India’s ₹35,000 Crore Corporate Social Responsibility (CSR) Mandate: An Underleveraged Frontier for Effective Giving?

A Note Before You Read: I'm writing this post partly to think through a problem I've been sitting with for a while, and partly to find out if anyone else is working on it - or has already tried and learned hard lessons. This is also an early public draft of a working paper I'm developing. I'd genuinely love to hear both pushback and interest in collaborating.

Disclosure: I used Grok AI to assist with drafting and editing portions of this post. All core arguments, research, data sourcing, and analysis were developed, reviewed, and modified by me.

The Basic Observation

India’s Companies Act, 2013 mandates that companies meeting certain financial thresholds - a net worth greater than or equal to ₹500 crore, a turnover greater than or equal to ₹1,000 crore, or a net profit greater than or equal to ₹5 crore - must spend at least 2% of their average net profits on Corporate Social Responsibility (CSR) activities. In FY 2023–24 alone, 27,188 companies spent approximately ~$4.2 billion (₹34,908.75 crore) - an official figure drawn directly from FY 2023-24 corporate filings on the MCA National CSR Portal Data Registry, not an estimate - across 59,633 projects mapped across Schedule VII’s developmental focus disciplines, according to the official Ministry of Corporate Affairs National CSR Portal Data Registry. Since the mandate's inception in 2014, the cumulative CSR deployment has crossed ~$26 billion (₹2.18 lakh crore) (the figure referenced in this post's title rounds the annual FY 2023-24 number; the cumulative total is significantly larger), an aggregate baseline verified in the recent Ministry of Corporate Affairs Official PIB Union Disclosure. This marks one of the largest directed pools of corporate social investment anywhere in the world - comparable in scale to several major bilateral aid programmes.

And most of it is being allocated without anything resembling rigorous cause prioritisation or cost-effectiveness thinking.

To put a realistic number on the counterfactual gap: the explicit "Health Care" vertical alone accounts for roughly 20.5% of total annual CSR disbursements, representing ~$860 million (₹7,150.81 crore) - an official figure derived directly from the MCA’s sector-wise FY 2023-24 disclosure data, not a modelled estimate - in annual health sector spend, as mathematically verified via Annexure-II of the Ministry of Corporate Affairs Lok Sabha Statutory Reporting Registry. If we expand this definition to include adjacent statutory tracks for sanitation, safe drinking water, and malnutrition eradication, the pool climbs to ~$1.09 billion (₹9,087.42 crore). If even 10% of that baseline healthcare pool were redirected from typical visibility-driven interventions to GiveWell-tier cost-effective programmes - a conservative assumption - at standard Indian health system cost-effectiveness thresholds of ₹20,000-50,000 per DALY averted, redirecting just 10% of that pool (approximately ~$86 million / ₹715 crore) would imply between 1.43 million and 3.58 million DALYs averted annually. Even under significantly more conservative assumptions about cost-effectiveness or the share of redirectable capital, the implied impact remains in the hundreds of thousands of DALYs averted per year.

This direction is highly consistent with empirical models mapped in the J-PAL South Asia Research Database summary on Frontline Delivery Loops. This evidence base includes Abhijit Banerjee et al.’s (2010) open-access evaluation on “Improving Immunisation Coverage in Rural India” published in the BMJ, alongside Zulfiqar A. Bhutta et al.’s (2013) landmark paper, “Evidence-based interventions for improvement of maternal and child nutrition,” published open-access in The Lancet. The 3–5x DALY multiplier is an illustrative estimate; the working paper will model this formally with sensitivity bounds based on standard World Health Organization Cost-Effectiveness Alternative Thresholds. The geographic constraint is respected. The counterfactual gap is large. That delta is what constrained maximisation captures - and it is entirely invisible to a CSR committee without an analytical framework.

I currently work at Fortify Health, a GiveWell-supported nonprofit working on reducing iron-deficiency anemia in India through wheat flour fortification. I should flag upfront: I work in the public health-nutrition space that this framework would partially cover, which creates a potential conflict of interest. The analysis below aims to be cause-neutral within Schedule VII constraints, and I'll address this directly in the working paper by testing whether the framework recommends interventions like Fortify Health's more than the evidence independently warrants. Readers should weigh that context.

What’s Actually Going Wrong with Indian CSR?

