In most countries corporate social responsibility is voluntary — a company chooses whether to spend, how much, and on what. India took a different route. The Companies Act 2013 made a minimum spend a statutory obligation for companies above certain thresholds, with a reporting duty attached.

The 2013 Act was not the first attempt. Voluntary guidelines were issued in 2009 and the National Voluntary Guidelines in 2011, and take-up was poor enough that the statutory route was chosen — which is itself part of the argument about whether mandating this works.

For a single company the arithmetic is small: a firm averaging ₹100 crore of net profit owes ₹2 crore a year. Aggregated across every covered company it becomes one of the larger non-government funding pools in Indian development — and, because it is a statutory duty rather than a discretionary budget, one that does not disappear in a bad year for the philanthropy sector.

The three-year window is the part most often forgotten. A company’s obligation this year was fixed by profits it reported in years it can no longer change, which makes CSR budgeting a scheduling problem rather than a forecasting one.

Voluntary CSR guidelines came first — the Ministry of Corporate Affairs issued them in 2009 and revised them in 2011 as the National Voluntary Guidelines. Uptake was thin and uneven. The Companies Act 2013 replaced encouragement with obligation.

• 2009 — MCA Corporate Social Responsibility Voluntary Guidelines
• 2011 — National Voluntary Guidelines on social, environmental and economic responsibilities of business
• 2013 — Companies Act 2013 passed; Section 135 creates the obligation
• 2014 — Section 135 and the CSR Rules come into force on 1 April; India becomes the first country to mandate corporate social spending by statute
• 2021 — Amendment Rules add unspent-money machinery, CSR-1 registration and impact assessment

The last point on the right is the one practitioners raise most and policy debate covers least. Schedule VII is a list of services and outcomes; work that is adversarial to power — legal aid against the state, union organising, campaigning — fits badly, and a funding stream that grows while that work does not is changing the shape of the sector, not only its budget.

Notice that the two columns are not symmetrical claims about the same thing. The left is mostly about money reaching the sector, which is measurable and largely true. The right is mostly about who decides, which is a question about legitimacy that no amount of spending data settles.

• Decide, from a company’s financials, whether Section 135 applies to it
• Compute the minimum obligation and say which years feed the average
• Judge whether a proposed activity falls inside Schedule VII — and defend the judgement
• Trace unspent money to the right account within the right deadline
• Read a BRSR filing and say what it does and does not tell you

Each of these is a decision someone actually has to make: a company secretary determining scope, a finance team computing the figure, a programme manager arguing a boundary case, an NGO deciding whether it can accept the money, an analyst reading a filing.

Section 135(1) applies to every company — including a foreign company’s Indian branch or project office — that meets any one of these in the immediately preceding financial year.

Test the year that just ended, not the current one and not an average. Scope is a single-year question with a yes or no answer, and it is asked afresh every year — a company can move in and out of scope as its balance sheet moves, subject to the three-year exit rule that follows.

Scope is tested on the immediately preceding financial year. The spending obligation is then calculated on the average of the three immediately preceding financial years. These are two different windows and they are routinely confused.

The confusion is easy to make and expensive to carry, because it produces a plausible answer of the wrong kind: a company correctly identified as in scope, with an obligation computed from the wrong year, or a company correctly told its obligation is nil and wrongly told it has no duties at all.

A company that ceases to meet the thresholds is not bound forever. Where a company no longer meets the criteria for three consecutive financial years, it is not required to constitute a CSR Committee, and the obligation lapses until it re-enters scope.

The three-year clock runs on the thresholds, not on the spending. A company that falls below the criteria in one year is still bound in that year and the two after it, and the obligation is computed on the three-year profit average from when it was profitable.

A foreign company with a branch or project office in India is covered if it meets the thresholds. Net worth, turnover and net profit are computed from the balance sheet and profit-and-loss account prepared under Section 381(1)(a) of the Act — that is, from the Indian operation, not the global group.

