The Agency Took the Cheque

A special after CSR Ticket Size. Not Part 9.

The series asked why India’s average CSR project stayed near ₹35 lakh while the money tripled.

This piece asks the question the comments kept asking.

Directly. Through an NGO. Through our own foundation.

Who holds the pen — and did that choice change the cheque?

Short answer: the pen changed hands. The cheque did not grow. The channel that absorbed the decade is the one that got thinner.

Three ways to file the same rupee

On the National CSR Portal, every project row carries a mode. The labels are messy — the same idea is capitalised two or three ways — but they collapse into three vehicles that matter:

• Directly by the company
• Other implementing agencies (the NGO / external partner line)
• A trust, society, or Section 8 company set up by the company itself

There is a fourth, small one: trusts set up by government. About 1% of spend, sitting near the national average. Not the plot.

And there is NEC / Not Mentioned. Many rows, little money. A labelling sink. Ignored here as a vehicle.

Across FY 2014-15 to FY 2024-25, read the typical row before you fall in love with the ₹70 lakh:

The foundation does not lift the everyday cheque. It fattens the average, because a thicker tail of ₹1 crore and ₹5 crore lines pulls the mean up. About 80% of own-trust rupees, in the years that label was used, sit in rows of ₹1 crore or more. The median never left the ₹10 lakh neighbourhood of the agency market.

That is the myth, dealt with. Now the decade, which is the actual story.

The pen moved

FY 2023-24 is the last year in this file where all three labels still exist. In FY 2024-25 the extract contains only agency, direct, and NEC. Do not read that as “foundations spent zero.” Read it as the form stopped offering the old bucket — or this pull no longer received it.

The takeover did not start in 2021. By FY 2016-17 the agency line was already about half of CSR spend. It then kept climbing: ~51%, ~60%, ~66%, ~70%.

Same shape as education and health in Part 6.

The channel that gained the volume did not keep a fat ticket. It settled toward the national number, and in the recent years it sits just above it (~₹43–44 lakh) while direct sits under it (~₹27 lakh).

India did not discover a deeper way to write CSR. India handed the default cheque to the implementing agency, and the default got ordinary.

The foundation number is an early-year object

If you only see the all-years table, you will go and set up a Section 8 company.

Don’t. Not for ticket size.

In FY 2014-15 the own-trust line was a fifth of all CSR spend — about ₹2,050 crore — written across under 1,000 non-zero rows. Average about ₹2.1 crore. That is a handful of large lines in year one of the law, not a national habit.

It then lived for a while as a minority channel: roughly 6–9% of spend, average row drifting from ~₹80 lakh toward ~₹60 lakh, through FY 2020-21.

Then the cliff.

FY 2021-22 is the year the CSR-1 rule bites: implementing agencies, including entities set up by the company, were pushed to register with the Ministry. A corporate foundation is, in law, an implementing agency. A large share of those rupees almost certainly moved into the “other implementing agencies” line rather than ceasing to exist.

So this is not an obituary for foundations.

It is a warning about the statistic. The ₹70 lakh all-years average is what the label looked like when companies still used it for their big lines, weighted toward the early years. Once the label is either rare or gone, there is no separate fat-cheque vehicle left on the form.

You cannot see, from the mode field alone, which of today’s agency rows are a company’s own foundation and which are an outside NGO. Anyone who ranks “own foundation vs NGO” off the recent portal file is ranking a category the file no longer keeps cleanly.

Direct is the channel that is actually small

Agency is the volume machine of delivery. Direct is the thin one.

All years, non-zero rows: half of direct rows are micro-lines. Recent direct average is ~₹27 lakh — under the national ₹35 lakh, and about half of what direct itself was in FY 2014-15.

That fits Part 5. The typical company-year is ~₹23 lakh. A company with one small obligation does not hire a foundation. It files directly, often one line, often under ₹5 lakh. Lecturing that company to “professionalise through a trust” does not create a ₹70 lakh row. It creates a compliance cost on top of a ₹5 lakh cheque.

The companies that can move a mean are already inside the agency line, or used to be visible as trusts and are now inside it unlabelled.

What to do with this on Monday

If you are a board.

“We work through an implementing agency” is no longer a strategy. It is the default. About seven rupees in ten are filed that way, at an average that has been drifting down for a decade. A new foundation does not show up on the recent form as a fatter cheque. Part 8 still stands: the design variable is how many rows, not which dropdown you pick.

Ask the agency question one level down, where the form has gone blind: of our agency rows, which are our own institution, and which are partners — and what is the median of each? The portal will not answer it for you anymore. Your annex will.

If you are an NGO.

You are not pitching a side door. You are pitching the market. Recent agency rows average on the order of ₹44 lakh. The all-years median agency row is still about ₹10 lakh. A ₹8 lakh proposal is the grain. A ₹5 crore proposal is a conversation with the tail — the same tail that once made own-trust averages look like a different country.

If you are reading the ₹70 lakh as a target.

It was a mean, in a label, in the years the label still caught large lines. The median under that label was ₹10 lakh. The recent years that still use the label average ~₹27 lakh. Chasing the historical mean is how annual reports stay busier than programmes.

The line that connects to the series

Part 1: spend tripled, the average project did not. Part 6: education and health became half the money and settled on the mean. This special: the implementing agency became the way the money is written, and settled there too.

Different dropdown. Same geometry.

The vehicle was never the lever. It was the place the lever got harder to see.

Data: National CSR Portal company-wise project filings, FY 2014-15 to FY 2024-25. Averages are amount spent ÷ non-zero project rows. Mode strings merged across capitalisation. NEC excluded from the vehicle story. FY 2024-25 has no own-trust or government-trust label in this file; the shift is therefore told through FY 2023-24, the last year the three vehicles can still be seen apart. A portal row is a filing unit, not always one ground programme. This is not a ranking of foundations, NGOs, or impact. Also on LinkedIn.