How CSR teams deploy SMARTON under Schedule VII: a 6-week playbook
An operational playbook for Indian CSR managers: how to scope, approve, procure, deploy and report a SMARTON accessibility programme that clears Companies Act Schedule VII audit on first review.
SMARTON Team
Author
Most CSR teams in India know why they should fund accessibility — the RPWD Act 2016, Schedule VII of the Companies Act 2013, and the obvious social impact all point in the same direction. The hard part is how: who do you talk to, in what order, with what documents, on what timeline? This is the operational playbook we use with corporate CSR partners deploying SMARTON across India. Six weeks from first call to signed-off impact report.
If you want the background on RPWD law and Schedule VII sub-clauses first, read our RPWD Act guide for CSR managers. This post assumes you already know the law and want to know what to do on Monday morning.
Week 0 — Decide your three deployment parameters
Before you even contact a vendor, your CSR team needs to lock three numbers. These determine everything else.
- Beneficiary count — how many BVI individuals will receive SMARTON. Typical SMARTON deployments range from 25 (pilot) to 500+ (multi-state programme). 50–100 is the sweet spot for a first-year flagship initiative.
- Geographic concentration — single city, single state, or pan-India? In-person onboarding logistics depend on this. If beneficiaries are spread across more than three states, plan remote-onboarding as primary with in-person as supplementary.
- Beneficiary source — your own employees + their families, a partner NGO's beneficiaries, a state government's disability roster, or an open application process? Each source has different selection, documentation, and consent processes.
Write these three down before you continue. Every vendor proposal you receive will be incomparable unless you've fixed these inputs first.
Week 1 — Enquiry and scoping call
Reach out via the Organisations enquiry form with your three locked parameters. SMARTON's institutional team will set up a 45-minute scoping call within two business days.
Bring to the call:
- Your CSR budget envelope (a range is fine — e.g., ₹10–25 lakh).
- Your reporting cycle (most CSR teams report quarterly to the board's CSR committee).
- Any constraints — e.g., must be deployed before fiscal year-end, must include a third-party impact assessment, must be GST-invoiced to a specific entity.
You will leave the call with:
- An indicative proposal range for the deployment size you've described.
- A list of the seven supporting documents SMARTON will provide for your audit file (see Week 4 below).
- A draft 6-week timeline mapped to your milestones.
Week 2 — Formal proposal + Schedule VII confirmation
Within 5 business days of the scoping call, SMARTON delivers a formal proposal. The proposal includes — and this is the part that matters for your audit — a Schedule VII sub-clause confirmation letter.
For every SMARTON deployment, the confirmation letter explicitly states which Schedule VII sub-clauses the project falls under. For BVI accessibility programmes, this is almost always:
- Schedule VII (i) — promoting education, including special education and employment-enhancing vocation skills, especially among the differently-abled.
- Schedule VII (ii) — promoting healthcare and reducing inequalities.
- Schedule VII (iii) — measures for the benefit of differently-abled, including livelihood enhancement projects.
This single letter is what most CSR audits ask for first. With it on file, your spend is defensible at every subsequent audit stage. Without it, the burden of proof shifts to your team to argue the case post hoc — which is fixable but exhausting.
Week 3 — Internal board / CSR committee approval
Most Indian listed companies require board CSR committee approval for new programmes above an internal threshold (commonly ₹5 lakh or ₹10 lakh). Schedule the approval into your team's existing CSR committee cycle, with these materials attached:
- SMARTON formal proposal (from Week 2).
- Schedule VII sub-clause confirmation letter.
- One-page programme summary (we provide a template you can drop into your company format).
- Indicative impact projection — beneficiary count × expected engagement metrics × expected outcome score change.
Most CSR committees clear SMARTON proposals in a single review because the documentation matches what they audit for. Plan one buffer week if your committee meets monthly.
Week 4 — Procurement and the seven-document audit pack
Once board-approved, procurement moves quickly. SMARTON delivers the following seven documents during and immediately after procurement — keep them in your audit file from Day 1:
- Schedule VII sub-clause confirmation letter (from Week 2).
- GST tax invoice — issued to your named CSR entity (the proper GST entity matters for your books; confirm in advance).
- Deployment certificate — names your organisation, the beneficiary count, the date, and the SMARTON SKU/package.
- Beneficiary activation log — anonymised but verifiable record of every user account created (mobile number hash or device serial), with activation timestamps.
- Training completion records — for each beneficiary, dates of onboarding call(s), training completion, and check-in calls.
- Quarterly utilisation reports — feature-level engagement data, average session length, active vs dormant accounts.
- Quarterly impact summary — qualitative + quantitative impact, including self-reported independence score change and VI support team field notes.
