How to Choose a CSR Implementing Agency in India: A Checklist

For many companies in India, the hardest part of CSR is not deciding to give. It is choosing who to give through. The right implementing agency turns your CSR budget into outcomes you can report with confidence. The wrong one creates compliance headaches, weak reporting and a project nobody wants to talk about in the annual report.

This guide is for CSR heads, foundation managers and finance teams. It walks through the legal basics, a practical due diligence checklist, the questions worth asking at a site visit, and why skill-based programmes for women are a strong fit for many CSR portfolios.

A quick recap of the CSR rules

Section 135 of the Companies Act, 2013 requires companies that meet any one of these thresholds in the preceding financial year to spend on CSR:

• net worth of ₹500 crore or more;
• turnover of ₹1,000 crore or more;
• net profit of ₹5 crore or more.

These companies must spend at least 2% of their average net profits of the three immediately preceding financial years on activities listed in Schedule VII. They can run projects themselves or through an implementing agency.

Two Schedule VII items are directly relevant to women’s skills programmes: promoting education, including employment-enhancing vocational skills, especially among women, and promoting gender equality and empowering women. Always confirm with your CSR committee and advisers how a specific project maps to Schedule VII.

What makes an NGO eligible as an implementing agency?

Under the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended in 2021, an implementing agency such as a registered public trust, a registered society or a Section 8 company must:

• be registered with the Central Government by filing Form CSR-1 on the MCA portal, which gives it a CSR registration number;
• hold registrations under Sections 12A and 80G of the Income-tax Act;
• for most independent NGOs, have an established track record of at least three years in similar activities.

These are minimum requirements, not a sign of quality. An agency can tick every legal box and still run a weak programme, which is why the checks below matter.

A due diligence checklist for CSR teams

Legal and governance documents

• Trust deed, society registration or Section 8 incorporation documents;
• CSR-1 registration and the CSR registration number;
• 12A and 80G certificates, and their validity periods;
• PAN, and registration on NITI Aayog’s NGO Darpan portal if your policy requires it;
• the list of trustees or board members, and a conflict of interest policy;
• policies on child and beneficiary protection, prevention of sexual harassment and procurement.

Financial health

• audited financial statements for at least the last three years;
• income tax returns and the auditor’s report;
• the share of spending that goes to programmes compared with administration;
• diversity of funding, so the programme does not collapse if one donor leaves;
• bank account details that match the registered name exactly.

Programme quality

• a clear theory of change: who the programme serves, what changes and how;
• a defined curriculum, duration and selection process for beneficiaries;
• qualified trainers and adequate infrastructure;
• outcome data, not just activity counts. For a skills programme, ask about completion, placement and income after training.

Monitoring and reporting

• the frequency and format of progress reports;
• willingness to share beneficiary-level data, with consent and privacy safeguards;
• utilisation certificates and fund-wise accounting;
• readiness to support an independent impact assessment. Under the CSR Rules, companies with an average CSR obligation of ₹10 crore or more must commission independent impact assessments for projects with outlays of ₹1 crore or more.

Remember that the board must satisfy itself that funds were used for the approved purposes, and the CFO must certify this. Choosing an agency with strong reporting makes that step far easier.

Questions to ask on a site visit

1. Can we meet current students or beneficiaries, and hear from them without staff in the room?
2. How do you select beneficiaries, and how do you verify eligibility?
3. What happens to a beneficiary after the programme ends?
4. What did not work last year, and what did you change?
5. Who will be our day-to-day contact, and how quickly do they respond?
6. Can you show us a sample quarterly report from an existing partner?
7. How will our contribution be accounted for separately?

Red flags

• reluctance to share audited accounts or registration certificates;
• outcome claims with no data, or numbers that change between documents;
• offers to return part of the grant or route funds elsewhere;
• a bank account in a name different from the registered entity;
• no clear plan for what happens if targets are missed.

Why skill-based programmes for women are a strong CSR choice

Programmes that train women for jobs combine two Schedule VII themes, education and women’s empowerment, and their outcomes are measurable. You can track how many women enrolled, completed training, found work and what they earn. Media and digital skills are especially relevant, because demand for video, design and content work keeps growing across businesses of every size.

About Karuna Media and PPET

Puppets Picture Education Trust (PPET), Noida, runs the Karuna Media Master Program (KMMP), a 12-month, studio-led programme that trains young women from low-income families in filmmaking, video editing, photography, audio, graphic design and AI content creation, followed by career preparation and placement support.

For CSR teams, the donate and partnership page lists PPET’s legal registrations, including the Trust Deed, 12A, 80G, CSR-1 and ISO 9001:2015, along with downloadable audited financial statements. CSR partners receive quarterly impact reports and audited statements, and the About page sets out the Trust’s governance, policies and monitoring approach.

If your team is shortlisting implementing agencies for women’s education and livelihood projects, we would welcome your due diligence. Use the CSR Donation and Partnership Form on our donate page to request documents or a site visit to our Noida studios. You can also see the facilities on the infrastructure page before you visit.

Choose with care

A good implementing agency is a long-term partner, not a vendor. Take the time to check documents, visit the programme and ask hard questions. The effort you put in before signing an MoU is what makes your CSR report worth reading a year later.