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Based on experience with CSR impact assessments across various business sectors, these are the most frequently observed failures as depicted by the video.

The 6 Step CSR Impact Assessment Process

Internationally recognised frameworks — including ISO 26000 (Social Responsibility) and OECD evaluation standards — inform what a robust impact assessment should contain. In practice, a well-conducted impact assessment for a CSR project in India typically follows these six steps.

Common Mistakes in Social Impact Assessment

Based on experience with CSR impact assessments across various business sectors, these are the most frequently observed failures as depicted by the infographic.

The 6-Step Social/CSR Impact Assessment Process

Internationally recognised frameworks — including ISO 26000 (Social Responsibility) and OECD evaluation standards — inform what a robust impact assessment should contain. In practice, a well-conducted impact assessment for a CSR project in India typically follows these six steps.

CSR Impact Assessment or Social impact assessment (SIA) is the systematic process of identifying, and measuring the positive or negative social effects of a project, programme, or policy on individuals and communities.

In India, IA for CSR projects is mandatory under the Companies (CSR Policy) Amendment Rules, 2021 for companies with an average CSR obligation of ₹10 crore or more during preceding three financial years, covering projects with outlays of ₹1 crore or more. Independent agencies conduct these assessments and results must be disclosed in the company's annual report and reported to the MCA.

India's corporate sector spent ₹34,908.75 crore on CSR in Financial Year 2023–24 — across 59,634 projects filed by 27,188 companies on the National CSR Portal. That is a substantial sum by any measure. Yet for years, a central question remained largely unanswered: how much of it actually worked?

The Companies (CSR Policy) Amendment Rules, 2021 introduced a decisive answer to that question. For the first time, impact assessment became a legal obligation for qualifying companies — not a voluntary good practice. The assessment had to be conducted by an independent third party, the findings had to be placed before the Board, and the report had to be annexed to the company's annual CSR disclosure.

This guide explains what social impact assessment means in the Indian CSR context, who is legally required to undertake one, what the process entails, and where companies typically go wrong. Whether you are a CFO preparing for compliance, a CSR Manager commissioning an assessment for the first time, or a Company Secretary advising the Board, this is the definitive reference.

Source: National CSR Portal, MCA, Government of India. CSR expenditure data FY 2019–2024

What is Impact Assessment?

Impact assessment is a structured, evidence-based process of evaluating the changes — intended and unintended, positive and negative — that a project or intervention brings about in the lives of individuals, households, and communities. It is both a planning tool and an accountability mechanism.

The concept draws its intellectual roots from definitions laid down by OECD Development Assistance Committee which defines evaluation as “The systematic and objective assessment of an on-going or completed project, programme or policy, its design, implementation and results. The aim is to determine the relevance and fulfilment of objectives, development, efficiency, effectiveness, impact and sustainability.

An evaluation should provide information that is credible and useful, enabling the incorporation of lessons learned into the decision–making process of both recipients and donors.

Evaluation also refers to the process of determining the worth or significance of an activity, policy or program. An assessment, as systematic and objective as possible, of a planned, on-going, or completed development intervention.”

In the CSR context, Impact Assessment is required under Rule 8(3) of the Companies (CSR Policy) Rules, 2014, as amended in 2021. The intention behind a SIA in general terms and Impact Assessment is essentially the same. Here it measures whether a company's CSR investment has achieved its intended social outcomes and requires assessment of projects that have been completed for more than one year

According to the MCA Circular (General Circular No. 14/2021), the purpose of impact assessment is to assess the social impact of a particular CSR project. The intent is to encourage companies to take considered decisions before deploying CSR amounts and assess the impact of their CSR spending. This not only serves as feedback for companies to plan and allocate resources better but shall also deepen the impact of CSR.

Social Impact Assessment vs. Impact Evaluation: Is There a Difference?

In everyday usage within the Indian CSR sector, 'social impact assessment', 'impact evaluation', and 'impact study' are often treated as synonyms. The MCA's own circulars use the terms 'impact assessment' and ‘evaluation’ without further qualification. Practitioners generally accept that, for compliance purposes, these terms refer to the same exercise: a systematic third-party review of the outcomes and impact of a CSR project, using a combination of quantitative and qualitative methods.

