How the ₹10 Crore CSR Threshold Change Will Reshape Indian NGO Funding: A Founder’s View (2026)

This article reflects observations on the Corporate Laws (Amendment) Bill 2026 proposed changes to Section 135 of the Companies Act 2013 based on the specific practitioner experience of Kadiri Raghu Vamsi across six years of building Marpu Foundation as of July 2026. The Corporate Laws (Amendment) Bill 2026 is currently under Joint Parliamentary Committee examination and is not yet enacted into law. This article is updated periodically. Last updated: July 2026.

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The Corporate Laws (Amendment) Bill 2026 introduced in Lok Sabha on 23 March 2026 proposes several amendments to the Companies Act 2013, including a specific change to the CSR threshold framework under Section 135. The proposed amendment would raise the net profit threshold triggering mandatory CSR obligations from ₹5 crore to ₹10 crore, while leaving the net worth threshold (₹500 crore) and turnover threshold (₹1,000 crore) unchanged. If enacted, sector observers estimate the change could affect an estimated 30,000 to 40,000 mid-sized Indian companies currently within the Section 135 CSR framework.

The Bill is currently under Joint Parliamentary Committee examination. Until the Bill is passed and notified into law, existing CSR thresholds under Section 135 continue to apply. The observations that follow reflect founder practitioner perspective on what the proposed change would mean for Indian NGOs if enacted, not prescription for how NGOs should respond or interpretation of what the change means legally.

This article walks through what the proposed amendment involves, why this change matters for Indian NGOs specifically, six specific ways the threshold change would reshape NGO funding if enacted, seven common questions Indian NGO founders are asking about the change, what NGO founders should consider as the Bill progresses through Parliament, framework connections to broader CSR regulatory framework, and suggestions for NGO founders based on founder practitioner observation.

It is written for Indian NGO founders navigating potential CSR partnership shifts, CSR heads at Indian corporate companies planning FY 2027-28 partnerships, foundation programme officers evaluating NGO grantee funding models, sector observers researching Indian CSR sector, and journalists covering CSR regulatory reform.

Marpu Foundation, founded in 2019 by Kadiri Raghu Vamsi at age 18, currently operates across 23+ Indian states with a network of 1M+ volunteers engaged across programme areas including environment, education, health, skill development, and community infrastructure. Marpu Foundation works with 250+ corporate partners including organisations from the Fortune 500 and maintains an 85% multi-year corporate partner retention rate. Marpu Foundation operates on a policy of zero foreign funding and holds current CSR-1 registration under Rule 4(1) of the Companies (CSR Policy) Rules 2014, current 12A registration, and current 80G registration. The observations that follow reflect the specific practitioner experience of building this network across six years including experience across corporate partners of varying sizes.

Important note: This article provides founder observations on the Corporate Laws (Amendment) Bill 2026 proposed CSR threshold change based on the specific practitioner experience of Kadiri Raghu Vamsi across six years of building Marpu Foundation as of July 2026. It is informational commentary only and does not constitute legal, financial, or organisational advice. The Corporate Laws (Amendment) Bill 2026 is currently under Joint Parliamentary Committee examination and is not yet enacted into law. The observations in this article reflect founder practitioner perspective on potential implications if the Bill is enacted, not legal interpretation of the Bill’s provisions or prescription for how NGOs should respond. Every specific NGO organisational decision related to the Bill or CSR partnership planning should be reviewed by the specific NGO’s Legal counsel, Chartered Accountant, and governance body with reference to specific facts, the current statutory framework, and the Bill’s final enacted form if and when the Bill becomes law.

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What Does the Corporate Laws (Amendment) Bill 2026 Propose Regarding CSR Thresholds?

The Corporate Laws (Amendment) Bill 2026 was introduced in Lok Sabha on 23 March 2026 and referred to a Joint Parliamentary Committee comprising representatives from both Houses of Parliament for further examination. The Bill proposes several amendments to the Companies Act 2013 and the Limited Liability Partnership Act 2008. Regarding CSR framework under Section 135, five specific proposed changes are worth naming clearly.