The consequence is that a multinational whose worldwide revenue is very large may owe nothing if its Indian branch is small, while a mid-sized foreign firm with a substantial Indian project office may be squarely in scope. Size in India is what the section reads.

‘Net profit’ for CSR is not the headline profit-after-tax in a press release. It is net profit computed under Section 198, with specific adjustments — and the CSR Rules further exclude:

• Any profit arising from overseas branches of the company, whether operated as a separate company or otherwise
• Any dividend received from other companies in India which are themselves covered by and complying with Section 135

Any one of the three thresholds brings a company into scope, so the binding test is usually turnover or net worth rather than profit. A loss-making company with turnover above ₹1,000 crore is still covered — and still owes two per cent of the average of its preceding three years.

Schedule VII lists the activities a company may include in its CSR policy. It is the gate: spending outside it is not CSR expenditure, however worthy.

• Eradicating hunger, poverty and malnutrition; promoting health care including preventive health care; sanitation; safe drinking water
• Promoting education, including special education and employment-enhancing vocational skills; livelihood enhancement projects
• Promoting gender equality; empowering women; homes and hostels for women and orphans; old age homes; reducing inequalities faced by socially and economically backward groups
• Environmental sustainability; ecological balance; conservation of natural resources; animal welfare; agroforestry
• Protection of national heritage, art and culture; public libraries; traditional arts and handicrafts
• Measures for the benefit of armed forces veterans, war widows and their dependants
• Training to promote rural, nationally recognised, Paralympic or Olympic sports
• Contribution to specified government funds
• Contributions to incubators and to specified research and development bodies
• Rural development projects; slum area development; disaster management including relief, rehabilitation and reconstruction

The Ministry of Corporate Affairs has repeatedly clarified that the entries in Schedule VII are to be interpreted liberally, so as to capture the essence of the subjects listed, rather than read as a narrow closed list.

“Liberally” is not the same as “anything”. The instruction is about reading the essence of each listed subject rather than its narrowest wording — a water project can be rural development, sanitation or environmental sustainability depending on its design, and none of those readings is wrong.

The MCA has repeatedly instructed that Schedule VII be read liberally, so most disputes are not about whether an activity is worthy but about whether the company is the beneficiary.

A useful working question: if the company vanished tomorrow, would this activity still be worth doing for the people it serves? If the answer is no — because the beneficiaries are its workforce, or the activity feeds its supply chain — it is probably business expenditure with a social character rather than CSR.

A useful working question: if the company vanished tomorrow, would this activity still be worth doing for the people it serves? If the answer is no — because the beneficiaries are its own workforce, or the activity feeds its supply chain — it is probably business expenditure with a social character rather than CSR.

The board must ensure the company spends, in every financial year, at least two per cent of the average net profit made during the three immediately preceding financial years.

Two words in that sentence do the work. Average means a single bad or spectacular year does not move the obligation much. Preceding means the amount is already fixed before the financial year begins — a company knows in April what it owes by March.

Note which years feed the calculation. The obligation for FY 2026–27 is set by the three years preceding it, so the money a company must spend this year was determined by profits it has already made and already reported. There is no forecasting involved, and no discretion.

Because the base is a three-year average, a single loss-making year does not extinguish the obligation. Equally, a company can be in scope on turnover or net worth while its three-year average net profit is nil — in which case the prescribed expenditure is nil, but the reporting duty remains.

A company can therefore be in scope with a nil obligation, and it still owes the governance: a Committee or a board process, a policy, an action plan, and a report recording that the prescribed amount was nil. None of the duty structure switches off because the arithmetic came to zero.

Any surplus arising out of CSR activities does not form part of the business profit of the company. Three routes are open to it, and none of them ends at the company.

Surplus here is wider than it first sounds: interest earned on CSR funds held in an account, income generated by a CSR asset, proceeds from the sale of anything produced by a CSR programme. A skilling centre that sells what its trainees make has generated CSR surplus, not revenue.

