Featured image for article: The CSR head's 20-minute due-diligence checklist for disability-inclusion projects
    CSR & Compliance
    July 20, 2026
    9 min read

    The CSR head's 20-minute due-diligence checklist for disability-inclusion projects

    Before any disability-inclusion project reaches your CSR committee, five questions must have verifiable answers: Schedule VII fit, partner credibility, per-rupee impact, co-branding, and multi-year viability. Here is the checklist, in the order you'll be asked.

    S

    SMARTON Team

    Author

    Most CSR heads evaluate a new project the same way: 20–30 minutes of quiet research on a Tuesday afternoon, before anyone from the project has been contacted. If the answers aren't publicly checkable in that window, the project waits — or loses to one that did the prep. This checklist is that evaluation, written down: the five questions every CSR committee in India will ask about a disability-inclusion project, what a verifiable answer looks like, and the red flags that end the conversation.

    Quick answer (TL;DR)

    • Question 1 — mandate fit: the project must map to a named Schedule VII category of the Companies Act 2013 and, for disability projects, align with the RPwD Act 2016.
    • Question 2 — credibility: a registered legal entity, named (not anonymous) NGO partners, and verifiable recognition.
    • Question 3 — unit economics: a clear "₹X funds Y beneficiaries for Z months, measured by A, B, C" statement.
    • Question 4 — reputational return: co-branding, an annual-report-ready impact certificate, and clean reporting.
    • Question 5 — continuity: a 2–3 year engagement model, not a disappearing one-time cheque.

    SMARTON publishes its answers to all five on one page: the SMARTON CSR partnership page.

    Question 1: Does it fit our CSR mandate under Schedule VII?

    Every rupee of statutory CSR spend must fall under a Schedule VII category. For disability-inclusion technology, two sub-clauses do the work:

    • Schedule VII (i) — promoting education, including special education and employment-enhancing vocational skills, especially among the differently-abled.
    • Schedule VII (ii) — promoting healthcare and measures for reducing inequalities faced by socially and economically backward groups.

    What a good answer looks like: the vendor or NGO names the sub-clause on their website and offers written confirmation for your committee records. Red flag: "we're sure it qualifies" with no clause cited. If your CSR policy lists education, digital inclusion, or disability among priority themes, a project like SMARTON is in-mandate on its face; if your policy is environment-only, no amount of impact data fixes the mismatch — say no early.

    For the legal background, see our RPwD Act 2016 guide for CSR managers.

    Question 2: Is the partner credible — and checkable?

    Your committee will ask "who are these people?" You need to answer with facts a stranger can verify:

    • A registered legal entity with its registration details public (SMARTON is built by Sunbots Innovations LLP, Ahmedabad, founded 2018).
    • Named NGO partners — "50+ NGO partners" means nothing until at least 3–5 are named. SMARTON's include the Blind People's Association (BPA), Ummeed Foundation, VOSAP, Rotary Club of Ahmedabad and Lions Club — organisations your team can call.
    • External recognition — SMARTON has been a Tata Social Enterprise Challenge finalist, partners with LV Prasad Eye Institute, and has been recognised by IIT BHU and IIT Mandi.

    Red flag: impact claims with no named partners, no entity details, and no way to verify either.

    Question 2½: Direct programme or implementing agency?

    Since the CSR Amendment Rules 2021, a company can implement CSR either directly (a company-run programme, where technology partners are procured as part of the programme) or through an implementing agency — typically a Section 8 company, registered public trust, or registered society with CSR-1 registration, 12A and 80G. A well-prepared project supports both structures. SMARTON deployments run either way: through one of our registered NGO implementing partners, or as a direct company programme with SMARTON as technology partner. Ask the vendor which structure they support before the committee meeting — retrofitting this after approval is painful.

    Question 3: What does the money actually buy?

    Vague impact is the single most common dealbreaker. The committee wants a sentence of the form: "₹X funds Y beneficiaries for Z months, who will be able to do A, B and C — and here is how we measure it."

    SMARTON's version: ₹2,000 funds one blind or visually impaired person for one full year — AI-powered education, document reading, currency recognition, daily audio news and entertainment, with onboarding and support included. ₹1,00,000 reaches a 50-user cohort. Usage is measured (activations, logins, documents read, AI Tutor sessions, audio episodes) and reported quarterly in exportable form. The full tier table is in what a CSR budget buys in disability inclusion.

    Red flag: per-beneficiary cost that only exists after you ask for it, or "impact" measured in devices shipped rather than sustained usage.

    Question 4: Can our company put its logo on this?

    CSR teams answer to boards and publish annual reports. Reputational safety is a requirement, not vanity. Look for an explicit co-branding offer: logo placement in the funded product, a co-branded impact certificate formatted for the annual report, press-release rights, and a dashboard your team can show internally. SMARTON includes all four in every corporate partnership — detailed in our guide to CSR impact reporting.

    Question 5: One-time cheque, or a partnership?

    A one-off donation is finished the day it's announced; a multi-year engagement compounds — in outcomes and in how it reads in successive annual reports. Ask every project for its Year 2 and Year 3 story. SMARTON's standard arc: Year 1 deploy and prove with a defined cohort; Year 2 expand to new states and NGO partners; Year 3 report education and employment-readiness outcomes. The comparison is worked through in multi-year CSR partnerships vs one-time donations.

    The checklist, in one table

    CheckPass looks likeFail looks like
    Schedule VII fitSub-clause named, written confirmation offered"It's obviously charitable"
    Legal entityEntity name + registration publicBrand name only, no entity
    NGO partners3–5 named, contactable"50+ partners", none named
    Unit economics₹X = Y users × Z months, metrics listedImpact only in adjectives
    ReportingQuarterly, exportable, audit-readyAnnual PDF of photos
    Co-brandingExplicit logo/certificate/press offer"We can discuss visibility"
    Continuity2–3 year engagement modelNo plan beyond the cheque

    FAQ

    Does assistive technology qualify as CSR spend in India?

    Yes — when the programme maps to a Schedule VII category. Assistive-technology deployments for education and inclusion of persons with disabilities typically qualify under Schedule VII (i) and (ii). Get the sub-clause confirmed in writing for your records.

    How long should due diligence on a small CSR project take?

    If the project has done its prep, 20–30 minutes to verify the five answers publicly, plus one scoping call. If basic facts (entity, partners, unit cost) can't be found in that window, treat it as a signal about how reporting will go later.

    Where does SMARTON publish its answers?

    On the SMARTON CSR partnership page — Schedule VII mapping, entity details, named NGO partners, the ₹2,000-per-user-year unit, co-branding offer and the 3-year model, with a downloadable 2-page CSR brief.

    Next step: if you're evaluating disability-inclusion projects this quarter, start with the CSR partnership page or request a proposal — you'll have a committee-ready pack within 2 business days.

    Tags

    CSR
    Due Diligence
    Schedule VII
    Disability Inclusion
    RPwD Act 2016
    India B2B
    Checklist

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