A knowledge session on 29 July at Yashoda Hospitals, Hitec City, Hyderabad took up the theme "CSR Meets the Social Stock Exchange: A Journey Ahead". The room had corporates, NGOs, philanthropists, impact investors and academia in it.
Two things came out of the session that matter to anyone running an NGO in India right now. One is a clear reading of where CSR money is headed. The other is a live example of an NGO preparing to list on the Social Stock Exchange.
The CSR journey, as Bhaskar Chatterjee told it
Bhaskar Chatterjee, the former IAS officer widely credited as an architect of India's CSR framework, opened with the history. It is worth repeating, because most people only know the 2013 half of it.
CSR did not begin with the Companies Act. It began in 2010, when CSR guidelines were issued for central public sector enterprises. The private sector came in only with the Companies Act, 2013, whose CSR provisions took effect from 1 April 2014. Four years separated the two.
His statement of the objective was plain: serve the underserved.
The numbers he shared show how far the framework has travelled.
Companies covered under mandatory CSR: from roughly 8,000 to more than 30,000
Annual CSR spending: from around ₹9,000 crore to more than ₹40,000 crore
His projection: ₹75,000 crore within three years, and eventually above ₹1 lakh crore
The last two figures are his projection rather than a published number. The direction is not in dispute.
The strategic triangle
The most useful part of his talk was structural. He described CSR delivery as a triangle with three roles, each held by a different party.
The apex is the government. It sets the framework and the rules. Through the Ministry of Corporate Affairs it decides what counts as CSR, who is covered, how much must be spent and what has to be reported. Through SEBI it now also governs how non-profits raise and account for money on the Social Stock Exchange. It does not deliver anything itself.
One side is the corporate. It funds the work, evaluates it and monitors it. Its accountability runs to its board, its shareholders and the Registrar. It answers for whether the money went where it was meant to go.
The third side is the implementing body. It secures the resources and takes the cause to the ground. In most cases this is an NGO. It carries the field knowledge, the community relationships and the operating capacity that neither of the other two has.
The reason he drew it as a triangle and not a chain is that the three roles are not interchangeable, and none of them sits above the other two in practice. A triangle only holds when all three sides bear load.
There is a second reason the shape matters, and it is about standing. An NGO in this model is a side of the triangle, not a vendor at the bottom of a procurement chain. The corporate cannot serve the cause without it. That position is only real if the NGO can actually do the two things assigned to it: secure resources, and deliver.
The Social Stock Exchange changes the triangle in a specific way. It gives the NGO a resource-raising route that does not depend on being introduced to a corporate CSR head. It shifts a large part of the verification load from the corporate to the regulator. And it gives the government's apex role a set of instruments rather than only rules. The three roles stay the same. The mechanism connecting them gets stronger.
Where the Social Stock Exchange fits
Chatterjee then connected this to the SSE. Eligible non-profits can raise money through Zero Coupon Zero Principal (ZCZP) instruments listed on the SSE, which runs as a segment of both the BSE and the NSE under SEBI's framework. The subscriber gets no interest and no principal back. What it gets is an audited, disclosed and verifiable account of what the money achieved.
The point that corporates in the room reacted to was about impact assessment.
Under Rule 8(3) of the CSR Rules, a company whose average CSR obligation over the three immediately preceding financial years is ₹10 crore or more must commission an independent impact assessment of any CSR work with an outlay of ₹1 crore or more, once it has been completed for at least a year. That is a real cost and a real administrative load, and it falls on the corporate.
Under the amendment notified by the MCA on 27 May 2026, which inserted Rule 4A into the CSR Rules, a company subscribing to ZCZP instruments does not have to conduct that assessment for the work funded through them. SEBI's SSE framework already carries the burden. The listed NPO has to file an Annual Impact Report assessed by a Social Impact Assessor, and it stays under continuous disclosure obligations for as long as the instrument is listed. The NPO also has to complete the work within three succeeding financial years of issue, and transfer any unspent amount to a Schedule VII fund when the listing ends.
So the compliance sits with the regulator and the NPO instead of the subscribing corporate. For a CSR head, that removes a step and a cost.
Today there is a restriction on the 10 per cent contribution, but it can eventually be raised. The MCA and corporate bodies are actively working on the rules and compliance, with the intent of easing the route so NPOs can access more resources and serve their cause more effectively.
One thing worth knowing if you are raising through ZCZP. Some commentators have argued that disclosure and impact assessment are not the same thing, and that a subscribing company can now fund work without ever forming its own view on whether it worked. Serious corporates will do their own diligence regardless of the exemption. Build for that.
Grace Cancer Foundation's announcement
The session also carried a concrete announcement. Grace Cancer Foundation said it plans to seek listing on the Social Stock Exchange.
The reason its founder, Chinnababu Sunkavalli, gave for the listing is the part worth noting. He said the aim is to strengthen institutional governance, transparency, compliance and impact measurement, not simply to raise funds.
That is the argument we keep making to NGOs. The SSE process forces structure on an organisation. Registration, disclosure, an assessed Annual Impact Report, outcomes defined in advance, and a fixed timeline. Most organisations find that discipline is worth more than the first round of money it brings in. We have written up what that process looked like for CHORD, which registered on the NSE segment.
The foundation's stated plans include a Centre of Excellence for Preventive Oncology, fully AI-enabled mobile cancer screening units, stronger rural digital healthcare platforms, and cancer and NCD screening expanded across the country.
What this means if you run an NGO
Put the two halves of the session together and the position is this.
CSR money is growing and is expected to keep growing. A formal, regulated route now exists to bring part of it to non-profits, and the rules were amended to make that route easier for corporates to use. Corporates using it will be looking for NPOs already registered on the SSE, because a ZCZP instrument can only be issued by one.
Registration is the gate, and the field is still thin. As of May 2026 there were 92 NPOs registered on the BSE SSE segment and 84 on the NSE SSE segment. Only 11 had actually listed an instrument and raised money through it.
SEBI has also been easing the route. An NPO can now stay registered for up to three years without raising funds, the minimum subscription needed for an issue to go through has been brought down from 75 per cent to 50 per cent, and the minimum application size for a subscriber is ₹1,000.
If your organisation is eligible, the work to do now is the unglamorous part. Registration. Governance documentation. Outcomes you are willing to be measured against. And a plan for the cause that can be delivered within three financial years.
Is your NGO ready for the SSE?
Check where your organisation stands against SEBI's criteria before you start the registration paperwork.