Filing Dates
- Form for FY 2020-21 has to be filed by 31st March 2022 separately as an online web Form.
- Form for subsequent years has to be filed as an addendum to Form AOC-4/AOC-4 XBRL/AOC-4 NBFC (Ind AS), as per the due dates of AOC4.
Some of the important issues covered in the Form are as follows:
CSR obligation for the year (Para 5(c) & 6): One of the most important figure being now asked for is the CSR amount obligation for the year. Company has to provide a complete detailed working of this. This is a good development, as it will make CSR obligation amount to be arrived at very transparent. Company would also know what it is obligated to spend during the year.
Project Details (Para 7(b)(i)&(ii)): Each Project has to be identified and listed on the Form. In fact Ongoing projects, one would need to give Project ID too.
CSR obligation for previous period (Para 10(a)): Any CSR obligation not spent effective FY 2020-21, needs to be specified and if any spending against the same, would need to be detailed Project-wise. It may be noted that a company is allowed to take up even new projects from unspent funds, but need to be disclosed. This is new, this was not mentioned in the Rules.
In case a company has spent any unspent CSR funds for FY 2014-15 to FY 2019-20, same should be disclosed. It may be noted that though a company is not required to spend this money, however in case a company does spend old obligations (this may happen in case of public sector companies), it needs to be disclosed, again project-wise.
Capital assets created through CSR spending (Para 12): All assets which have been created through CSR spending needs to be disclosed, alongwith details of who is holding the same.
Website (Para 4(b)): The Form asks for weblinks of various information which are required to be disclosed on website. Please make sure your company has a website with weblinks to all the information required to be posted. This includes Composition of CSR Committee, CSR Policy, CSR Projects approved by the Board and Impact Assessment reports.
CSR Set Off (Para 4(d)): In case a company has spent more than CSR compulsory requirement, then same can be set-off over next 3 years. Such year-wise details has to be provided in the Form. Since the rules became effective only from FY 2020-21, hence this set-off rule is applicable only from that year only.
Signing Authority: The Form has to be signed by at least someone who is a director on the Board. This means now directors are directly responsible for disclosure of all CSR details. It may be noted that any false statement/certificate and false evidence attached are punishable offences under S.448 and S.449 respectively.
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