Dignity in life
Dignity in life
Before any CSR commitment is made, the compliance question must be answered first.
For STEM education programmes, the question is almost always the same: does this qualify under Schedule VII of the Companies Act 2013, and what documentation does our company need to demonstrate that it does?
This guide answers both questions specifically for SMILE HUB — Samabhavana’s 9-module STEM education CSR programme.
Schedule VII of the Companies Act 2013 lists the categories of activities that qualify as eligible CSR expenditure. Item II is the education clause, and it covers two distinct categories that are relevant to SMILE HUB:
| “Promoting education, including special education and employment enhancing vocational skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects.” — Schedule VII, Item (ii), Companies Act 2013 |
This single clause covers two separate qualifying routes for SMILE HUB:
Both routes are valid. Many SMILE HUB programmes will qualify under both simultaneously.
Beyond the Schedule VII clause, SMILE HUB’s alignment with the National Education Policy 2020 strengthens the compliance case in a way that is increasingly valuable for CSR-2 filings and BRSR disclosures.
NEP-2020 mandates the integration of Technology, Coding, Artificial Intelligence, and Computational thinking into school education across India. SMILE HUB is designed specifically to deliver on these NEP-2020 mandates in government schools that lack the internal capacity to implement them independently.
A CSR programme that is explicitly aligned to a National Education Policy — with documented curriculum mapping — is a significantly stronger compliance position than one that simply donates equipment.
This is a distinction we explore in detail in our post on AI and IoT Education CSR in India, which covers the policy context and implementation requirements for technology education CSR.
Yes — and the compliance standard for PSU CSR is higher, not lower. PSU CSR programmes are subject to CAG scrutiny, RTI queries, and in some cases parliamentary review.
As we outlined in our guide on CSR for PSU Companies in India, PSU CSR managers need an implementing agency that can provide documentation that holds up under audit — not just a programme that delivers activities.
SMILE HUB’s compliance infrastructure is built to meet this standard. Every programme includes beneficiary data, session logs, pre- and post-assessment scores, teacher training records, equipment utilisation data, and financial audit trail documentation — structured for CAG-audit-ready reporting.
For companies filing a Business Responsibility and Sustainability Report (BRSR), SMILE HUB programmes are reportable under Principal 8: Inclusive Growth and Equitable Development.
Specifically:
For companies that have adopted the BRSR Core (mandatory for the top 150 listed entities from FY2023-24), SMILE HUB’s outcome documentation is designed to meet the higher assurance standard required.
Some companies ask whether they can transfer CSR funds directly to a school rather than through a registered implementing agency.
Legally, direct transfers to schools are permitted under the Companies Act, but they carry significant compliance risk: schools are not equipped to provide the structured impact documentation, CSR-1-backed receipts, or outcome reporting that CSR-2 filing requires.
The implementing agency model — where a registered NGO like Samabhavana holds the funds and manages the programme — is the approach that minimises compliance risk for the corporate partner.
The Government of India’s SOAR (Skilling for AI Readiness) programme, launched in 2025, introduces foundational AI and machine learning modules for Classes 6–12. SMILE HUB’s Robotics, AI, and IoT modules are directly aligned with the SOAR competency framework. CSR programmes that fund SOAR-aligned technology education can cite this alignment explicitly in their BRSR disclosures and CSR-2 filings — strengthening the government policy justification for the expenditure.
| Want a compliance-ready SMILE HUB proposal for your company? Samabhavana holds valid 80G, 12A, and CSR-1 certifications and is registered with Niti Aayog. We provide the full documentation package your CSR-2 filing, BRSR report, and internal audit require — as part of every programme. Contact us: info@samabhavana.in Call: 022-45658306 | SMILE HUB |
Related Reading: CSR for PSU Companies India | AI and IoT Education CSR India | The Role of NGOs in CSR
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