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Guide3 min readPublished

Form CSR-2: audit considerations on the MCA CSR report

What an auditor checks before Form CSR-2 is filed with the MCA, including its relationship to the board's report CSR annexure and the figures it must reconcile against.

Form CSR-2 is a separate report on corporate social responsibility that companies to which section 135 applies file electronically with the Registrar, generally after the annual filing of financial statements and typically as an addendum rather than alongside Form AOC-4, and an auditor's role before it is filed is to confirm every figure in it, including the CSR obligation computation, amount spent, amount unspent and its transfer details, and ongoing project disclosures, reconciles exactly to the CSR annexure already disclosed in the board's report and to the audited financial statements, since CSR-2 has no independent basis of its own and should never show a different number from what was already reported and audited; the exact filing timeline and form structure should be confirmed against the current MCA notification.

Why CSR-2 is a reconciliation exercise, not a fresh computation

The board's report for a company to which section 135 applies already carries a detailed CSR annexure covering the obligation computation, committee composition, amount spent against each project, and unspent amount details. CSR-2 asks for substantially the same information in a structured, filterable electronic format the MCA can use to track CSR compliance across companies at scale. Because it is filed separately and often after the main annual filing, there is a real risk of it being populated independently by someone who was not involved in finalising the board's report annexure, which is exactly how the two documents can end up disagreeing.

Testing approach

  1. 01Line up the CSR-2 draft against the board's report CSR annexure field by fieldConfirm average net profit, the two percent obligation, amount spent on each project, administrative overhead, and unspent amount figures match exactly; any figure that differs needs a specific explanation, not a silent override.
  2. 02Confirm project-wise details match the annual action plan and the ongoing/non-ongoing classification used elsewhereThe same classification used for the unspent CSR account transfer and the CARO unspent CSR clause should carry through to CSR-2 without being reclassified for this filing.
  3. 03Check the filing window and sequencingCSR-2 is typically required to be filed after the financial statements are filed in Form AOC-4, within a separately notified window; confirm the company's filing sequence and timing against the current requirement rather than assuming it is filed simultaneously.
  4. 04Confirm impact assessment disclosures, if applicable, are consistentCompanies above the prescribed threshold that are required to carry out an impact assessment should show consistent figures for impact assessment cost and findings across the board's report annexure and CSR-2.

Because CSR-2 is filed after the main annual filing, a late correction identified in the board's report annexure after it has already been approved is sometimes carried into CSR-2 without the board's report itself being amended, leaving two official filings on record with different figures; reconcile CSR-2 against the final, approved board's report, not an earlier draft.

Regulatory requirement

The exact filing timeline, form structure and the companies required to file CSR-2 are set out in the Companies Act rules and the MCA's notifications on CSR reporting as currently in force. Confirm all of these against current source material before filing.

This is practical guidance written for audit teams, not an authoritative statement of any standard or statute. Standards, forms and timelines change. Check the current text issued by the ICAI and the relevant authority before relying on anything here in an audit file.

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