A lot of the problem is structural rather than a failure of intent. Six things I’ve observed and read about:

1. It’s designed as a compliance mechanism, not an impact mechanism.

The legal framework under Schedule VII of the Companies Act, 2013 specifies eligible activity categories broadly - education, healthcare, rural development, environmental sustainability - but provides no guidance on prioritisation within those categories, no cost-effectiveness requirements, and no meaningful impact measurement obligation.

The 2021 amendments moved from a flexible “comply or explain” regime to a strict, penalty-backed “comply or transfer” architecture, as outlined in the official Ministry of Corporate Affairs CSR Policy Amendment Rules. Unspent CSR funds must be transferred to government-designated escrow accounts within six months of the fiscal year-end - and defaulting corporate officers face direct, mandatory personal financial liabilities. The Ministry of Corporate Affairs has issued compliance show-cause notices and initiated penal proceedings against defaulting companies; this is not an abstract threat.

The consequence is predictable and important: CSR heads operate under what amounts to a structural sword of Damocles. Speed of capital absorption and safety of the audit trail completely crowd out any optimization for impact per rupee. The rational response, from a compliance risk standpoint, is to partner with a known, reputable implementing agency and produce clear output metrics - classrooms built, patients treated, trees planted - regardless of whether those outputs translate into meaningful long-term outcomes. This is not irrationality; it is rational behavior under a badly designed incentive system.

But the same amendments also introduced something vital: a mandatory independent impact assessment requirement for large CSR spenders (companies with an annual CSR obligation greater than or equal to ₹10 crore). This requirement, tracked comprehensively within the governance frameworks of the Institute of Company Secretaries of India (ICSI) Statutory Bulletin, serves as our primary regulatory wedge.

2. CSR heads face the wrong incentives.

Even where legal latitude exists, CSR heads are rarely incentivised to maximise impact per rupee. They are incentivised to minimise compliance risk and maximise corporate visibility. An Effective Altruism-aligned approach requires embracing probabilistic thinking - acknowledging that some interventions might not work as expected but carry massive upside potential. Corporate boards, by contrast, demand audit-proof, predictable outputs: “We built 10 classrooms.” “We planted 5,000 trees.” The incentive structure actively works against rigorous prioritisation.

3. The NGO sector has a capacity problem that limits evaluability.

GiveWell’s model depends on cost-effectiveness analysis anchored in rigorous evidence - randomised controlled trials, detailed financial modelling, and tight monitoring data. When GiveWell’s own team attempted to evaluate local Indian NGOs, they documented a severe structural mismatch in their historical assessment, Evaluating Local Charities in India: standard cost-effectiveness criteria simply did not fit organizations lacking the capacity for extensive monitoring, evaluation, and documentation.

While certain metrics have improved, the fundamental measurement and evaluation (M&E) infrastructure gap remains unresolved. India has hundreds of thousands of registered civil society organizations listed on platforms like GuideStar India, but the proportion with the institutional architecture to manage large, multi-year programs and report transparently against strict outcome indicators is considerably smaller. This creates a circular bottleneck: evaluators cannot analyze what cannot be measured, and grassroots NGOs do not invest in complex measurement systems because corporate donors do not demand or fund them.

4. The intermediary layer is the actual bottleneck - and it’s largely invisible to EA analysis.

This is the structural insight I think is most underappreciated in existing discussions of this space, and the one I’d most welcome pushback on from people with direct CSR consultancy experience.

Corporate boards rarely interface with implementing organisations directly. Instead, they rely on institutional CSR consultancies and intermediary agencies - firms like Samhita, Sattva, or KPMG India’s CSR practice - to manage their allocations. Because these intermediaries are themselves evaluated on capital deployment speed and compliance safety rather than marginal outcome optimisation, they default to low-risk, asset-heavy, highly visible interventions. This reality is documented in Sattva Consulting's India CSR Outlook Insights, which reveals that three-quarters of all corporate capital remains heavily concentrated in traditional, output-centric delivery loops. The incentive misalignment doesn’t end at the CSR committee - it runs through the entire advisory ecosystem that sits between corporate capital and ground-level impact.

