Indian Corporate Law

Corporate Social Responsibility (CSR) Rules in India

Corporate Social Responsibility (CSR) Rules in India A Complete 2026 Guide — Laws, Thresholds, Compliance & Best Practices CSR in India Corporate Social Responsibility (CSR) is no longer a voluntary goodwill gesture in India — it is a statutory obligation enshrined in law. India became one of the first countries in the world to make CSR spending mandatory when Section 135 of the Companies Act, 2013 came into force. Over the past decade, the CSR framework has evolved significantly, and as of 2026, it stands as one of the most robust and structured corporate governance mechanisms in the country. In the financial year 2024-25 alone, India’s top listed companies collectively spent over ₹25,000 crore on CSR activities, touching millions of lives across education, healthcare, environment, and rural development. The Ministry of Corporate Affairs (MCA) continues to tighten compliance norms, making it imperative for every eligible business to understand the rules thoroughly. This comprehensive guide covers every dimension of India’s CSR rules — the legal framework, eligibility thresholds, approved activities, unspent fund management, penalties, reporting requirements, and best practices — all updated for 2026. Legal Framework Governing CSR in India Section 135 of the Companies Act, 2013 The primary legal basis for CSR in India is Section 135 of the Companies Act, 2013, read together with Schedule VII of the Act and the Companies (Corporate Social Responsibility Policy) Rules, 2014 (as amended). The law makes it mandatory for qualifying companies to spend a minimum of 2% of their average net profits on CSR activities. Key Amendments and Updates (2020–2026) The CSR framework has undergone multiple amendments since 2013. The most significant overhaul came through the Companies (Amendment) Act, 2019 and the revised CSR Rules notified in January 2021. Further amendments in 2022 and 2023 strengthened monitoring and reporting. In 2026, the MCA has introduced enhanced digital reporting requirements via the CSR-2 form and mandatory geo-tagging of CSR projects. Governing Ministry & Regulatory Authority The Ministry of Corporate Affairs (MCA) is the primary regulator overseeing CSR compliance in India. The National Stock Exchange (NSE) and Bombay Stock Exchange (BSE) also mandate Business Responsibility and Sustainability Reports (BRSR) for the top 1,000 listed companies by market capitalisation, adding another layer of accountability. CSR Eligibility Criteria for Companies in 2026 As per Section 135(1) of the Companies Act, 2013, a company is required to constitute a CSR Committee and spend on CSR if it meets any ONE of the following financial thresholds in any of the immediately preceding three financial years: Criterion Threshold Net Worth ₹500 crore or more Turnover ₹1,000 crore or more Net Profit ₹5 crore or more (net profit as per Section 198) Note: The thresholds apply to every company including holding or subsidiary companies, and foreign companies having their branch or project office in India. Constitution of the CSR Committee Composition Requirements Every eligible company must constitute a CSR Committee of the Board of Directors. The composition requirements under Section 135(1) are: Minimum three directors, including at least one Independent Director For companies not required to appoint an Independent Director: at least two directors For private companies with a single director: that director alone may constitute the committee For foreign companies: two persons, one of whom shall be the person resident in India authorised to accept service of process Functions of the CSR Committee Formulate and recommend the CSR Policy to the Board Recommend the amount of expenditure to be incurred on CSR activities Monitor the CSR Policy of the company from time to time Review and approve annual CSR Action Plans Ensure that the Annual Report on CSR is prepared and placed before the Board The 2% CSR Spending Mandate — How to Calculate Calculating Average Net Profit The mandatory CSR spend is 2% of the average net profits made during the three immediately preceding financial years. Net profit for this purpose is calculated as per Section 198 of the Companies Act, 2013, which has specific inclusions and exclusions different from the P&L account profit. Inclusions in Net Profit (Section 198) Profit from operations of the company Bounties and subsidies received from any Government Profit on sale of immovable property or fixed assets Profit from shares, debentures, or other securities Exclusions from Net Profit (Section 198) Capital gains arising from sale of investments and assets Profits of foreign subsidiaries Dividend paid or payable Any amount representing unrealised gains or notional gains Worked Example (FY 2025-26) Financial Year Net Profit (₹ Crore) FY 2022-23 80 FY 2023-24 100 FY 2024-25 120 Average 100 2% CSR Obligation ₹2 Crore Approved CSR Activities — Schedule VII (Updated 2026) Schedule VII of the Companies Act, 2013 lists the activities eligible for CSR spending. The list has been progressively expanded. Here are all approved CSR activity heads as of 2026: 1. Eradicating Hunger, Poverty & Malnutrition Activities promoting preventive healthcare, sanitation, and safe drinking water. This includes mid-day meal programs, nutrition initiatives, anganwadi support, and clean drinking water projects. PM POSHAN and Jal Jeevan Mission aligned activities are eligible. 2. Promoting Education Activities relating to education — including special education, vocational skills development among children, women, elderly, and the differently abled — qualify under CSR. Setting up schools, providing scholarships, digital literacy programs, and supporting Government schools with infrastructure are all covered. 3. Promoting Gender Equality & Women Empowerment Setting up homes, hostels for women and orphans; old age homes; day care centres; and other facilities for senior citizens; measures for reducing inequality faced by socially and economically backward groups. Self-help group funding and livelihood support for women entrepreneurs are covered. 4. Ensuring Environmental Sustainability Ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources, and maintaining quality of soil, air, and water. Clean energy projects, EV infrastructure, renewable energy installations, and climate action programs qualify here. 5. Protection of National Heritage, Art & Culture Protection and restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional arts