The important distinction is not one of terminology but of timing. A needs assessment and baseline study happens before a project begins and concurrent monitoring happens during implementation.

An impact assessment happens after the project is complete — specifically, no more than one year after completion. All the three, baseline/needs assessment, concurrent monitoring and impact evaluation would together be tied to the overall Impact Assessment.

Why Impact Assessment is Mandatory for Indian Companies

The legal foundation for mandatory IA in the CSR context is Rule 8(3) of the Companies (Corporate Social Responsibility Policy) Rules, 2014, as substituted by the Companies (CSR Policy) Amendment Rules, 2021, notified by the Ministry of Corporate Affairs on 22 January 2021.

The Exact Legal Threshold — Rule 8(3)

Every company having an average CSR obligation of ₹10 crore or more in the three immediately preceding financial years shall undertake impact assessment, through an independent agency, for any CSR project that:

  (a) has an outlay of ₹1 crore or more, AND

  (b) has been completed not less than one year before the date of undertaking the assessment.

All conditions must be met. A company with a ₹10 crore+ obligation whose individual projects are each below ₹1 crore is not required to conduct a formal assessment, though it is good practice to do so.

Source: Rule 8(3), Companies (CSR Policy) Amendment Rules, 2021, notified 22 January 2021

Why These Numbers? The Scale of the Obligation

To put the ₹10 crore average CSR obligation threshold in context: it applies to companies with an average net profit (under Section 198) of approximately ₹500 crore or more over three years. These are India's largest listed and unlisted companies — the organisations whose CSR programmes are most likely to involve large-scale, multi-year projects with measurable community outcomes.

According to PRIME Database analysis, CSR spending by listed companies alone rose 16% to ₹17,967 crore in FY 2023–24, with approximately 98% of companies meeting their mandatory spending obligations. India has spent more than ₹1.53 lakh crore on CSR since the law became mandatory in FY 2014–15.

The impact assessment mandate exists because a spend of this scale — directed to meet developmental needs— demands proportionate accountability. Without independent verification of outcomes, CSR risks becoming a compliance exercise that produces activity reports rather than verified social change.

Source: PRIME Database, CSR Spending Analysis FY 2023–24. India CSR / Economic Survey 2023–24, MCA data

What Must Happen After the Assessment

The impact assessment report is not a file-and-forget document. Under Rule 8(3)b, the Board must:

1.       Place the report before the Board of Directors.

2.      Annex it to the Annual Report on CSR (the Board Report).

The company may book the expenditure on the impact assessment itself as CSR expenditure — but this is capped at 2% of total CSR expenditure for that financial year, or ₹50 lakh, whichever is higher.

Impact assessment expenditure is separate from and in addition to the 5% cap on administrative overheads.

A critical timing rule: the assessment must be undertaken after one year of the project's completion date. For ongoing multi-year projects, an interim assessment can be conducted.

The 6-Step Social Impact Assessment Process

The MCA circulars do not prescribe a specific methodology for conducting a impact assessment under the CSR rules.. However, internationally recognised frameworks — including ISO 26000 (Social Responsibility) and OECD evaluation standards — inform what a robust IA should contain. In practice, a well-conducted impact assessment for a CSR project in India typically follows these six steps:

Step 1 — Define the Scope and Set the Evaluation Questions

The assessment must begin with a clear articulation of what the project intended to achieve. This means revisiting the original CSR project proposal, the need assessment (if one was conducted), and the theory of change — the causal logic connecting inputs, activities, outputs, and intended outcomes.

The scoping stage answers: What change was the project meant to create? Who were the intended beneficiaries? What does 'success' look like in measurable terms? Poorly scoped assessments — where the evaluation questions are vague — are the most common quality failure in CSR impact studies in India.

Step 2 — Develop the Baseline (or Reconstruct It)

A baseline survey establishes the conditions among the target population before the CSR intervention. Ideally, the company conducts a baseline before the project begins, so the impact assessment can compare 'before' and 'after' using the same indicators.