This pack is the difference between a CSR audit that takes one meeting and an audit that drags on for months. We've prepared it for every deployment since 2024 because we've sat in the rooms where vendors couldn't produce it and watched what happened next.
Week 5 — Deployment and onboarding
SMARTON deployments follow a standardised 4-stage onboarding journey for every beneficiary:
- Activation — beneficiary receives the SMARTON Kit (glasses + app subscription) or app-only access. App is installed and account created.
- Welcome call (72-hour SLA) — a SMARTON VI support team member (themselves visually impaired) calls within 72 hours. Audio-only, in the beneficiary's language. Walks through pairing glasses, activating MIRA, running the first SmartEye scan, navigating to News, and saving the first document. By the end of the call, the beneficiary has used five core features.
- Week 2 check-in — same support team member calls back. Reviews which features have been tried, troubleshoots barriers, expands to features the user hasn't tried yet (AI Tutor, Audio Drama, Dating). Any technical issues are escalated to the product team the same day.
- Ongoing support — unlimited support over WhatsApp and phone for the duration of the subscription, in the beneficiary's language.
For larger deployments (100+ beneficiaries), SMARTON also runs in-person training camps in partner-NGO offices, eye hospitals, or your CSR-partner schools. Schedule these in Week 5 alongside individual welcome calls.
Week 6 — First impact report and CSR committee read-out
Six weeks after the procurement order, your first impact summary is ready. It includes:
- Beneficiary activation completion rate (target: 95%+ activated within 14 days).
- Welcome-call completion rate (target: 90%+ completed in their preferred language).
- Active-user rate (target: 75%+ active in the first 30 days).
- Most-used features ranked, with average daily session length.
- Self-reported independence-score change from beneficiary survey (administered by SMARTON's VI support team to remove bias).
- 3–5 anonymised beneficiary quotes from check-in calls (with explicit consent — never used otherwise).
Present this directly to your CSR committee. We've seen Indian boards approve programme expansion within the same meeting because the documentation pattern matches what they expect from an audit-cleared CSR programme.
Beyond Week 6: quarterly reporting cadence
After the first six weeks, the deployment moves to a quarterly cadence:
- Quarterly utilisation report (auto-generated, delivered to your CSR programme owner).
- Quarterly impact summary (qualitative + quantitative).
- Annual audit pack (rolled up from quarterly reports — drops directly into your statutory audit response file).
Common deployment patterns we see
Pattern 1: Employee + family programme
A large enterprise extends SMARTON access to BVI employees and their immediate family members (parents, siblings, children). Typical size: 25–80 beneficiaries. Fast to approve because the beneficiary list is internal. CSR books usually treat this as Schedule VII (i) and (iii).
Pattern 2: NGO partner programme
The CSR team funds SMARTON access for beneficiaries of an existing NGO partner — typically a blind school, eye hospital, or rehabilitation centre. Typical size: 50–200 beneficiaries. The NGO becomes the on-the-ground touchpoint, while SMARTON handles the technology, training, and reporting.
Pattern 3: Government-aligned programme
The CSR team funds a deployment that aligns with a state disability commission or central scheme (ADIP, etc.) — extending reach beyond what the government alone funds. Typical size: 100–500+ beneficiaries. Documentation requirements are heavier; SMARTON's 4-stage onboarding fits well because government auditors look for the same pattern.
What to avoid
Don't pay for devices without budgeting for training
The single most common CSR audit finding on assistive-technology spend is "devices delivered, not used". Every SMARTON proposal bundles training and support — refuse any vendor (including future SMARTON pricing variations) that lets you buy hardware alone.
Don't sign on a vendor who can't produce the seven-document audit pack
Ask in writing for samples of all seven documents before you procure. If a vendor can't show you a sample Schedule VII confirmation letter or a sample quarterly impact report, the documentation will not appear by itself when audit time comes.
Don't underestimate the language-localisation issue
Non-Indian vendors (Be My Eyes, Seeing AI, OrCam, Envision) do not natively support the languages your beneficiaries actually speak. See our app comparison for the detail. Language support is an audit point, not a nice-to-have — RPWD Act Sections 40–46 mandate accessible information in regional languages where applicable.
Ready to start?
The six-week timeline above is the fast path — most CSR teams that have done a deployment before can move from enquiry to signed deployment in 4 weeks; first-time deployments take 6–8. We've delivered SMARTON to 17,000+ beneficiaries across 50+ NGO partners in this exact pattern.
Start with the enquiry form or download the CSR Impact Brief for a portable copy of this playbook to share with your committee. We can also send the seven-document audit pack samples to your CSR audit lead directly — ask on the scoping call.
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