account" and spent within the following three financial years. Amounts not linked to an ongoing project must instead be transferred to a specified fund (such as the PM CARES Fund or a Schedule VII fund) within six months of the financial year-end. CSR-2 requires this position — spent, carried forward, or transferred — to be reported and reconciled.
We help companies map their CSR applicability, reconcile CSR spend against the 2% obligation, and keep AOC-4, MGT-7 and CSR-2 filings on schedule.
ROC Filing Services Bookkeeping & Compliance Support Contact UsThis article is for general information and does not constitute legal or professional advice. CSR-2 due dates are notified and revised by the Ministry of Corporate Affairs from time to time and have been extended in past filing cycles — please confirm the current due date from the applicable MCA circular or the MCA portal before relying on any date mentioned here, and consult us for guidance specific to your company's facts.