Where a company spends more than its obligation in a financial year, the excess may be set off against the requirement of succeeding financial years, subject to conditions in the Rules — board approval, a limit on how far forward it carries, and the exclusion of any surplus arising out of CSR activities.

The mechanism exists because CSR spending is lumpy while the obligation is annual. A company that builds a facility in one year may spend three years’ worth at once; without set-off it would be over-compliant once and under-compliant twice.

CSR spend may create or acquire a capital asset, but the asset may not simply sit on the company’s balance sheet. It must be held by a Section 8 company or a registered trust or society with an established track record, or by the beneficiaries themselves as a self-help group or collective, or by a public authority.

Assets created before the 2021 amendment had to be transferred within 180 days, extendable by a further 90 on board approval — a transitional rule that caught a great many company-owned school buildings and health centres.

Administrative overheads — the company’s own expenses of managing and administering its CSR functions — may not exceed five per cent of total CSR expenditure for the financial year.

The cap covers the company’s cost of running its own CSR function — salaries of CSR staff, office costs, programme audit. It does not cover the implementing partner’s cost of delivering the project, which is project expenditure. An NGO’s staff salaries for running the programme are programme cost, not the company’s overhead.

“Net profit” here is not profit before tax from the income statement. It is profit computed under Section 198, which starts from the profit and loss account and then adds back and deducts specified items.

A company that spends above its obligation may set the excess off against the requirement of up to the three immediately succeeding financial years.

• The excess must not include the surplus arising out of CSR activities
• The board must pass a resolution to that effect
• The set-off is capped at the excess actually spent, carried for three years

The board resolution is the operative condition. Excess spending does not create a set-off automatically — a company that overspends without resolving to carry the excess forward has simply overspent, and discovers this a year later when it tries to claim the credit.

Where CSR money creates or acquires a capital asset, the company may not hold it. The asset must sit with one of three kinds of holder.

The rule attaches to the asset, not to the money that bought it. A company funding a building, a piece of equipment or a vehicle has to place the title outside itself — which means the implementing partner, a community body or the state must be able to hold it, maintain it and bear its running costs.

Across all covered companies, mandated CSR came to ₹34,909 crore in FY2023-24. That is the whole of India’s statutory corporate giving in one number — large enough to matter to the sectors it enters, small beside public expenditure on the same subjects.

It is also a number that only exists because of the statute. Voluntary corporate giving in India before 2014 was a fraction of this and concentrated in a handful of houses; whatever else the mandate did, it created a floor.

The concentration is worth pausing on. Schedule VII lists education, health, gender equality, environment, rural development, sport, heritage, armed-forces veterans, technology incubation and more — and two heads absorb about seven rupees in ten. The distribution is not set by need; it is the aggregate of thousands of separate corporate decisions, and those cluster on what is legible, photographable and uncontroversial.

The distribution is roughly what you would expect from a rule pegged to profit: banks, IT services, oil and steel — the most profitable large firms in the economy — with no relationship to where social need is concentrated.

The tail matters as much as the head. A company with a ₹40 lakh obligation cannot fund a district programme, cannot commission an impact assessment at Rule 8 thresholds, and will usually look for a partner who can absorb a small grant with light reporting. That is a different fundraising conversation from the one with a top-ten spender, and confusing the two wastes everyone’s time.

Set that against where Indian development need is usually said to sit. Nutrition, sanitation and primary care fall inside the health head; schooling and skilling inside education. Almost everything else — social protection, disability, legal aid, urban poverty, care work, gender-based violence — competes inside the 11.4 per cent labelled ‘other’.

Health and education together take seven rupees in every ten. The remaining Schedule VII heads — gender, sports, arts and heritage, disaster relief, technology incubation — share what is left.

The ten largest spenders account for roughly ₹5,880 crore — about 17 per cent of all CSR — while thousands of covered companies contribute the rest in much smaller amounts.

A company in scope must constitute a CSR Committee of the Board, consisting of three or more directors, of which at least one must be an independent director.

