ICSI Requests Clarification and Extension for Form CSR-2 Filing

Request for Clarification and Extension for Filing Form CSR-2

On March 16, 2022, the Institute of Company Secretaries of India (ICSI) formally reached out to the Ministry of Corporate Affairs (MCA) regarding two main issues concerning the filing of Form CSR-2.

Background

The correspondence referenced the new rule 12(1B), which was added through the Companies (Accounts) Amendment Rules, 2022, and was notified by MCA on February 11, 2022. This rule mandates that every company subject to the provisions of section 135(1) must submit a Corporate Social Responsibility (CSR) report in Form CSR-2 to the Registrar. This submission should accompany Form AOC-4, AOC-4 XBRL, or AOC-4 NBFC (Ind AS), as applicable, starting from the financial year 2020-2021.

According to the proviso to Rule 12(1B), companies are required to file Form CSR-2 separately for the financial year 2020-2021 by March 31, 2022, after the submission of the aforementioned forms.

Current Challenges

ICSI has noted that professionals and companies are encountering significant challenges in filing Form CSR-2 due to ambiguities in certain fields within the form. During a webinar on Form CSR-2 conducted by ICSI on March 7, 2022, several issues and queries were gathered from participants. These queries have been compiled and are attached as an Annexure for further examination.

Request for Clarification and Extension

In light of the difficulties faced by companies and professionals, the ICSI has respectfully requested the following from the MCA:

Clarification on Queries: Provision of clear guidance addressing the issues raised in the Annexure, which will assist professionals in accurately completing the e-form.
Extension of Filing Timeline: An extension of the deadline for companies to file Form CSR-2 for the financial year 2020-2021, changing the submission date from March 31, 2022, to June 30, 2022.

ICSI expresses its willingness to provide any further information or assist in this matter as needed upon receiving a response from the MCA.