The implication is uncomfortable: an EA-aligned information infrastructure that targets only the internal CSR team will not move the money. It must actively reshape the evaluation rubrics used by these consultancies - the layer that acts as the real gatekeeper to these funds. That means engaging Samhita, Sattva, and KPMG India’s CSR practice directly, not just the committees they advise. I don’t yet have a fully developed theory of change for how to do this, but the contours of one are beginning to take shape. A plausible near-term pathway has three components: first, publishing a methodological framework (the Comparative Cost-Effectiveness Registry described later in this post) that intermediaries could adopt voluntarily as a quality differentiator in a competitive market where most CSR consultancies offer nearly identical compliance-focused services; second, identifying one intermediary firm willing to pilot an EA-aligned impact assessment on a single live project, generating a case study that demonstrates the audit-defensibility benefit to other firms in the market; and third, working through the Institute of Company Secretaries of India (ICSI) and similar professional bodies whose statutory bulletins already shape how CSR consultancies interpret compliance requirements, to embed cost-effectiveness considerations into the recommended impact assessment templates these professional bodies issue. This is a sketch, not a fully tested theory of change. I would value input from anyone who has tried any version of this.

5. The evaluator landscape is emerging - but lacks the distribution to reach corporate boardrooms.

The picture is more nuanced than simply “there’s no GiveWell for India.” Platforms like GuideStar India assess governance and financial efficiency, while specialized verification bodies operating under the Credibility Alliance National Accreditation Framework focus on operational due diligence and minimum voluntary norms. Crucially, Impactful Giving India's Evidence-Based Methodology has established a rigorous domestic effective-giving pipeline, utilizing scale-solvability-neglectedness frameworks to vet and direct funds to highly cost-effective domestic charities.

The gap, then, is not simply the absence of evaluators. It’s that existing evaluators lack the distribution networks, corporate credibility, and regulatory framing to reach mainstream CSR committees. A company under Schedule VII compliance pressure isn’t browsing EA-adjacent platforms. They need a trusted interlocutor who speaks the language of compliance, audit, and corporate governance while applying the analytical rigour of cost-effectiveness thinking. That bridge doesn’t yet exist at scale.

6. Deadline-driven allocation crowds out thoughtful prioritisation.

Many CSR teams begin their allocation process late in the financial year. The result is that partner selection happens under severe time pressure, through referrals and informal networks, with little room for systematic analysis.

The root cause is not a lack of funds; it is a structural artifact of administrative planning timelines. Under the strict penalty frameworks detailed in the Ministry of Corporate Affairs Official PIB Union Disclosure, any unspent capital not committed to an ongoing project must be transferred to a government escrow account within six months of the fiscal year-end. This creates an intense year-end administrative rush where the certainty of immediate capital absorption is prioritized over long-term strategic value. EA’s multi-year planning horizon is structurally difficult to reconcile with the rigid 12-month fiscal calendar that governs statutory CSR compliance.

What I’m Trying to Think Through

The core hypothesis - and why it’s harder than it looks.

My working hypothesis is that Effective Altruism-style prioritisation is legally viable within India’s CSR framework. Schedule VII is a floor, not a ceiling. The law dictates which broad buckets money must be spent in, but it is completely silent on how effectively those buckets are filled. A company mandated to spend ₹5 crore on healthcare in a specific district of Maharashtra can legally choose to spend it on a high-evidence, cost-effective intervention - like maternal iron supplementation or community health worker programmes - rather than an expensive, low-impact mobile medical van. That legal latitude exists.

But legal viability and institutional viability are different things. The honest framing of this project is: what would it take to close the gap between the two?

EA as a decentralised information ledger, not a moral imposition.

One reframe that I think matters enormously for how this gets adopted: EA frameworks shouldn’t be presented to CSR committees as a moral obligation or a critique of their past choices. They should be presented as a solution to a problem CSR committees already experience and already want solved - the problem of not knowing whether their money is doing anything.

CSR heads in Mumbai or Delhi are trying to allocate capital to distributed local problems-nutritional stunting in a tribal block of Jharkhand, waterborne disease in a peri-urban slum in Odisha-that they have no direct expertise in, through implementing partners they cannot independently evaluate. This is a classic Hayekian knowledge-dispersal problem: the information needed to allocate well is dispersed, local, tacit, and entirely inaccessible through normal corporate data systems.