• A company not required to appoint an independent director constitutes its Committee with two or more directors
• Where the amount to be spent does not exceed ₹50 lakh, the requirement to constitute a Committee does not apply, and the Board discharges its functions

Since 2021 it also formulates the annual action plan for board approval. The Committee must have three or more directors including at least one independent director; a company not required to have an independent director may constitute it with two.

• Approve the CSR Policy and disclose its contents in the Board’s report and on the website
• Ensure the activities in the Policy are actually undertaken
• Ensure the company spends the prescribed amount
• Satisfy itself that the funds disbursed have been utilised for the purposes and in the manner approved — with the CFO certifying this
• Where the amount is not spent, give the reason in the Board’s report

Read the fourth duty carefully. The board must satisfy itself that funds were utilised for the purposes and in the manner approved — not merely that they were disbursed. Money that left the company and did something other than what the action plan said is not compliant spending.

• The list of CSR projects or programmes approved, within Schedule VII
• The manner of execution
• The modalities of utilisation of funds and implementation schedules
• Monitoring and reporting mechanism
• Details of need and impact assessment, if any, for the projects

This list is why the annual action plan is the document an auditor reads first. It converts a policy — which can be aspirational — into named projects with money, dates and a named way of checking them.

The board’s report must include an annual report on CSR containing the particulars specified in the Rules, and the company must publish three things on its website: the composition of the CSR Committee, the CSR Policy, and the projects approved by the board.

• Board’s report — the annual CSR report, in the prescribed format
• Website — Committee composition, policy, approved projects
• Where impact assessment applies — the assessment report, annexed

Since the 2021 amendment the CSR Committee must formulate, and the board approve, an annual action plan. It is the document an auditor reads, and it must contain more than a list of intentions.

• The list of approved CSR projects, mapped to Schedule VII heads
• The manner of execution — directly, or through an implementing agency
• Modalities of utilisation of funds and implementation schedules
• Monitoring and reporting mechanism for each project
• Details of need and impact assessment, where undertaken

“Need assessment” sits quietly in that last line and is the most skipped item on it. A plan that names projects and budgets without any statement of how the need was established is complete on its face and hollow underneath — and it is how a company ends up funding what it already knows rather than what the district lacks.

CSR non-compliance was a criminal offence as originally amended. The Companies (Amendment) Act 2020 decriminalised it, replacing imprisonment with monetary penalty.

The penalty attaches to the failure to transfer unspent money to the right account or fund, not to under-spending as such. A company that spends nothing but transfers correctly is in a different position from one that neither spends nor transfers.

India was the first country to make corporate social spending a statutory duty. That is a genuine policy experiment, and it is contested on both sides.

Before 2021, a company that failed to spend explained itself in the board’s report, and that was largely the end of it. Unspent CSR was a disclosure item, not a liability.

The difference is not cosmetic. An ongoing project keeps the money within the company’s control for up to three more years and lets it finish what it started. Anything else loses the money to a Central Government fund within six months, whatever the reason it went unspent.

An ongoing project means a multi-year project undertaken by a company in fulfilment of its CSR obligation, having a timeline not exceeding three years excluding the financial year in which it was commenced. It includes a project that was initially not approved as multi-year but whose duration is extended beyond one year by the Board on reasonable justification.

The extension clause matters as much as the definition. A project not originally approved as multi-year can become ongoing if the board extends it beyond a year with reasonable justification recorded — which is the legitimate route, and also the route a company takes when it wants to keep money it has not managed to spend.

Money sitting in the Unspent CSR Account that is not spent within three financial years must be transferred to a fund specified in Schedule VII within 30 days from the end of the third financial year.

The three years run from the end of the financial year in which the money was transferred, not from when the project started. A project that slips can therefore exhaust the window while still running — and the unspent balance leaves anyway.

• Prime Minister’s National Relief Fund
• PM CARES Fund
• Clean Ganga Fund
• Swachh Bharat Kosh
• Any other fund set up by the Central Government as specified in Schedule VII

Every one of these is a fund of the Central Government. There is no option to transfer unspent money to a state fund, a local body, a district administration, or the NGO the company had been working with — even where that partner has a live project and the capacity to absorb the money.

