CSR-1 Registration Under the 2025 Amendments: What Companies and Implementing Agencies Need to Know

An entity that wants to receive CSR funds must register on Form CSR-1 (Rule 4(2), CSR Rules, 2014). MCA replaced that form in July 2025, and the position has shifted again in 2026.

What changed in 2025

The Companies (CSR Policy) Amendment Rules, 2025 (G.S.R. 452(E), notified 7 July 2025) took effect on 14 July 2025. They substituted a new web-based e-form CSR-1, with these features:

• PAN, OTP-verified email IDs and the DSC of the authorised officer are mandatory.
• The entity must state which eligibility category it relies on.
• Entities without a company parent must show a three-year track record in similar work.
• A practising CA, CS or CMA must certify the form and bears liability for false certification.

The open question: do existing agencies re-register?

The notification doesn't say whether agencies already holding a CSR registration number must refile. Commentary generally reads existing registrations as continuing, with fresh tie-ups expected to reflect the updated disclosure standard. Companies should confirm an agency's current status themselves rather than assume.

2026 developments

• Rule 4A (27 May 2026, G.S.R. 415(E)): companies may route CSR through zero-coupon zero-principal instruments issued by non-profits registered on the Social Stock Exchange.
  • Spend through this route is capped at 10% of that year's CSR expenditure.
  • It is exempt from impact assessment.
  • Rule 4A(4) excludes Rule 4(5) and (6), so CSR-1 registration is not required for that route.
• Corporate Laws (Amendment) Bill, 2026: introduced 23 March 2026 and pending before a JPC, it proposes to double the CSR net-profit threshold from ₹5 crore to ₹10 crore. It is not law.

For companies

1. Verify the agency's CSR registration number on the MCA portal, not just from its certificate.
2. Record the CSR Committee's reasoning for selecting the agency.
3. Sign a written agreement covering scope, Schedule VII mapping, budget, timelines and reporting.
4. Reflect the 10% ZCZP ceiling if you use that route, and update the CSR policy if it lists permitted modes.
5. Keep an audit trail for CSR-2 reporting.

For implementing agencies

1. Be clear on your eligibility category and keep supporting records ready.
2. Keep PAN, 12A/80G status and governing-body details current.
3. Choose your certifying professional carefully.
4. Check whether your registration needs updating for new projects.

Bottom line

CSR-1 is now a stricter, certified registration, and 2026 adds an optional exchange-linked route. The Bill is worth watching, but plan on current law.