Notification
Number GSR 107(E) dated 11th February 2022 was released by MCA to
mandate a new 11-page reporting requirements for Corporate Social Responsibility
(CSR). Under this notification a new
Form CSR-2 has been mandated to be submitted by entities who fall under ambit
of section 135 of Companies Act, 2013. This
is a pseudo retrospective amendment as this new report is mandated for the financial
year 2020-21 also with a due date of 31st March 2022. For subsequent
years this new report should be filed as an addendum with AOC-4 (AOC-4 is for filing
of the company's financial statement for every financial year). This new reporting mandate is contained in new
Rule 12(1B) of the Companies (Accounts) Rules, 2022.
Due Dates to Remember
For 2020-21 31st March 2022
For subsequent
years Same as AOC-4
(addendum to AOC-4)
CSR-2 is
a comprehensive reporting requirement covering aspects like Networth, Turnover,
Net Profit, details of CSR committee, its meetings, amount spent on projects,
balance unspent, details of transfer of unspent amount etc. The big surprise is that all these
information is already contained in Director’s report which is annexed to the financial
statement since inception of CSR regulations.
Then why there is an additional requirement? I only find some additional information
mandated in CSR-2 which are “Amount spent on administrative overheads” & “Amount
spent on Impact Assessment”. Argument from MCA maybe that all information contained
on this CSR-2 is easily accessible in one particular structured format and can
be utilised for data mining & analysis by the CSR department of MCA.
This new
form according to me will increase cost of compliance of corporates as there is
a mandate for submitting same information in different formats in different statutory
forms.
This new form could have been avoided and MCA could have picked up the data from Directors report
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