ICSI requests Extension for filing Form CSR-2 due to MCA Portal Issues

The Institute of Company Secretaries of India (ICSI) has recently requested the Ministry of Corporate Affairs (MCA) to extend the due date for filing Form CSR-2, owing to the issues faced by Company Secretaries due to MCA Portal issues.

The communication dated March 21, 2023 stated “We wish to draw your kind attention towards provisions of Rule 12(lB) of the Companies (Accounts) Rules, 2014. It provides that every company covered under the provisions of sub-section (l) Io section 1.35 of the Act shall furnish a report on Corporate Social Responsibility in Form CSR-2 to the Registrar for the preceding financial year (2020-2021) and onwards as an addendum to Form AOC-4 or AOC-4 XBRL or AOC-4 NBFC (Ind AS), as the case may be.

It further provides that for the FY 2021-22, Form CSR-2 shall be filed separately on or before

March 31, 2023 after filing Form AOC-4 or AOC-4 XBRL or AOC-4 NBFC (Ind AS), as the case may be.

Accordingly, the last date for filing Form CSR-2 for the financial year ending March 31, 2022 is March 31, 2023. However, professionals and corporates are still facing difficulties in filing Form CSR-2. As informed by professionals, the difficulties being faced are as under:

Unable to fill the form as some of the tabs are not working

Unable to edit the fields of the Form

Unable to submit after filling the form – while trying to ‘submit’, the form shows some service error

in case, the Form gets submitted, upon clicking on the download button for affixing DSC, it shows ‘our apologies’

Unable to download after pre-scrutiny

Showing DSC not registered even when the sallie DSC is used for other V2 and V3 filing

In case of NO ongoing project, unable to fill as NA/O and fill the Form)”

In view of the above, it was requested to extend the timelines to file Form CSR-2 by the companies for the preceding financial year 2021-22 from March 3 1, 2023 to June 30, 2023.

Further, the instruction kit to Form CSR-2 provides that Form CSR-2 is to be filed as ‘addendum’ to Form AOC-4 with respect to financial year 2020-21 onwards. This is in contradiction to Rule 12(1 B) of the Companies (Accounts) Rules, 2014 and hence needs to be modified, the letter from ICSI further stated.

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