Failure to comply with the transfer obligations attracts penalty on the company and on every officer in default under Section 135(7). The Companies (Amendment) Act 2020 converted the regime from criminal to civil.

That change is easy to read as a softening and is better read as a redesign. Criminalising a spending shortfall made directors personally liable to imprisonment for a budgeting failure, which chilled participation on boards without improving spending. A monetary penalty attached to the transfer duty targets the behaviour the state actually wants: money that is not spent must still leave the company.

The two unspent regimes are decided by one question: was the money committed to an ongoing project?

The first row requires a separate bank account, opened for the purpose and named for the financial year. It is not a ledger entry or a ring-fenced balance — the money physically moves, which is what makes the obligation checkable.

• Itself — directly, through its own teams
• Its own foundation — a Section 8 company, registered trust or society established by the company, alone or with others
• A government entity — established under an Act of Parliament or a State legislature
• An external organisation — a Section 8 company, registered public trust or registered society with an established track record of at least three years

The choice is not neutral. Delivering directly keeps control and builds no external capacity; a company foundation keeps control while looking independent; an established NGO brings field presence the company does not have, and takes a share of the decisions with it.

From 1 April 2021, an entity intending to undertake CSR activities on behalf of a company must register itself with the Central Government by filing Form CSR-1 electronically with the Registrar, and obtain a CSR Registration Number.

The registration is with the Registrar of Companies, not with the funding company, and it is a one-time filing rather than a per-grant approval. Once issued, the CSR Registration Number is quoted by every company that funds the entity.

• Registration under Section 12A and 80G of the Income-tax Act 1961, where applicable
• The entity type — Section 8 company, registered public trust or registered society
• Governing body details, PAN, and the registration certificate
• Digital signature of an authorised person
• Certification by a practising chartered accountant, company secretary or cost accountant

Filing is free and there is no fee, but it is not a formality: the professional certifying the form is attesting that the entity meets the eligibility conditions, including the three-year track record. On acceptance the MCA issues a CSR registration number, which the funding company records in its own reporting.

An external implementing organisation must have an established track record of at least three years in undertaking similar activities. An entity established by the company itself — its own foundation or Section 8 company — does not face this requirement.

The Board must satisfy itself that funds disbursed have been utilised for the purposes and in the manner approved, and the Chief Financial Officer or the person responsible for financial management must certify to that effect.

The certification runs to the Chief Financial Officer or the person responsible for financial management — not to the CSR Committee that set the policy, and not to the implementing agency that did the work. The person who signs is downstream of both.

A company may collaborate with other companies on a project, provided the CSR Committees of each are in a position to report separately on that project in accordance with the Rules.

The economics make this attractive. Most covered companies owe a few lakh to a few crore — enough to fund a fragment of a programme, not a programme. Ten such obligations pooled reach a scale at which a district-level intervention can be designed, staffed and evaluated rather than scattered across ten small grants.

From 1 April 2021 no company may route CSR funds to an implementing agency that has not filed Form CSR-1 with the Ministry of Corporate Affairs and obtained a registration number.

• The entity must be a Section 8 company, a registered public trust or a registered society
• It must hold registration under Section 12A and 80G of the Income-tax Act
• It must have an established track record of at least three years in similar activities
• The form is certified by a practising CA, CS or cost accountant

Read those four together and the shape of the eligible partner appears: formally registered, tax-compliant, professionally audited, and three years old. That is a reasonable description of an established NGO and a poor description of a new community organisation — which is the trade-off the rule makes deliberately.

A company must undertake impact assessment through an independent agency where it meets both limbs:

The one-year gap in the second limb is deliberate. Assessing a project immediately on completion measures delivery, not effect; most outcomes worth measuring — income, attendance, health status — take time to appear or to fade.

Impact assessment expenditure may be booked to CSR for that financial year, subject to a cap in the Rules expressed as a percentage of total CSR expenditure or an absolute figure, whichever is higher.