As Friedrich A. Hayek famously demonstrated in his landmark 1945 paper, “The Use of Knowledge in Society”, originally published in The American Economic Review, central allocation of capital to local problems it cannot see clearly is structurally bound to fail due to bad epistemics rather than bad intent. To resolve these centralized information vulnerabilities within decentralized development environments, our optimization model builds on the institutional design principles laid out in Elinor Ostrom’s pioneering research on complex economic systems, accessible via the official Nobel Prize archive in her open-access text, “Beyond Markets and States: Polycentric Governance of Complex Economic Systems.” EA frameworks, in this framing, are an information infrastructure that solves a knowledge problem corporations already want solved. They don’t need to gather evidence from scratch on whether community health workers reduce under-5 mortality in low-income rural settings; that evidence already exists, has been synthesised, and can be applied locally. That reframe - institutional utility, not moral philosophy - might matter more for adoption than any argument about effective altruism as an ethical commitment.

The 2021 Impact Assessment Mandate as a wedge - turning a compliance cost into a data engine.

The 2021 CSR amendments mandated that companies with annual CSR obligations greater than or equal to ₹10 crore must conduct independent third-party impact assessments for individual projects greater than or equal to ₹1 crore. Corporate India is already paying for third-party evaluation. The problem is that most of this evaluation is uninspired compliance-checking - box-ticking on outputs rather than rigorous analysis of outcomes or cost-effectiveness. It is an administrative cost centre, not an information asset.

But it doesn’t have to be. Effective Altruism frameworks could be positioned not as an additional burden on already-stretched CSR teams, but as a way to make the mandatory impact assessments companies are already commissioning actually useful for future allocation decisions. An impact assessment designed around cost-effectiveness principles doesn’t just satisfy the regulator - it generates the comparative data that allows a CSR committee to make a better decision next year. It transforms a backward-looking compliance exercise into a forward-looking allocation tool. And crucially, a rigorous, documented, evidence-informed process is a far stronger audit defence for board directors than “we gave to a charity we’d heard of.”

This is the wedge. Not an argument about EA philosophy - an argument about making a mandatory regulatory requirement more useful, tracked directly via the compliance pathways outlined in The Institute of Company Secretaries of India (ICSI) Statutory Bulletin.

Constrained Maximisation - working within the limits rather than around them.

The approach I find most honest and most likely to be adopted is what I’d call “constrained maximisation”: accepting the geographic and sectoral constraints that Schedule VII and corporate culture impose, and then applying rigorous cost-effectiveness thinking within those constraints.

To make this concrete: a standard default intervention in this space is a high-visibility mobile medical van serving a factory catchment area-typically costing around ~$48,000 (₹40 lakh), treating roughly 1,000 patients per year, with well-documented limitations including low medication adherence, high operational costs, and minimal impact on underlying disease burden. The same ~$48,000 (₹40 lakh) directed to community health worker deployment and maternal iron-folic acid supplementation in the same catchment area plausibly generates 3–5x the DALY impact at equivalent cost.

This direction is highly consistent with empirical models mapped in the J-PAL South Asia Research Database summary on Frontline Delivery Loops, which aggregates randomized evaluations on frontline delivery frameworks. This evidence base includes Abhijit Banerjee et al.’s (2010) open-access study on “Improving Immunisation Coverage in Rural India” published in the BMJ, alongside Zulfiqar A. Bhutta et al.’s (2013) landmark paper, “Evidence-based interventions for improvement of maternal and child nutrition,” published open-access in The Lancet.

The 3–5x DALY multiplier is an illustrative estimate; the working paper will model this formally with sensitivity bounds based on standard World Health Organization Cost-Effectiveness Alternative Thresholds. The geographic constraint is respected. The counterfactual gap is large. That delta is what constrained maximisation captures-and it is entirely invisible to a CSR committee without an analytical framework.

There is a genuine tension here between EA’s cause-neutral global framing and the regulatory and cultural pressure for CSR to benefit local communities. I don’t think the right answer is simply “cause-neutrality wins.” The regulatory constraint is real and isn’t going away. Constrained maximisation is a more modest ambition than cause-neutral EA - but it’s honest, legally compliant, and might actually get used. Whether that framing concedes too much is one of the things I’d most like to hear pushback on.

Is a GiveWell-for-India feasible?

Partially, and the prerequisites matter. The NGO M&E capacity gap is real and will take years to close. But a lighter-touch version-what we might call a Comparative Cost-Effectiveness Registry for Schedule VII-is achievable in the near term.

