csr: New CSR disclosure rules let companies omit key details – Blue Barrows

A notification by the Ministry of Corporate Affairs (MCA) has limited the information companies must disclose on expenditures toward corporate social responsibility (CSR) in their annual reports.

Among other things, the Companies (Corporate Social Responsibility Policy) Amendment Rules, 2022, issued on September 20, has revised Annexure II – the format in which CSR activities are disclosed in the annual report. The revised Annexure II excludes details concerning the companies’ expenditure toward ongoing and other CSR projects.

The details omitted include the name, the location and duration of the company’s CSR project, the amount allocated for the project, the amount spent in the current financial year on the project, mode of implementation, the name of the implementing agency along with their CSR registration number and amount transferred to the unspent CSR account.


This omission has been an important, yet not so-known change made to Annexure II. While the disclosure in the annual report has been removed, the companies are still required to disclose these omitted details in the CSR-2 form filed through the MCA portal.

According to the CSR expenditure data released on the national CSR portal, more than 17,000 companies have together spent nearly Rs 24,865 crore for the financial year 2020-21 on almost 37,000 projects across 14 development sectors. With the revised disclosure rules, the information on how and where the CSR kitty of individual listed companies will be spent will not easily be known by the companies’ shareholders, employees, peers, customers, and the public.

“This is important information that has been skipped out from the annual reports,” said chartered accountant Daniel Selvaraj, partner at Manohar Chowdhry & Associates and a specialist in the non-profit sector. “Emphasising impact assessment without informing the company’s stakeholders about where and how the CSR amount is getting spent will not add the expected value.”

CSR experts questioned the omission.