That matters more than it sounds. Evaluation is usually the first line cut, because it competes with delivery for the same budget and produces no beneficiaries. Making it chargeable to CSR means a company commissioning a serious assessment is not spending money it could otherwise have spent on the programme — it is spending CSR money on finding out whether the programme worked.

The Rules require an independent agency. They do not prescribe a methodology, a qualification or an accreditation. In practice this is a real weakness and a real opportunity.

Nothing in the Rules prevents a good assessment. There is no ceiling on rigour, the cost is chargeable to CSR, and the report is published. What is missing is a floor — and in the absence of one, the quality of any given assessment depends entirely on whether the commissioning company wanted to find something out.

• States the theory of change the project was built on, and tests it
• Distinguishes outputs from outcomes, and says which it can evidence
• Is explicit about attribution — what would have happened anyway
• Reports what did not work, not only what did
• Names its limitations, sample and period

None of this requires a randomised trial. It requires the author to be explicit about what the study can and cannot support — which is a writing discipline before it is a methodological one.

A CSR report will say a programme reached 40,000 people. The evaluation question is different: what changed that would not have changed anyway?

The gap is not usually dishonesty. Reach is cheap to measure and change is expensive, so a report constrained by budget and deadline reports what it has. The problem is that both are presented in the same register, and a reader who does not know the difference will take a headcount for a result.

The honest version is available and rarely used: say what was delivered, say what was measured, and say plainly that the study cannot separate the programme’s effect from everything else happening in those districts over those years. That sentence costs nothing and is almost never written.

The impact assessment report must be placed before the board and annexed to the annual report on CSR. That annexure is filed and published, which makes it one of the few evaluation documents in Indian development that anyone can read without asking permission.

The quality varies enormously. Some are competent evaluations with a stated design, sample and limitations. Others are the programme brochure with a cover page. Both satisfy the same rule, because the Rules require an assessment by an independent agency without specifying what an assessment must contain.

The rules require an impact assessment through an independent agency for companies above the thresholds, but they do not specify a method. In practice most published assessments report what happened to participants and stop there.

CSR under Section 135 asks: did you spend, and on what? ESG reporting asks a different question: how does your business behave, and what does it cost the world? The audience shifts from the regulator to the investor.

The two overlap but do not nest. A large unlisted company can be squarely inside Section 135 and file no BRSR at all; a listed company can file a full BRSR while its CSR obligation is modest. They are different regimes with different regulators that happen to share a subject.

The Business Responsibility and Sustainability Report is SEBI’s mandatory ESG disclosure format, replacing the earlier Business Responsibility Report. It applies to the top 1,000 listed entities by market capitalisation, mandatory from FY 2022–23.

It replaced the Business Responsibility Report, and the change of name marks a change of scope: the BRR asked mainly about conduct, while the BRSR adds quantitative environmental and social disclosure and a structure that can be compared across companies and years.

BRSR is structured on the National Guidelines on Responsible Business Conduct. Businesses should:

• Conduct themselves with integrity, ethics, transparency and accountability
• Provide goods and services in a safe and sustainable manner
• Respect and promote the wellbeing of all employees, including those in value chains
• Respect the interests of and be responsive to all stakeholders
• Respect and promote human rights
• Protect and restore the environment
• Engage in policy advocacy responsibly and transparently
• Promote inclusive growth and equitable development
• Engage with and provide value to consumers responsibly

• Section A — entity details, products, employees, CSR, transparency
• Section B — policies against each of the nine principles, and governance of them
• Section C — essential and leadership indicators for each principle

SEBI introduced BRSR Core: a defined subset of key performance indicators requiring reasonable assurance, phased in by market-capitalisation rank, with disclosure extending into the value chain.

The boundary question does the most work. A group can report emissions for its listed parent and exclude the subsidiaries where the manufacturing happens, disclose the exclusion accurately in a footnote, and produce a headline figure that is true and useless. Nothing has been misstated; the reader has simply been given a different company from the one they thought they were reading about.