Instead of requiring under-resourced grassroots NGOs to generate original experimental data, this entity would specialize in evidence localization: taking robust empirical evidence from the J-PAL Randomized Evaluation Evidence Repository and the Cochrane Collaboration Library, and mapping those impact coefficients onto local Indian NGO cost structures and delivery models. The output would be a sector-specific, Schedule VII-mapped comparative database-not cost-per-life-saved estimates requiring years of original RCTs, but a “cost-per-beneficiary-outcome” tier that lets a CSR committee compare interventions in their geographic mandate area by evidence base and estimated cost-effectiveness.

For evidence localization methodology, this mapping model adapts the Bayesian hierarchical tools outlined in Rachael Meager’s (2022) landmark paper, “Aggregating Distributional Treatment Effects: A Bayesian Hierarchical Analysis of the Microcredit Literature,” published in The American Economic Review, which directly addresses the econometric and statistical challenges of pooling and generalizing treatment effect heterogeneity across diverse geographic contexts.

Critically, this Registry could plug directly into the mandatory impact assessment ecosystem introduced by the 2021 amendments-generating audit-defensible, evidence-grounded comparative data that tracks smoothly against the statutory provisions broken down in the Bombay Chartered Accountant Journal's CSR Rule Analysis and the compliance parameters detailed in the Institute of Company Secretaries of India (ICSI) Statutory Bulletin. This gives corporate boards a legitimate, legally recognized regulatory architecture to justify funding unglamorous, high-impact interventions over high-visibility, low-impact ones.

One honest caveat: evidence localization from globalized, tightly controlled trial environments to highly variable local Indian delivery contexts involves serious transportability challenges. Microeconomic parameters vary, local cost architectures differ significantly, and programmatic implementation fidelity is rarely uniform. The working paper will grapple with these external validity constraints directly by modeling structural parameter bounds against official World Health Organization Cost-Effectiveness Alternative Thresholds rather than assuming a frictionless transfer of impact.

What I’m Working On

I’m developing a working paper tentatively titled “From Compliance to Impact: Applying Effective Altruism Principles to India’s Mandatory CSR Ecosystem.” My aim is to produce something useful for both the Effective Altruism research community and practitioners - CSR committee members, corporate legal teams, and corporate foundations who might actually want to give better but do not know where to start.

The final paper will do three specific things this introductory overview does not:

1. Develop the DALY quantification model with proper methodology and sensitivity analysis.
2. Build out a concrete theory of change for how EA-aligned evaluation standards might realistically propagate through the intermediary consultancy layer.
3. Address the conflict-of-interest question directly by testing whether our constrained maximisation framework recommends large-scale fortification interventions more than the empirical evidence independently warrants.

I’m in the early stages, and I am not aware of anyone else currently exploring these specific questions. I’m writing this post precisely because I genuinely want to find out whether others have already worked through parts of this problem, what they found, and if there are lessons to be learned.

What I’d Love to Know from You

I’d really love to hear from you if you fit any of the following profiles:

If you’re a researcher or writer:

• LMIC Institutional Giving: Are you already working on EA frameworks applied to corporate or institutional giving in low- and middle-income countries? I’d love to compare notes and avoid duplicating work.
• The Epistemic State: Have you engaged seriously with the Hayekian knowledge-problem framing in an EA context? What is the current state of that literature?
• Transportability Barriers: What do you see as the strongest methodological objection to evidence localisation - specifically, applying global RCT impact coefficients to local Indian delivery contexts?
• Existing CEA Literature: Do you know of existing, rigorous cost-effectiveness analysis of Indian NGOs that goes beyond basic governance-and-compliance ratings?

If you’re a practitioner - in CSR, a corporate foundation, or an Indian NGO:

• Operational Friction: Have you tried applying evidence-based cost-effectiveness thinking inside a live CSR programme? What worked, and what hit walls?
• Reshaping the Gatekeepers: Has anyone successfully influenced or changed the evaluation and allocation rubrics used by a major institutional CSR consultancy like Samhita or Sattva? I would especially like to hear about this.
• The Impact Mandate Wedge: Have you seen the 2021 impact assessment mandate used meaningfully to shift capital, or is it purely compliance theatre so far?
• Boardroom Triggers: What does a corporate CSR committee actually need to see on paper to start making better allocation decisions?