In practice, many companies do not commission a baseline at the outset. In such cases, the impact assessment agency must reconstruct the baseline through recall surveys, secondary data from government sources (Census, NFHS, NSSO), or a comparator group approach — comparing the beneficiary community to a similar community that did not receive the CSR intervention. (However, this approach may also be disadvantageous in situations where, data on contextual /micro level situation is not available For example, data available at district level may not be useful for a project involving cluster of villages)

This is the single strongest argument for planning the impact assessment from the start of the project, not after it ends.

Step 3 — Primary Data Collection

The assessment agency collects original data directly from the beneficiary population using a combination of:

Quantitative methods: structured surveys, household data collection, attendance and enrollment records, health outcome tracking, income and livelihood surveys.

Qualitative methods: focus group discussions (FGDs), key informant interviews (KIIs) with community leaders, NGO staff, and local government functionaries, case studies documenting individual change narratives.

Observational methods: site visits, infrastructure assessments (for physical assets created under CSR), third-party verification of project records.

The CSR Rules read with MCA circular(General Circular No. 14/2021) confirms that while international organisations may be appointed as independent agencies to conduct evaluations, there is no restriction on domestic agencies — the Board can choose its impact assessment conducting agency.

Step 4 — Analysis and Attribution

Collecting data is not the same as conducting an impact assessment. The analytical rigour of an IA lies in its attribution methodology — the effort to establish that the observed changes in beneficiary lives were caused by the CSR project, and not by other factors such as general economic improvement, government schemes running in parallel, or seasonal variation.

Common attribution approaches used in Indian CSR impact assessments include:

Before and after : A simple and widely used impact assessment approach that compares key indicators before the intervention (baseline) and after the intervention (endline) to measure the change attributable to the project.It assumes that the difference between the two measurements reflects the effect of the intervention, though other external factors may also influence the change.

Difference-in-differences or Propensity score matching: uses statistical techniques to comparekey KPIs in the beneficiary group over time against a control group (group of comparable individuals who did not receive the intervention)

Social Return on Investment (SROI): a monetised value framework that converts social outcomes into a financial ratio. For example, an SROI of 4:1 means ₹4 of social value was generated for every ₹1 of CSR expenditure.

The choice of attribution method depends on the project type, available data, and budget for the assessment itself. All methods must be documented transparently in the final report.

Step 5 — Report Preparation and Board Presentation

The impact assessment report must be structured for two audiences simultaneously: the Board of Directors (who receive the findings under Rule 8(3)) and the public (since the report is annexed to the Annual Report which is publicly accessible via MCA21 filings).

A complete impact assessment report typically includes:

Executive summary with key outcome findings

Project background and context

Assessment methodology and sampling framework

Baseline and endline comparison (or reconstructed baseline)

Outcome and impact findings, with evidence

Attribution analysis and limitations

Lessons learned and recommendations for future programme design

Annexures: data tables, survey instruments, FGD notes

Step 6 — Annual Report Disclosure

The final report is annexed to the company's Annual Report on CSR, which forms part of the Board Report filed with MCA. The disclosure must include executive summary of the assessment along with link to the full report for all projects for which impact assessment was required to be conducted.,

Companies should be aware that the impact assessment report — once annexed — is in the public domain. It can be examined by investors, NGOs, media, and regulatory authorities. Superficial reports that claim all outcomes were achieved without supporting evidence can be increasingly scrutinized.

Compliance Reminder

Impact assessment expenditure is bookable as CSR expenditure — but is capped at the HIGHER R of:

(a) 2% of total CSR expenditure for the financial year, OR

(b) ₹50 lakh

This is separate from the 5% administrative overhead cap and does not count against it.

Expenditure on concurrent monitoring (during implementation) is different — that is project cost , not impact assessment.

Who Can Conduct a CSR/Social Impact Assessment in India?

The MCA has intentionally left the selection of the independent assessment agency to the discretion of the company's Board. Rule 8(3) requires only that the agency be 'independent' — meaning it cannot be the same entity that implemented the CSR project, and it cannot be an internal team of the company.

The MCA  circular (General Circular No. 14/2021) provides important clarifications:

The Board has full discretion to determine the eligibility criteria for the independent agency.

International organisations may be appointed, provided they meet the Board's eligibility criteria.

There is no central government-maintained list of impanelled agencies for CSR impact assessment.

