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CSR Applicability Under Section 135: Board and Finance Checklist

CSR Applicability Under Section 135: Board and Finance Checklist
Finin2min Compliance Desk·June 2026·7 min readCSR

CSR is not just a donation budget. Section 135 creates a board-governance and reporting framework where applicability, committee, policy, spending and unspent amount tracking all matter.

Section 135 base

Section 135 applies to companies meeting specified net worth, turnover or net profit thresholds and requires CSR governance. It also states that the Board shall ensure spending in every financial year of at least two per cent of the average net profits of the company made during the three immediately preceding financial years, subject to the provision.

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CSR control table

ControlWhy it matters
Applicability testCheck net worth, turnover and net profit triggers.
CSR committee / board governanceSet up oversight where required.
CSR policy and project selectionSupport eligible CSR activity and approval.
Spend trackerTrack 2% computation, actual spend and unspent amount.
Board report disclosureCSR reporting must align with accounts and governance records.

Finance checklist

  • Compute average net profits carefully.
  • Maintain project/vendor/implementing agency documents.
  • Track ongoing vs other projects separately where relevant.
  • Reconcile CSR spend with ledger and board-approved policy.
  • Prepare board report annexure support early.

Finin2min warning

CSR should not be treated as random philanthropy. It is a statutory governance workflow with documentation and reporting.
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Official sources used

This article is intentionally source-limited to official MCA / India Code material. Verify final filing positions with the latest Act, Rules, MCA forms and portal advisories before publishing.

FAQs

Which section covers CSR? â–¾

Section 135 of the Companies Act covers corporate social responsibility.

What is the broad CSR spend rule? â–¾

Section 135 refers to at least 2% of average net profits of the three immediately preceding financial years, subject to the provision.

Should finance own CSR alone? â–¾

No. Finance, board/CSR committee and compliance teams should jointly control it.

Source and review trail

Use the current official instrument, portal or regulator publication before acting. This panel separates the category authority from page-specific references.

Primary category
Companies Act & MCA
Official starting point
www.mca.gov.in

Page source links

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