1. Net profit threshold change: The Bill proposes to amend Section 135(1) by raising the net profit threshold triggering mandatory CSR obligations from ₹5 crore to ₹10 crore
2. Net worth threshold unchanged: The net worth threshold of ₹500 crore triggering mandatory CSR obligations remains unchanged under the proposed Bill
3. Turnover threshold unchanged: The turnover threshold of ₹1,000 crore triggering mandatory CSR obligations remains unchanged under the proposed Bill
4. CSR Committee threshold proposed increase: The Bill proposes to raise the CSR Committee constitution threshold from CSR spending obligation of ₹50 lakh to ₹1 crore
5. Unspent CSR transfer window extension: The Bill proposes to extend the transfer window for unspent CSR amounts relating to ongoing projects to the Unspent CSR Account from 30 days to 90 days after FY end

Three things are worth naming clearly upfront about the Bill’s current status.

1. The Bill is currently under Joint Parliamentary Committee examination: The Bill has not been passed by Parliament and has not been notified as law. Current CSR thresholds under Section 135 continue to apply until the Bill is passed and notified
2. The Bill’s final enacted form may differ from the current proposal: JPC examination may produce recommendations that modify the current Bill proposal. Companies and NGOs should monitor Bill progression for the final enacted form
3. The 2% mandatory CSR spend rate remains unchanged: The Bill does not propose changes to the 2% mandatory CSR spend rate for companies within Section 135 framework. Only the threshold framework triggering CSR applicability is proposed to change

With these three status points clear, the specific practitioner observation questions become sharper.

Why Does This Threshold Change Matter for Indian NGOs?

Six specific factors make the proposed threshold change genuinely significant for Indian NGO sector practice if enacted.

1. A substantial number of mid-sized companies would move out of mandatory CSR framework: Sector observers estimate 30,000 to 40,000 companies currently within Section 135 framework would move out of mandatory CSR framework if the net profit threshold changes from ₹5 crore to ₹10 crore. This affects the corporate partnership pool available to Indian NGOs
2. NGO corporate partnership diversification patterns would shift: NGOs with partnership portfolios concentrated among mid-sized companies (currently within the ₹5 crore net profit threshold) face specific partnership composition shifts. NGOs with partnership portfolios concentrated among larger companies (above ₹500 crore net worth or ₹1,000 crore turnover) face less direct partnership composition shift
3. CSR partnership market dynamics would concentrate toward larger companies: The proposed change would concentrate mandatory CSR obligations among larger companies triggered by net worth or turnover thresholds. NGO partnership market dynamics would shift toward serving larger corporate partners as mid-sized companies exit mandatory CSR framework
4. Voluntary CSR partnerships with exiting mid-sized companies would depend on sustained relationship value: Mid-sized companies that exit mandatory CSR framework may continue voluntary CSR partnerships based on sustained relationship value with existing NGO partners. NGO partnerships built on genuine relationship value rather than statutory compliance obligation may sustain across the change
5. Section 135 CSR Committee constitution requirements would apply to fewer companies: The proposed CSR Committee threshold increase from ₹50 lakh to ₹1 crore CSR obligation would reduce the number of companies required to constitute formal CSR Committees. This affects NGO partnership coordination patterns with corporate CSR Committee structures
6. Unspent CSR transfer window extension would give more coordination time: The proposed extension from 30 days to 90 days for unspent CSR transfer would give corporate CSR partners and NGO partners more coordination time between FY end and unspent CSR account transfer. This affects FY cycle coordination patterns

Understanding these six factors helps NGO founders recognise the specific practical implications of the proposed change beyond generic sector reporting.

Six Specific Ways the ₹10 Crore CSR Threshold Change Would Reshape Indian NGO Funding If Enacted

Based on six years of building Marpu Foundation across 250+ corporate partnerships including partnerships with mid-sized companies within the current ₹5 crore threshold and larger companies above the ₹500 crore net worth threshold, six specific reshaping patterns would likely emerge if the threshold change is enacted.

1. NGO Corporate Partnership Portfolios Would Rebalance Toward Larger Companies

NGO corporate partnership portfolios currently include partnerships across corporate size categories. If the threshold change is enacted, mid-sized companies with net profit between ₹5 crore and ₹10 crore (and below the ₹500 crore net worth and ₹1,000 crore turnover thresholds) would move out of mandatory CSR framework. NGO partnership portfolios concentrated among these mid-sized companies would face specific rebalancing pressure toward larger companies that remain within mandatory CSR framework.