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Foreign Subsidiary of Indian Company

Foreign Subsidiary of an Indian Company: The Ultimate A-to-Z Guide for 2026 India’s economy has grown to become one of the world’s largest, and Indian companies are aggressively expanding their global footprint. Setting up a foreign subsidiary has become a strategic necessity for Indian businesses aiming to access new markets, optimise tax structures, acquire foreign talent, and build a globally recognised brand. In 2026, with updated RBI guidelines, revised FEMA regulations, and India’s new overseas investment framework, the process is more structured — and more exciting — than ever before. This comprehensive guide covers everything an Indian promoter, CFO, or legal counsel needs to know: what a foreign subsidiary is, how it differs from other structures, the step-by-step process under current law, tax implications, compliance requirements, funding routes, and much more. 1. What is a Foreign Subsidiary of an Indian Company? A foreign subsidiary is a company incorporated in a foreign country in which an Indian parent company holds more than 50% of the voting equity share capital, either directly or through another subsidiary. The parent company (the Indian entity) is called the holding company, and the overseas entity is the subsidiary. Under the Foreign Exchange Management (Overseas Investment) Rules, 2022 — which replaced the earlier ODI (Overseas Direct Investment) framework — and subsequent RBI Master Directions updated through 2025-26, the definition and compliance requirements for such subsidiaries are clearly laid out. 💡  A Wholly Owned Subsidiary (WOS) is a special type where the Indian parent owns 100% of the share capital of the foreign entity. 2. Types of Foreign Business Structures for Indian Companies Before incorporating a foreign subsidiary, it is essential to understand the different structures available: Structure Ownership Liability Tax Treatment Best For Wholly Owned Subsidiary (WOS) 100% Indian parent Separate legal entity Local + Indian CFC rules Full control, large operations Joint Venture (JV) Shared with foreign partner Separate entity Depends on JV agreement Market entry with local partner Branch Office Extension of Indian company Parent bears liability Taxed in both countries Limited service operations Representative / Liaison Office Extension — no commercial activity Parent bears liability Not taxable (no revenue) Market research, promotion Project Office Temporary setup for a project Limited to project duration Project-based taxation Specific contracts/projects 3. Why Indian Companies Set Up Foreign Subsidiaries in 2026 The motivations for Indian companies to establish foreign subsidiaries have evolved significantly. In 2026, the top strategic reasons include: Market Access & Global Expansion: Direct presence in target markets (USA, UAE, Singapore, UK) enables sales, customer service, and brand building. Technology & IP Acquisition: Many Indian IT and pharma companies set up subsidiaries in innovation hubs to acquire patents, software, and R&D capabilities. Tax Efficiency: Jurisdictions like Singapore (17% corporate tax, 0% on qualifying dividends) and UAE (9% with free zone benefits) offer tax advantages over India’s 25-30% corporate tax rate. Access to Foreign Capital: A foreign subsidiary can raise foreign currency loans, issue equity to foreign investors, and tap global capital markets more easily. Talent Pool: Hiring globally skilled professionals in their local jurisdiction while leveraging Indian management expertise. Regulatory Advantages: Certain industries (e.g., fintech, crypto) have more favourable regulatory environments abroad. Currency Diversification: Revenue in USD, EUR, or AED protects against INR depreciation risk. Listing Abroad: A foreign subsidiary can be the vehicle for an IPO on NYSE, NASDAQ, SGX, or other exchanges, while the Indian parent retains control. 