What ThinkCap Advisors Recommends When Selecting an Agency

Since the MCA does not prescribe a roster, companies are in the position of having to evaluate agencies themselves. As a CSR consulting services specialists we recommend,  look for:

Domain expertise: Has the agency previously assessed projects in your CSR thematic area (education, health, livelihood, environment)?

Methodological capability: Does the agency use both quantitative surveys and qualitative fieldwork? Can it conduct SROI analysis if needed?

Independence: Is the agency genuinely at arm's-length from the implementing NGO and from your company?

CA/audit oversight: Given that the findings are Board-level disclosures with regulatory consequences, firms with both social sector and CA expertise provide an additional layer of credibility.

Track record: Can the agency demonstrate impact assessments filed in previous years' Annual Reports of comparable companies?

ThinkCap Advisors conducts CSR impact assessments as an eligible independent agency, combining Chartered Accountant oversight with social sector expertise.

The CA + Social Sector Combination — Why It Matters

Most CSR impact assessment agencies come from one of two backgrounds: development sector consultants (strong on field methodology, weaker on regulatory compliance) or accounting/audit firms (strong on financial accuracy, weaker on social measurement).

Companies that engage an agency combining both credentials reduce the risk of two common failures: assessment reports that are methodologically rigorous but do not meet

MCA disclosure norms, and reports that technically comply with regulatory form but contain weak evidence of actual social change.

For companies subject to regulatory scrutiny — particularly large listed companies, PSUs, and multinationals with Indian operations — this combination provides the most defensible position. The combination also proves useful for companies who have just started their impact assessment journey.

Common Mistakes in Social Impact Assessment

Based on experience with impact assessments across various business sectors, these are the most frequently observed failures:

Commissioning the Assessment After the Compliance Deadline

Rule 8(3) requires the assessment to be completed after one year of the project's completion date. Companies that fail to track this deadline — typically because CSR compliance is managed as an annual reporting exercise rather than an ongoing project management function — find themselves unable to commission a legitimate assessment in time.

The project data has aged, beneficiaries have dispersed, and field surveys become unreliable. It is important to collect required data either during the duration of the project or immediately after its completion, not when the Annual Report deadline approaches.

No Baseline Data

The single most common technical weakness in Indian CSR impact assessments is the absence of a pre-project baseline. Without baseline data, it is impossible to measure change — only current status.

An assessment that reports '78% of beneficiary children are now attending school' is not an impact assessment; it is a status survey. An assessment that reports 'school attendance among beneficiary children improved from 52% to 78% over the project period, compared to 54% to 59% in the comparator community' is a credible impact finding.

Companies should build baseline data collection into the project design from day 1.

Appointing the Implementing NGO to Conduct the Assessment

The independence requirement in Rule 8(3) explicitly prohibits this. The implementing NGO has a direct financial and reputational interest in a positive outcome. A report prepared by the same agency that executed the project has zero credibility with the Board, investors, and regulators.

Treating the Assessment as a Communications Exercise

Impact assessment reports are regulatory documents with Board-level accountability. A report padded with photographs, beneficiary quotes, and project activity summaries — but containing no statistical analysis, no outcome indicators, and no attribution — does not meet the standard implied by Rule 8(3) or the MCA circular.

The Board is responsible for the disclosures in the Annual Report; a superficial report may expose directors to regulatory risk.

Missing the ₹1 Crore Project Threshold — or Miscomputing It

The ₹1 crore threshold applies to the project outlay — the total amount the company spent on that project over the course of its implementation, not the amount spent in a single financial year.

A project with ₹40 lakh per year approved for three years has a total outlay of ₹1.2 crore and is therefore in scope for mandatory impact assessment. Companies that compute the threshold on a single-year basis systematically under-report their assessment obligations.

Confusing Concurrent Monitoring with Impact Assessment

These are two different activities with different regulatory treatments. Concurrent monitoring — reviewing programme implementation, field visits, document review during the project — counts as project cost admissible under CSR expenditure.

Impact assessment — the third-party evaluation after project completion — is separately allowed up to 2% of CSR expenditure or ₹50 lakh, whichever is higher, and not as 5% administrative overheads.