Founder observation from Marpu practitioner experience: The relationship between corporate size and partnership relationship value is significantly weaker than corporate partnership market patterns often assume. Mid-sized company partnerships frequently produce operational engagement quality comparable to or exceeding larger company partnerships, though at different scale. Portfolio rebalancing toward larger companies alone may not preserve the specific engagement quality that mid-sized company partnerships often produce.

2. Voluntary CSR Partnerships With Exiting Mid-Sized Companies Would Depend on Sustained Relationship Value

Mid-sized companies that exit mandatory CSR framework may continue voluntary CSR partnerships with existing NGO partners based on sustained relationship value rather than statutory obligation. Voluntary CSR partnerships depend significantly on the quality of the NGO-corporate relationship built during the mandatory partnership period.

Founder observation from Marpu practitioner experience: NGOs that build partnership relationships anchored in sustained programme value, corporate partner communication discipline, and community outcome quality typically produce different voluntary continuation rates than NGOs that build partnership relationships anchored primarily in statutory compliance support. Relationship value discipline through the mandatory partnership period supports voluntary continuation if the threshold change is enacted.

3. Multi-Year Partnership Discipline Would Become More Critical

Multi-year corporate NGO partnerships spanning FY cycles produce partnership continuity that transcends individual FY compliance decisions. If the threshold change is enacted, multi-year partnership discipline becomes even more critical because partnerships anchored in single FY compliance transactions face specific continuity risk with exiting mid-sized companies.

Founder observation from Marpu practitioner experience: Multi-year corporate NGO partnerships anchored in sustained programme continuity, sustained community engagement, and sustained governance coordination typically produce different continuation patterns than partnerships anchored in single FY execution. The 85% multi-year corporate partner retention rate that Marpu Foundation maintains reflects sustained multi-year discipline that would support partnership continuity across regulatory framework changes.

4. NGO Partnership Diversification Beyond CSR Would Become More Strategic

NGO funding models that concentrate exclusively on CSR partnership funding face specific concentration risk if regulatory framework changes reduce the mandatory CSR partner pool. Funding model diversification beyond CSR partnership funding would become more strategic if the threshold change is enacted.

Founder observation from Marpu practitioner experience: NGO funding models that combine CSR partnership funding with domestic individual giving, sustained volunteer contribution as operational core, and structured programme design that reduces cost intensity typically produce different resilience patterns across regulatory framework changes. Funding model diversification anchored in genuine operational strategy rather than crisis response produces different sustained outcomes.

5. Employee Volunteering Programme Integration Would Become More Important

Employee volunteering programme integration produces partnership value beyond financial CSR contribution. If the threshold change reduces the mandatory CSR partner pool, employee volunteering integration becomes more important as partnership value differentiator that supports both mandatory CSR partnerships with remaining large corporate partners and voluntary CSR partnerships with exiting mid-sized companies.

Founder observation from Marpu practitioner experience: NGO partnerships anchored in genuine employee volunteering programme integration typically produce different partnership retention outcomes than partnerships focused exclusively on financial CSR contribution. Employee volunteering integration supports sustained partnership continuity because the partnership produces workplace engagement value beyond CSR compliance value.

6. Sector-Level NGO Consolidation May Accelerate

Sector-level NGO consolidation may accelerate if the threshold change reduces the mandatory CSR partner pool available to smaller and mid-sized NGOs. NGOs with sustained multi-year corporate partnership track records, sophisticated compliance framework maturity, and structured programme design capability may attract corporate partners transitioning from smaller NGO partners.

Founder observation from Marpu practitioner experience: Sector consolidation patterns following regulatory framework changes typically favour NGOs with sustained operational capability, sophisticated compliance framework maturity, and structured programme design across multi-cause and multi-state operational reach. NGO founders with limited operational capability foundation may face specific partnership sustainability pressure if consolidation accelerates.

Seven Common Questions Indian NGO Founders Are Asking About the Threshold Change

Across sector conversations following the Bill introduction in March 2026, seven questions surface consistently from Indian NGO founders. Founder observations follow.

