Corporate Social Responsibility (CSR) has become a cornerstone of philanthropic activity in India since the enactment of Section 135 of the Companies Act, 2013. To facilitate transparent and accountable disbursal of CSR funds, the Ministry of Corporate Affairs (MCA) introduced Form CSR-1, an electronic registration mechanism for non-profit entities seeking to receive CSR contributions from companies. A common question among NGO founders and trustees is: How long does a CSR-1 registration remain valid? This article explores the lifecycle of CSR-1, associated compliance requirements, and best practices to maintain uninterrupted eligibility for CSR funding.

What Is Form CSR-1?

Form CSR-1 is a mandatory e-form filed on the MCA21 portal by non-governmental organizations (NGOs), charitable trusts, societies, and Section 8 companies that intend to receive CSR funding from corporate donors.

• Purpose: To generate a unique CSR Registration Number (CRN), which companies quote while earmarking CSR budgets under Section 135.

• Responsible Signatory: The form must be digitally signed by a practicing Chartered Accountant (CA), Company Secretary (CS), or Cost Accountant to ensure accuracy and authenticity.

By consolidating NGO details—such as objectives, registration particulars, trustees, and bank account information—into a standardized electronic record, Form CSR-1 aims to simplify due diligence for corporate donors and curb malpractices in CSR spending.

Validity and Expiration: The Core Question

Unlike many government licenses or permits that carry a defined expiry date, Form CSR-1 does not itself expire or require periodic renewal. Once filed correctly and accepted by the Registrar of Companies (RoC), the NGO is assigned a perpetual CSR Registration Number (CRN). Key takeaways include:

• No Defined Expiry: MCA guidelines do not stipulate any validity period for CSR-1; the registration remains active indefinitely.

• One-Time Filing: Since CSR-1 cannot be revised or edited once submitted, NGOs must ensure all details are accurate at the time of filing. Any subsequent changes in address, trustees, or bank details cannot be updated in the original CSR-1 record.

Thus, NGOs can continue receiving CSR contributions quoting their original CRN, provided all ancillary registrations and compliances are kept up to date.

Conditions Affecting CSR-1 Effectiveness

While CSR-1 itself has no built-in expiry, its effectiveness hinges on the validity of certain linked registrations and ongoing compliance. If these supporting credentials lapse or are revoked, companies may hesitate to disburse CSR funds—even if the CSR-1 record is technically active. Critical dependencies include:

1. Income-Tax Exemptions (Sections 12A/80G)

   • Most corporate donors seek assurance that their CSR contributions qualify for tax deductions under Section 80G, and that the NGO enjoys income-tax exemption under Section 12A.

   • Lapse or cancellation of these registrations can render an NGO ineligible to receive CSR funds until reinstatement.

2. NITI Aayog NGO Darpan Registration

   • A listing on the NITI Aayog’s NGO Darpan portal enhances transparency and provides a verified profile for companies to review.

   • Though not mandatory for CSR-1, absence of or outdated Darpan data can slow down corporate vetting.

3. Compliance with Companies Act and ROC Filings

   • Timely submission of annual statutory returns, financial statements, and any changes in the NGO’s board or constitution to the RoC maintains credibility.

   • Non-compliance or penalties can cast doubt on the NGO’s governance standards.

Should any of these ancillary registrations be suspended or expire, corporate donors may withhold CSR budgets until full compliance is demonstrated. Therefore, NGOs must vigilantly track renewal deadlines and rectify any discrepancies.

Corrections and Re-filing: Navigating Inflexibilities

Given that CSR-1 cannot be edited post-submission, NGOs facing changes in their organizational details must undertake corrective measures:

• Cancellation and Re-filing: The prevailing approach is to apply for cancellation of the original CSR-1 and subsequently file a fresh form with updated particulars.

• Supporting Documents: NGOs must furnish clear justifications for amendments, along with board resolutions and notarized affidavits, to facilitate cancellation approval by the RoC.

Although time-consuming, this process ensures that the registered information aligns with an NGO’s current operational reality, safeguarding against miscommunication with CSR-focused companies.

Best Practices for Sustained CSR-1 Validity

To maximize the utility of CSR-1 registration and avoid lapses in CSR funding, NGOs should adopt the following practices:

1. Pre-Filing Due Diligence

   • Audit all organizational documents—trust deed or memorandum, PAN, bank details, and trustee identities—for consistency before filing CSR-1.

2. Calendar-Based Compliance Tracking

   • Maintain a digital calendar of all renewal dates (12A/80G, Darpan, RoC annual filings) with automated reminders at least 60 days in advance.

3. Annual Governance Reviews

   • Convene board meetings annually to verify that organizational objectives and leadership remain unchanged, minimizing the need for mid-term amendments.

4. Transparent Stakeholder Communication

   • Proactively share compliance certificates and CSR-1 CRN with prospective corporate donors to streamline the vetting process.

5. Professional Support

   • Engage a qualified CA or legal advisor to monitor regulatory updates and guide timely corrective actions if registrations approach expiry.

By instituting robust administrative controls, NGOs can ensure their CSR-1 registration remains both valid and trusted by corporate stakeholders.

Conclusion

Form CSR-1 plays a pivotal role in India’s CSR ecosystem by providing a standardized, electronic registration pathway for NGOs seeking corporate funding. Unlike conventional permits, CSR-1 itself does not expire, offering perpetual validity once accepted. However, its real-world efficacy is contingent upon the NGO’s diligence in maintaining linked registrations—such as tax exemptions under Sections 12A/80G and NITI Aayog listings—and adherence to RoC compliance norms. NGOs that implement proactive governance practices, schedule timely renewals, and maintain transparent communication with corporate donors are best positioned to leverage their CSR-1 registration for sustained philanthropic impact.