4. Legal Framework Governing Foreign Subsidiaries in 2026 4.1 Foreign Exchange Management Act (FEMA), 1999 FEMA is the primary law governing all cross-border financial transactions by Indian residents and entities. The Foreign Exchange Management (Overseas Investment) Rules, 2022 (OI Rules) and the Foreign Exchange Management (Overseas Investment) Regulations, 2022 (OI Regulations) form the core framework, as updated by RBI circulars through March 2026. 4.2 Overseas Direct Investment (ODI) — Key Definitions ODI means investment by an Indian entity in the equity capital of a foreign entity, or subscribing to the Memorandum of Association of a foreign entity. An Indian entity includes companies, LLPs, registered partnership firms, and individuals under Liberalised Remittance Scheme (LRS). Financial Commitment means the total financial exposure by an Indian entity to its foreign investment — including equity, loans, and guarantees. 4.3 Automatic Route vs. Approval Route Criterion Automatic Route Approval Route (RBI/Govt) Who approves No prior approval — only post-facto filing with AD bank RBI or Government of India Financial Commitment Limit Up to 400% of Net Worth of Indian entity Beyond 400% of Net Worth Sector Any sector not in negative list Financial Services sector, Pakistan/FATF-blacklisted countries Step-down subsidiary Allowed — subsidiary can invest further Additional compliance required Timing of Investment Anytime after filing Form ODI Only after approval ⚠️  Note: As of April 2026, RBI has clarified that investments in the financial services sector abroad (banking, insurance, NBFC) by Indian entities require prior RBI approval regardless of amount. 4.4 Companies Act, 2013 — Sections Relevant to Foreign Subsidiaries Section 2(87): Defines ‘subsidiary company’ — more than 50% of total voting power or control of composition of the board. Section 186: Loans and investments by companies — applicable even for overseas loans to subsidiaries. Section 129: Preparation of consolidated financial statements including foreign subsidiaries. Section 139/143: Auditor’s reporting obligations extend to subsidiaries. Schedule III (Amendment 2021, effective 2022): Mandatory disclosure of foreign subsidiary details in the parent’s financial statements. 5. Eligible Indian Entities — Who Can Set Up a Foreign Subsidiary? Not every Indian entity can invest abroad. Here are the eligibility criteria under the current framework: Entity Type Eligible? Conditions Indian Company (Pvt/Public) Yes Must have net profit in 3 of preceding 5 years; no regulatory actions pending LLP registered in India Yes Subject to FEMA OI Rules; RBI general permission for ODI Registered Partnership Firm Yes (limited) Only in operating entities; not in financial services Proprietorship / Individual Yes (via LRS) Up to USD 2,50,000 per financial year under LRS Resident Individual (via LRS) Yes USD 2,50,000 per year ceiling; for operating business, personal investment Startups (DPIIT Recognised)

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