The BRSR is organised around the nine principles of the National Guidelines on Responsible Business Conduct. Each principle carries essential indicators (mandatory) and leadership indicators (voluntary).

• P1 Integrity and ethical conduct
• P2 Goods and services that are safe and sustainable
• P3 Wellbeing of employees, including value-chain workers
• P4 Responsiveness to all stakeholders
• P5 Respect and promotion of human rights
• P6 Protection and restoration of the environment
• P7 Responsible and transparent public policy influence
• P8 Inclusive growth and equitable development
• P9 Value to consumers in a responsible manner

Principle 7 is the one that surprises people: responsible and transparent public policy influence. It asks a company to disclose the trade and industry bodies it belongs to and the positions it advocates — a question CSR reporting never asks, and one that reaches an activity with far more effect on outcomes than most CSR spending.

Disclosure without verification is a claim. SEBI introduced BRSR Core — a subset of attributes subject to reasonable assurance by an independent assurance provider, phased in by market capitalisation.

• Greenhouse gas footprint
• Water footprint
• Energy footprint
• Embracing circularity — waste management
• Enhancing employee wellbeing and safety
• Enabling gender diversity in business
• Enabling inclusive development
• Fairness in engaging with customers and suppliers
• Openness of business — concentration of purchases and sales

The nine are chosen to be quantitative and comparable rather than comprehensive. They leave out most of what NGRBC covers, and that is the design: assurance is expensive, so it is spent on the attributes where a wrong number would most mislead an investor.

Greenwashing rarely takes the form of a false number. It usually takes the form of a true number chosen carefully.

Each of these has a defensible rationale, which is exactly why they are worth checking rather than accusing. Intensity metrics genuinely are the right measure for some questions; baselines genuinely do get restated when a company acquires or divests. The signal is not any single choice but whether every choice happens to run the same way.

The BRSR runs to three sections and over a hundred data points. A reader with limited time gets most of the signal from a few of them.

• Section A — turnover, employees, and the products in scope. Establishes what the rest is about.
• Section B — policies against each of the nine NGRBC principles, and whether the board has approved them.
• Section C — the essential and leadership indicators, principle by principle. The numbers live here.
• BRSR Core — the nine attributes subject to reasonable assurance. These are the audited ones.

Read Section A first and keep it open. Everything in Sections B and C is proportional to something declared there — turnover, employee numbers, plant locations — and a figure that looks impressive in isolation often looks ordinary once divided by the size of the business reporting it.

ESG reporting grew from voluntary initiatives rather than a single regulator, so the field arrived crowded. Consolidation is underway but incomplete.

The two questions can point in opposite directions. A factory’s water use may be financially immaterial — water is cheap, supply is secure, no investor cares — while being the single most material fact about that factory to the village sharing the aquifer. Under financial materiality alone, it is not reported.

BRSR is built on the NGRBC principles and covers both business conduct and environmental performance, so it sits closer to a broad-stakeholder view than to a purely investor-financial one — while BRSR Core’s assured KPIs and value-chain reach move it toward investor-grade comparability.

It also arrived from a different direction. GRI and SASB grew out of voluntary investor and civil-society initiatives; BRSR descends from a government guideline (NGRBC) enforced by a securities regulator. That lineage is why it asks about business conduct and policy advocacy alongside emissions — questions an investor-first framework would not have started with.

Companies routinely map CSR and ESG activity to the Sustainable Development Goals. The mapping is genuinely useful for communication and genuinely weak as accountability: the SDGs were written for states, have no corporate reporting requirement, and almost any activity can be mapped to at least one goal.

There are 17 goals, 169 targets and 231 unique indicators. The indicators are the part with measurement definitions attached, and they are also the part corporate SDG mapping almost never reaches — a report will claim alignment with a goal, occasionally a target, and essentially never an indicator.