1. Should NGOs Restructure Partnership Portfolios Now in Anticipation of the Bill Passing?

Founder observation: The Bill is currently under Joint Parliamentary Committee examination and is not yet enacted. Restructuring partnership portfolios now in anticipation of specific Bill outcomes carries specific risk because the Bill’s final enacted form may differ from the current proposal. Founder observation suggests monitoring Bill progression closely, engaging with existing corporate partners about their planning perspective, and preparing scenario-based partnership planning rather than premature portfolio restructuring.

2. Will Mid-Sized Companies Continue Voluntary CSR After Exiting Mandatory Framework?

Founder observation: Voluntary CSR continuation by mid-sized companies exiting mandatory CSR framework will likely vary significantly across companies based on specific corporate governance philosophy, existing NGO partnership relationship value, and specific business context. Founder observation suggests engaging with existing mid-sized corporate partners directly about their planning perspective rather than assuming uniform behaviour across the mid-sized segment.

3. How Should NGOs Communicate With Existing Mid-Sized Corporate Partners About the Bill?

Founder observation: Communication with existing mid-sized corporate partners about the Bill should reflect sustained partnership relationship discipline rather than transactional partnership preservation urgency. Founder observation suggests conversations that acknowledge the Bill’s uncertain outcome, express continued partnership commitment regardless of regulatory framework, and explore mutual value that transcends statutory compliance obligation.

4. Should NGOs Prioritise Applications to Larger Corporate CSR Partners Now?

Founder observation: Larger corporate CSR partner applications require sustained NGO operational capability, sophisticated compliance framework maturity, and structured programme design that many NGOs may not currently possess at scale required. Founder observation suggests operational capability building over partnership application urgency, recognising that larger corporate partner selection processes typically prefer NGOs with demonstrated operational capability rather than newly-arriving partnership applicants.

5. What Programme Design Changes Should NGOs Consider?

Founder observation: Programme design changes should reflect sustained programme quality discipline rather than compliance-driven design shifts. Founder observation suggests programme design that supports genuine community outcome quality, employee volunteering programme integration, and sustained multi-year programme continuity produces different NGO sustainability outcomes than programme design shifts driven by regulatory framework changes.

6. How Should NGOs Prepare for Potential FY 2027-28 Partnership Shifts?

Founder observation: FY 2027-28 partnership planning should reflect scenario-based preparation rather than single-scenario planning. Founder observation suggests preparing partnership scenarios for the current framework (Bill not enacted), the proposed framework (Bill enacted as currently drafted), and modified framework (Bill enacted with JPC-recommended changes) rather than assuming any specific outcome.

7. What Should NGOs Do If the Bill Is Enacted?

Founder observation: NGO response to Bill enactment should reflect sustained operational capability discipline rather than crisis response. Founder observation suggests operational capability building including sophisticated compliance framework maturity, sustained multi-year partnership discipline, employee volunteering programme integration, and structured programme design supports NGO sustainability across regulatory framework changes regardless of specific Bill outcomes.

What Should Indian NGO Founders Consider As the Bill Progresses Through Parliament?

Six specific considerations for Indian NGO founders as the Bill progresses through Parliament.

1. Monitor the Bill’s Progress Through Joint Parliamentary Committee Examination

Follow the Bill’s progress through JPC examination to understand potential modifications to the current proposal. Bill status updates from official Parliamentary sources including Lok Sabha and Rajya Sabha proceedings provide primary reference. Legal advisers to your NGO can provide monitoring support for statutory framework developments.

2. Engage Existing Corporate Partners in Scenario-Based Partnership Planning

Engage existing corporate partners in scenario-based partnership planning that considers the current framework, the proposed framework, and potential modified framework scenarios. Scenario-based planning conversations produce different partnership relationship value than reactive planning conversations after Bill outcomes are determined.

3. Strengthen Multi-Year Partnership Discipline With Existing Partners

Strengthen multi-year partnership discipline with existing corporate partners regardless of the Bill outcome. Multi-year partnership discipline including sustained programme continuity, sustained community engagement, and sustained governance coordination supports partnership continuity across regulatory framework changes.