Companies that book impact assessment costs as administrative overheads may exceed the overhead cap and create a compliance issue.

How ThinkCap Advisors Approaches CSR Impact Assessment

ThinkCap Advisors is a CA-led CSR consulting firm with a dedicated impact assessment practice. Our team combines Chartered Accountant oversight — ensuring the financial accuracy and regulatory compliance of the report — with trained social sector researchers who conduct baseline surveys, beneficiary interviews, and field verification visits.

Our reports are structured to meet Rule 8(3) disclosure requirements and are designed for direct Board presentation.

Where companies have not maintained a baseline, we use a combination of retrospective survey techniques and secondary data triangulation to reconstruct pre-project conditions with documented confidence levels. We do not suppress findings that reflect poorly on project implementation — our assessment reports are governance documents, and their credibility depends on objectivity.

FAQs on Social/CSR Impact Assessment

Is CSR impact assessment mandatory for all CSR companies?

No. The mandate under Rule 8(3) applies only to companies that have an average CSR obligation of ₹10 crore or more in the three immediately preceding financial years AND have specific projects with outlays of ₹1 crore or more. Companies below the ₹10 crore average obligation threshold are not legally required to conduct a formal impact assessment, though best practice recommends it.

From which date is the impact assessment mandate effective?

The MCA  circular (General Circular No. 14/2021) clarifies that the impact assessment requirement applies to CSR projects completed on or after 22 January 2021, the date the Amendment Rules came into force. As a matter of good governance, the Board may voluntarily commission assessments of projects completed before this date.

Can the company conduct the impact assessment internally?

No. Rule 8(3) explicitly requires an independent agency — external to the company. The rationale is objectivity: an internal team cannot credibly evaluate the outcomes of a project the company itself implemented.

What if the impact assessment reveals the project failed to meet its objectives?

This is one of the most important governance questions in the Indian CSR space. An honest assessment that documents implementation failures, missed targets, or limited social change is far more valuable — and far more legally defensible — than a report that asserts success without evidence.

The MCA does not penalise honest findings. The Board is expected to use the findings to improve future programme design. Boards should treat negative or mixed findings as governance intelligence, not reputational risk.

Can the impact assessment agency be an international organisation?

Yes. The MCA  circular confirms that there is no restriction on international organisations being appointed, provided they meet the Board's eligibility criteria. This is relevant for multinational companies with global CSR monitoring frameworks who wish to engage their parent company's assessment partners.

What is the difference between a CSR impact assessment and an SROI analysis?

A Social Return on Investment (SROI) analysis is a specific methodology within the broader social impact assessment framework. It converts social outcomes into a monetised value — for example, every ₹1 spent on a skill training programme generates ₹4 in economic value through improved livelihoods — expressed as an SROI ratio.

Not all CSR impact assessments use SROI; many rely on outcome indicators without monetisation. SROI is particularly useful for presentations to Board, investors, and CSR Committees because it translates social outcomes into financial language.

How long does a social impact assessment take?

For a straightforward CSR project with an existing baseline and a defined beneficiary population, a credible assessment typically takes 8–12 weeks: 2 weeks for scoping and tool development, 3–4 weeks for field data collection, 2 weeks for analysis, and 1–2 weeks for report writing and review.

The Importance Of Pre-Grant Due Diligence

Companies increasingly prefer Pre-Grant Due Diligence as corporate governance expectations and CSR laws continue to evolve. 

Also, advanced PGD significantly reduces risk exposure and sets the foundation for responsible CSR investments.

Looking for a capable consulting team for NGO Due Diligence. Reach Us. 

Key Elements Of Post Grant Monitoring

Once the project execution begins, the focus transitions from vetting the implementation partner to continuously tracking project performance. The following infographic explains key components of Post Grant Monitoring. 

Pre-Grant Due Diligence Why It Matters

Companies increasingly prefer Pre-Grant Due Diligence as corporate governance expectations and CSR laws continue to evolve. Also, advanced PGD significantly reduces risk exposure and sets the foundation for responsible CSR investments.

Are you looking for a capable consulting team for NGO Due Diligence Reach Us. https://www.thinkcapadvisors.com/ngo-due-diligence-and-grant-audits