Skip to content
Companies Act / CSR

CSR: Impact Assessment Requirement for Large Companies

Impact assessment is mandatory for large CSR spenders. The assessment is not a public-relations document; it must evaluate the project against its stated objectives, and the report must be placed before the board and disclosed.

29 Oct 20262 min read

The Applicability Test

The Companies (CSR Policy) Rules, 2014 require a company with an average CSR obligation of ₹10 crore or more in the three immediately preceding financial years, and with CSR projects having an outlay of ₹1 crore or more, to undertake an impact assessment of its CSR projects. The assessment must be conducted by an independent agency, and the report must be placed before the board.

The Scope of the Assessment

The impact assessment should evaluate: the project’s relevance to the community; the achievement of the stated objectives; the efficiency of resource use; the sustainability of the outcomes; and the lessons for future project design. The assessment should use a methodology that is appropriate to the project’s nature—quantitative surveys, qualitative interviews, or a combination—and should disclose the limitations of the methodology.

The Independent Agency

The impact assessment agency should be independent of the implementing agency and the company. The agency should have demonstrated experience in social-impact evaluation. The company should document the selection process and the agency’s credentials. An assessment conducted by an entity related to the company or the implementing agency is vulnerable to a finding of bias.

Timing and Coverage

The impact assessment must be conducted for the projects completed during the financial year, and the report must be placed before the board. The assessment should cover a representative sample where the number of projects is large. The company should maintain a schedule that identifies the projects requiring assessment each year, so that the assessment is not compressed into the final quarter.

The Disclosure

The board’s report must disclose the impact assessment report or a summary. The disclosure should include the project name, the assessment findings, and the corrective actions taken. A disclosure that states only that an assessment was conducted, without the findings, does not satisfy the transparency objective.

The Strategic Value

An impact assessment that is treated as a compliance formality misses its governance value. The findings should inform the next year’s annual action plan, the selection of implementing agencies, and the CSR committee’s review. A company that conducts the assessment but does not change its project design based on the findings is not using the assessment as a management tool.

Call to Action: For CSR impact assessment scoping, agency selection, or board reporting, contact office@anujdesaiassociates.com or 9619456656. Website: https://anujdesaiassociates.com. LinkedIn: linkedin.com/in/ca-anuj-desai-122547230.

Compliance GuideCSR impact assessmentCSR impact assessment applicabilityCSR large companyCSR impact assessment thresholdCSR impact assessment agencyCSR impact assessment reportCSR impact assessment compliancesection 135 impact assessmentCSR rules impact assessmentCSR project impactCSR social impactCSR evaluationCSR third party assessmentCSR impact assessment timelineCSR impact assessment disclosureCSR impact assessment penaltyCSR impact assessment exemptionCSR impact assessment methodologyCSR impact assessment checklistAnuj Desai Associates CSR impact advisory
Share

Related insights

Companies Act / Board Governance

Section 185 Loans to Directors: The 2023 Amendment and Its Impact

A technical breakdown of Section 185 after the 2023 amendment: the surviving prohibition, the special resolution gateway, and the documentation conditions that determine whether a director loan is defensible before the ROC or NCLT.

29 Oct 2026

Companies Act / Treasury & Investment Compliance

Section 186 Loans and Investments: Calculating the 60%/100% Limits

How the 60%/100% outer limit actually works, why the higher figure governs, and the three-tier approval chain that determines when a board resolution is no longer sufficient for loans, guarantees, securities, and investments.

29 Oct 2026

Companies Act / Inter-Corporate Transactions

Inter-Corporate Deposits (ICDs) and Section 186 Compliance

The ICD is not a standalone instrument. It is a Section 186 deployment that must satisfy the aggregate ceiling, the board-resolution-first rule, and the G-sec floor on interest—three conditions that are tested independently.

29 Oct 2026

Work with ADA

Ready to talk to an advisor?

Book a consultation and get a clear, considered view from a team that handles audit, tax, regulatory and cross-border work under one roof.