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
- 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.
- 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.
- 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.
- 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.
Related resources
- CARO & Companies ActSecretarial compliance checklist for a statutory auditorBoard meeting frequency, statutory registers and ROC filing timeliness, read as evidence of compliance culture rather than a secretarial checklist in its own right.
- CARO & Companies ActBooks of account compliance under the Companies ActWhat proper books of account require under the Companies Act, the audit-trail-software requirement, and how to test whether it is actually switched on.
- CARO & Companies ActCARO 2020 reporting checklist for statutory auditorsThe topic areas CARO reporting covers, what evidence each one needs, and how the clauses fit together across the audit file.
- Payroll & employee costDirector remuneration audit under the Companies ActManagerial remuneration limits and approvals, financial statement disclosure, and testing payments against board and shareholder resolutions.
Free tools, no signup
Each one reads a file entirely in your browser — or, for two of them, just answers a few questions — and nothing is ever uploaded.
- Purchase register checkDuplicate payments, round-sum amounts, weekend-dated invoices, incomplete records.
- GSTR-2B reconcilerMatches your purchase register against GSTR-2B — missing invoices either side, amount mismatches.
- Bank reconciliation checkerMatches your cash book against a bank statement — what's outstanding on each side.
- Fixed asset register checkDuplicate asset codes, missing location or useful life, negative net book value.
- Payroll red-flag scannerBank accounts shared across employees, and records missing an ID, PAN or salary.
- CARO applicability checkerAnswer a few questions about the company and see which CARO 2020 clauses likely apply.
- MSME payment delay checkerMSME-flagged invoices paid — or still unpaid — beyond the 45-day Section 22 limit.
- Related-party transaction screenerTransactions above a threshold you set with no approval reference, grouped by counterparty.
- Depreciation useful life checkerCompares a useful life in use against the Schedule II, Part C indicative figure.
- Materiality calculatorOverall and performance materiality against PBT, revenue, assets or equity, with reasoning shown.
- Sample size calculatorStatistical sample size for a test of controls or a substantive test of detail.