Introduction
Separate Filing of e-form CSR-2 is mandatory for companies falling under Section 135 of the Companies Act, 2013. After MCA21 transitioned from Version 2 to Version 3, the Ministry of Corporate Affairs issued clarifications to avoid confusion. Non-compliance can lead to hefty penalties. This blog simplifies how to file CSR-2 properly in the new system.
Understanding CSR-2 Filing: The Basics
- What is CSR-2?
It is an annual form where companies report their Corporate Social Responsibility activities, as mandated under Section 135 read with Rule 12(1B) of the Companies (Accounts) Rules, 2014. - Who must file?
Every company covered under CSR provisions must file e-form CSR-2 separately.
Why Separate Filing of e-form CSR-2 Matters Post V2-V3 Transition
With the shift from MCA21 V2 to V3, certain e-forms migrated while others remained partially on V2.
Key MCA Clarifications
- MCA Circular dated 31.03.2022: Allowed filing CSR-2 for FY 2020-21 separately.
- MCA Notification G.S.R. 207(E) dated 11.02.2022: Inserted Rule 12(1B), mandating CSR-2 to be filed as an addendum to AOC-4, AOC-4 XBRL or AOC-4 NBFC (Ind AS).
However: Due to tech transitions, MCA allows CSR-2 as an independent e-form to avoid delays.
👉 Practical Tip: Companies must check the latest MCA portal version before filing to avoid uploading on the wrong version.
Step-by-Step Guide: Separate Filing of CSR-2
1️⃣ Prepare CSR data – Ensure details match your Board Report & CSR Policy.
2️⃣ Complete AOC-4 filing first – CSR-2 can be filed only after AOC-4 submission.
3️⃣ Login to MCA21 V3 Portal – Use updated credentials.
4️⃣ Download latest CSR-2 form – Always use the version available on MCA site: MCA CSR-2 Forms
5️⃣ Fill & validate – Use MCA pre-scrutiny tool.
6️⃣ Attach digital signature – Get Board-authorised signatory’s DSC.
7️⃣ Upload & pay fee (if applicable) – Keep acknowledgment for records.
Penalties for Non-Filing
🔴 Default Consequence: Non-filing attracts penalties under Section 134, 135 & 137.
- Company: ₹1 lakh to ₹5 lakh
- Officers in Default: Fine and possible imprisonment as per severity.
Expert View: Efiletax Compliance Tip
✅ “Always cross-verify whether your CSR-2 submission reflects in the MCA database. Download final SRN copy and keep with your Board records to face any scrutiny confidently.” — Efiletax Compliance Team.
Quick Comparison: Before vs After MCA V3
| Aspect | Before V3 | After V3 |
|---|---|---|
| Filing | CSR-2 filed along with AOC-4 | CSR-2 filed separately |
| Platform | MCA21 V2 | MCA21 V3 |
| Tech support | Limited | Improved validation tools |
FAQs on Separate Filing of CSR-2
Q1. Can CSR-2 be filed before AOC-4?
No. AOC-4 must be filed first. CSR-2 follows.
Q2. Is there an extension for FY 2023-24 CSR-2?
No general extension notified as of June 2025. Follow regular due dates.
Q3. Where to check latest MCA updates?
Visit MCA Official Site regularly or follow Efiletax blog.
Snippet Summary
Separate Filing of e-form CSR-2 is mandatory post MCA21 V2-V3 transition. File AOC-4 first, then CSR-2 independently on MCA V3 portal. Avoid penalties by following MCA notifications and using the latest forms.
Closing CTA
Stay updated with Efiletax for hassle-free CSR and annual compliance. Need help? Contact our experts today and keep your business MCA-ready!