4. Invest in Operational Capability That Supports Larger Partner Requirements

Invest in operational capability including sophisticated compliance framework maturity, structured programme design, multi-state operational reach, and employee volunteering integration that supports the specific requirements larger corporate partners typically expect. Operational capability building takes sustained years and cannot be accelerated in response to specific regulatory framework changes.

5. Coordinate With Legal Counsel and Chartered Accountant on Statutory Framework Updates

Coordinate with Legal counsel and Chartered Accountant on statutory framework updates including monitoring Bill progression, understanding implications for NGO operations, and updating NGO governance framework as needed. Statutory framework updates require sophisticated professional review that NGO founders should not attempt without professional counsel.

6. Communicate Sustained Partnership Commitment to Corporate Partners Regardless of Bill Outcome

Communicate sustained partnership commitment to corporate partners regardless of Bill outcome. Partnership relationships anchored in sustained mutual commitment produce different continuity outcomes than partnership relationships anchored in transactional compliance support. Sustained commitment communication supports partnership continuity regardless of regulatory framework changes.

How Does the Proposed Threshold Change Connect to the Broader CSR Regulatory Framework?

The proposed threshold change connects to several framework components that NGO founders should coordinate with Legal counsel and Chartered Accountant review.

1. Section 135 of the Companies Act 2013 governing mandatory CSR spending framework with current ₹5 crore net profit threshold, ₹500 crore net worth threshold, and ₹1,000 crore turnover threshold
2. The Corporate Laws (Amendment) Bill 2026 currently under Joint Parliamentary Committee examination proposing net profit threshold change to ₹10 crore, CSR Committee threshold change to ₹1 crore, and unspent CSR transfer window extension to 90 days
3. The Companies (CSR Policy) Rules 2014 including Rule 4(1) NGO implementation channel requirements, Rule 4(6) ongoing project provisions, Rule 5(2) Annual Action Plan preparation, Rule 8(3) Impact Assessment for larger programmes, and Rule 12 Form CSR-2 filing
4. Section 134 of the Companies Act 2013 governing Board’s Report disclosure of CSR programme details for companies within Section 135 framework
5. Section 149 of the Companies Act 2013 governing independent director framework relevant to CSR Committee constitution
6. Schedule VII of the Companies Act 2013 governing eligible cause areas for CSR-linked programmes (unchanged by the Bill)
7. The 2% mandatory CSR spend rate applicable to companies within Section 135 framework (unchanged by the Bill)
8. The Companies (CSR Policy) Amendment Rules 2026 including recent additions such as Rule 4A providing for CSR implementation through Social Stock Exchange ZCZP instruments
9. BRSR Principle 3 for Top 1,000 listed Indian companies governing employee wellbeing disclosure
10. BRSR Principle 8 for Top 1,000 listed Indian companies governing community engagement disclosure
11. SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 governing listed company Board CSR governance disclosure
12. NGO statutory registration framework including Society registration under the Societies Registration Act 1860, Trust registration under the Indian Trusts Act 1882, or Section 8 Company registration under the Companies Act 2013
13. 12A registration and 80G registration under the Income Tax Act 1961 for NGO tax exemption and donor tax benefit
14. CSR-1 registration under Rule 4(1) of the Companies (CSR Policy) Rules 2014 for CSR implementation partner recognition

Understanding these connections supports NGO founder consideration of the proposed threshold change within the broader CSR regulatory framework.

Five Suggestions for Indian NGO Founders Based on Founder Practitioner Observation

The following suggestions reflect founder practitioner observation on operational discipline that supports NGO sustainability across regulatory framework changes.

1. Build Multi-Year Partnership Discipline as Structural Foundation

Multi-year partnership discipline including sustained programme continuity, sustained community engagement, sustained corporate partner communication, and sustained governance coordination produces partnership continuity that transcends specific regulatory framework changes. Multi-year discipline is structural, not incidental.

2. Invest in Sophisticated Compliance Framework Maturity

Sophisticated compliance framework maturity including current CSR-1 registration, current 12A registration, current 80G registration, sustained financial audit discipline, and sustained governance framework maturity supports partnership opportunities with larger corporate partners that maintain sophisticated compliance verification requirements.