The UN Guiding Principles on Business and Human Rights set out a duty to protect, a corporate responsibility to respect, and access to remedy — with human rights due diligence at the centre. NGRBC Principle 5 carries this into the Indian frame.

The three pillars are not symmetrical. The state has a duty to protect; the company has a responsibility to respect — a lower bar, meaning do no harm rather than do good; and both owe access to remedy when harm occurs. CSR spending satisfies none of these, because it is about benefit conferred rather than harm avoided.

A company’s own operations are rarely where its worst impacts sit. They sit in the value chain — suppliers, contractors, informal labour. Scope 3 emissions, supplier labour conditions and contract-worker safety are where reporting is thinnest and the stakes are highest.

An Indian listed company above the BRSR threshold with European customers may be reporting under BRSR and preparing for CSRD at the same time, and the two ask different questions of the same operations.

For an Indian company this is not a hypothetical. CSRD reaches non-EU companies with substantial EU turnover, and reaches many more indirectly as suppliers to firms that are in scope — who then ask for the value-chain data their own reporting requires. The obligation arrives through the customer rather than the regulator.

Few people who study this will spend a career drafting Section 135 policies. Almost everyone will have to read reports written by people with an interest in how they are read, and decide what to believe.

That does not mean assuming bad faith. Most CSR and sustainability reporting is produced by people trying to describe real work accurately, under formats and deadlines they did not choose. The discipline is to separate what the document establishes from what it asserts — and to notice that the two are laid out to look alike.

• What is the reporting boundary — which entities are in?
• Is the prescribed CSR amount stated, and does the arithmetic work?
• Is any amount unspent, and where did it go?
• Are projects named, or only themes?
• Who implemented, and are they CSR-1 registered?
• Is there an impact assessment, and does it have a counterfactual?
• Are ESG figures assured — and reasonable or limited assurance?
• Are targets given a baseline and a date?
• Are Scope 3 emissions reported or omitted?
• Does anything in the numbers contradict the narrative?

Nine of the ten can be answered from documents the company is already required to publish. Only the last needs judgement, and it is the one that most often produces the finding — a report whose numbers and narrative disagree has usually had the narrative written first.

The two columns fail differently. CSR reporting usually fails by being vague about what was done; ESG reporting usually fails by being precise about the wrong thing. A beneficiary count with no definition and an emissions-intensity figure with no absolute are the same move made in opposite registers.

Thresholds, deadlines, forms, penalty amounts and BRSR applicability have all been amended since 2014, several times. Do not teach any figure in this deck as permanent.

• mca.gov.in — the Companies Act, the CSR Rules, circulars and the CSR FAQ
• csr.gov.in — the national CSR data portal, with company-level spending data
• sebi.gov.in — LODR regulations and BRSR circulars
• The company’s own website — policy, committee composition and annual CSR report are all required to be public

The national CSR portal publishes company-level CSR spending, by year, sector and state. It is a genuine dataset and it is open.

• Which sectors attract the most CSR money — and which almost none?
• How is spending distributed across states? Does it follow need, or follow head offices?
• Which companies report large obligations and small spends?

The distribution questions are the interesting ones. CSR is generated where companies are profitable and headquartered, which is not where need is greatest — so the geography of CSR spending is a live question about whether a decentralised, corporate-directed funding stream reaches the districts a public programme would have prioritised.

The left column can be checked against a statute. The right column cannot be settled by reading harder — it needs evidence that mostly does not exist yet, and value judgements that evidence would not settle anyway.

• Development Architecture 101 — how development funding is structured, including CSR flows
• Climate Essentials 101 — the climate science and policy behind the E in ESG
• MEL for Development — the flagship, for the evaluation half of impact assessment
• Theory of Change Studio and Impact Evaluation Studio — build and defend the designs an assessment needs

Two of these matter more than the others depending on where you are going. If you will be commissioning or reading impact assessments, the MEL flagship and the two studios are the direct continuation of Section 08. If you will be raising CSR funds, Development Architecture 101 explains where corporate money sits among the other flows an organisation might approach.