CSR for Disability: Mapping Programmes to Schedule VII

A CSR for disability programme can be recognised under Schedule VII of the Companies Act, 2013 when it delivers education or vocational skills for people with disabilities. Item (ii) of the Schedule covers promoting education, including special education and vocational skills, especially for the differently abled. A programme that does not map to a Schedule VII item cannot simply be labelled CSR, however useful it is, so the mapping has to be done before the money is spent.

Key takeaways

• Item (ii) of Schedule VII is the usual fit for disability education and vocational skills programmes.
• Write the mapping as one sentence before approval, and check the wording with counsel.
• Devices alone may not clearly fit. Programmes are stronger when they include training or skills and the link is documented.
• Auditors look for approval, agreements, utilisation records, beneficiary records and outcome records.
• Most errors come from weak documentation, not from the programme idea.

Mapping a CSR for disability programme to Schedule VII

The mapping exercise is simple in principle. Take each planned activity, find the Schedule VII item it falls under, and write down why. In practice, the question is whether the activity is education or skills, and whether the beneficiaries are persons with disabilities. The table below shows how common programme types usually line up. The right-hand column is a prompt for review, not a legal conclusion.

The RPWD Act 2016 guide for CSR managers explains how disability rights in India connect to assistive technology planning, which helps when writing the programme rationale.

What an auditor will expect to see

An auditor reviewing a disability project will want to follow a clear trail from the approved budget to the people reached. The trail is easier to build if the records are created at each stage rather than reconstructed at year end. For each project, keep these items together:

1. A reference to the company's CSR policy and the approval of the project by the committee or board, as applicable.
2. The Schedule VII item the project maps to, written in one sentence.
3. The agreement with the implementing agency and the due diligence record behind it.
4. Utilisation records that show how funds were spent, with invoices and payment proofs.
5. Beneficiary selection and consent records, including the criteria used.
6. Training logs, attendance and outcome records in defined units.
7. A reconciliation that links the project to its entry in the annual CSR report.

Common mistakes to avoid

Most problems in disability CSR come from a few predictable mistakes. Each one is easy to avoid if it is caught early.

• Classifying general staff welfare or internal accessibility work as CSR without a Schedule VII link.
• Counting devices handed out as education or skills outcomes when no training took place.
• Keeping no record of how beneficiaries were selected or whether they consented.
• Mixing administrative overheads into project costs without a clear and documented basis.
• Reporting adjectives such as impactful instead of counts that a reader can check.
• Engaging an implementing agency without checking its registration, controls and reporting.

Designing the programme so the mapping holds

The simplest way to protect a disability project is to design it around education or skills from the start. A device without training is hard to map. A device with a structured training course, a recorded skills outcome and a follow-up period is much easier to explain. This is also the design that tends to produce results that last, because the person learns to use the tool for a real task.

SMARTON's training and onboarding are part of the VI Inclusive Package for the SMARTON Kit, which is sold at ₹19,999 one time with a one-year hardware warranty. When a company designs its project around the training and onboarding steps, the records for those steps become the evidence for the mapping. Questions about how a project fits the schedule are best settled with the company's auditors and legal counsel before the first payment.

A short project note keeps the mapping honest. It should state the Schedule VII item, the beneficiary group, the training design, the units the project expects to count, the budget lines that pay for each step, and the records each unit will generate. Writing that record plan at the start means the questions an auditor would ask are answered before they are asked. Review the note with the finance and legal teams, and update it if the design changes during the year, so the file always reflects what the programme actually did. Keep the programme's language consistent across the proposal, the agreement and the annual report, so the same activity carries the same name in every document.

Before the next financial year starts, write the Schedule VII mapping for each planned disability project. If a project cannot be mapped, redesign it around education or skills, or fund it outside CSR. The frequently asked questions page covers general questions about SMARTON, and the CSR section sets out how the company works with corporate partners.