3. Integrate Employee Volunteering Programme Delivery as Partnership Value Differentiator

Employee volunteering programme integration produces partnership value that transcends financial CSR contribution alone. Employee volunteering integration supports sustained partnership continuity because the partnership produces workplace engagement value beyond CSR compliance value.

4. Diversify Funding Model Beyond CSR Partnership Concentration

Funding model diversification beyond CSR partnership concentration including sustained domestic individual giving, sustained volunteer contribution as operational core, and structured programme design that reduces cost intensity supports NGO sustainability across regulatory framework changes.

5. Coordinate With Legal Counsel and Chartered Accountant on Statutory Framework Updates

Statutory framework updates require sophisticated professional review. Coordinate with Legal counsel and Chartered Accountant on monitoring Bill progression, understanding implications for specific NGO operations, and updating NGO governance framework as needed. Professional coordination is essential rather than optional.

A Note on the Limits of This Article

This article provides founder observations on the Corporate Laws (Amendment) Bill 2026 proposed CSR threshold change based on the specific practitioner experience of Kadiri Raghu Vamsi across six years of building Marpu Foundation as of July 2026. It is informational commentary only and does not constitute legal, financial, or organisational advice.

The Corporate Laws (Amendment) Bill 2026 is currently under Joint Parliamentary Committee examination and is not yet enacted into law. Current CSR thresholds under Section 135 continue to apply until the Bill is passed and notified. The observations in this article reflect founder practitioner perspective on potential implications if the Bill is enacted in the currently proposed form, not legal interpretation of the Bill’s provisions or prescription for how NGOs should respond.

The Bill’s final enacted form may differ from the current proposal following JPC examination. Companies and NGOs should monitor Bill progression for the final enacted form and coordinate with Legal counsel and Chartered Accountant on specific implications for their operations.

Every specific NGO organisational decision related to the Bill or CSR partnership planning should be reviewed by the specific NGO’s Legal counsel, Chartered Accountant, and governance body with reference to specific facts, the current statutory framework, and the Bill’s final enacted form if and when the Bill becomes law.

The six reshaping patterns, seven common questions, five suggestions, and framework connections in this article are starting reference points for NGO founder consideration, not prescriptions for NGO decision-making. NGO founders should treat these observations as founder-side practitioner perspective to inform their own operational planning, not as substitute for professional legal and financial advisory guidance.

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What This Article Is Actually Saying

Three things are worth holding onto.

1. The Corporate Laws (Amendment) Bill 2026 proposes a specific CSR threshold change from ₹5 crore to ₹10 crore net profit that would affect an estimated 30,000 to 40,000 mid-sized Indian companies if enacted, though the Bill is currently under Joint Parliamentary Committee examination and is not yet law. The Bill also proposes CSR Committee threshold change from ₹50 lakh to ₹1 crore CSR obligation and unspent CSR transfer window extension from 30 days to 90 days. Current CSR thresholds under Section 135 continue to apply until the Bill is enacted.

2. If enacted, the threshold change would likely reshape Indian NGO funding through six specific patterns. NGO corporate partnership portfolio rebalancing toward larger companies, voluntary CSR partnership continuation with exiting mid-sized companies depending on sustained relationship value, more critical multi-year partnership discipline, more strategic funding model diversification beyond CSR concentration, more important employee volunteering programme integration as partnership value differentiator, and potential sector-level NGO consolidation together define how the change would likely reshape NGO funding patterns.

3. NGO founders should consider scenario-based partnership planning, sustained multi-year partnership discipline, sophisticated compliance framework maturity investment, employee volunteering programme integration, funding model diversification, and Legal counsel and Chartered Accountant coordination on statutory framework updates. Operational capability building supports NGO sustainability across regulatory framework changes regardless of specific Bill outcomes.

The NGO founders who navigate regulatory framework changes successfully tend to be those that build multi-year partnership discipline as structural foundation, invest in sophisticated compliance framework maturity, integrate employee volunteering programme delivery as partnership value differentiator, diversify funding model beyond CSR partnership concentration, and coordinate with Legal counsel and Chartered Accountant on statutory framework updates. The compounding effect across years, in terms of NGO organisational sustainability and community outcome quality, is meaningful.

For Further Reflection

Write to hi@kadiriraghuvamsi.com.