If you’re a funder or EA-infrastructure person:

• Applied Research Funding: Is there existing funding or interest for applied research on EA movement-building in India or the broader LMIC institutional giving space?
• Infrastructure Viability: Would a Comparative Cost-Effectiveness Registry for Schedule VII be the kind of structural infrastructure project that EA Funds, Co-Impact, or similar grant pools would consider evaluating?
• Strategic Bridges: Are there existing organisations currently trying to bridge the gap between EA frameworks and corporate giving that I should know about?

Thanks for reading. I’d especially welcome pushback on the framing above - particularly on whether the intermediary layer argument holds up among people with direct CSR consultancy experience, and whether constrained maximisation concedes too much to regulatory constraints that might be more malleable than I’m assuming. I’m thinking in public here and may be missing things that are obvious to people who’ve worked in this space longer.

Tagging a few organisations and individuals who may find this relevant or useful: @GiveWell, @Coefficient Giving, @Ambitious Impact, @Luke Freeman

Bibliography

• Abdul Latif Jameel Poverty Action Lab (J-PAL). (2018). The Role of Cash Transfers in Improving Child Health: A Review of the Evidence. J-PAL South Asia Research Review Publications. https://www.povertyactionlab.org/sites/default/files/review-paper/CaTCH_review-paper_cash-transfers_2018.10.09.pdf
• Abdul Latif Jameel Poverty Action Lab (J-PAL). (2026). Randomized Evaluation Evidence Repository Database. Massachusetts Institute of Technology. https://www.povertyactionlab.org/evaluations
• Banerjee, A., Duflo, E., Glennerster, R., & Kothari, D. (2010). Improving immunisation coverage in rural India: Clustered randomised controlled evaluation of teams providing reliable services and incentives. BMJ, 340, c2220. https://www.bmj.com/content/340/bmj.c2220
• Bhutta, Z. A., Das, J. K., Bahl, R., Lawn, J. E., Salam, R. A., Paul, V. K., ... & Black, R. E. (2013). Evidence-based interventions for improvement of maternal and child nutrition: What can be done and at what cost? The Lancet, 382(9890), 452–477. https://www.thelancet.com/journals/lancet/article/PIIS0140-6736(13)60996-4/fulltext
• Bombay Chartered Accountant Journal (BCAJ). (2021). CSR Rules Amendment: An Analysis. BCAJ Statutory Compliance Archive. https://bcajonline.org/journal/csr-rules-amendment-an-analysis/
• Cochrane Collaboration. (2026). Cochrane Library of Systematic Reviews. Wiley Online Library. https://www.cochranelibrary.com/
• Credibility Alliance. (2026). National Accreditation Framework: Minimum Voluntary Norms and Operational Due Diligence Standards for Good Governance. https://credibilityalliance.org/
• GiveWell. (2011). Evaluating Local Charities in India. GiveWell Official Blog Archive. https://blog.givewell.org/2011/05/04/evaluating-local-charities-in-india/
• GuideStar India. (2026). Nonprofit ratings, regulatory compliance, and philanthropy transparency portal. Civil Society Information Services India. https://www.guidestarindia.org/
• Hayek, F. A. (1945). The Use of Knowledge in Society. The American Economic Review, 35(4), 519–530. Free open-access text available via University of Chicago: https://home.uchicago.edu/~vlima/courses/econ200/spring01/hayek.pdf
• Impactful Giving India. (2026). Our Approach: Evidence-Based Methodology and Allocation Frameworks. Impactful Giving Portals. https://www.impactfulgiving.in/approach
• Marseille, E., Larson, B., Kazi, D. S., Kahn, J. G., & Rosen, S. (2015). Thresholds for the cost-effectiveness of interventions: Alternative approaches. Bulletin of the World Health Organization, 93(2), 118–124. Direct open-access PDF available via the Center for Global Development: https://www.cgdev.org/sites/default/files/Marseille%2CLarson%2CKazi%2CKahn%2CRosen-2015-Thresholds-for-the-Cost-Effectiveness-of-Interventions-Alternative-Approaches.pdf
• Meager, R. (2022). Aggregating Distributional Treatment Effects: A Bayesian Hierarchical Analysis of the Microcredit Literature. The American Economic Review, 112(6), 1818–1847. Free open-access version available via London School of Economics: https://www.lse.ac.uk/economics/Assets/Documents/finance-and-development-workshop/meager-aggregating-distributiona-treatment-effects.pdf
• Ministry of Corporate Affairs. (2021). Companies (Corporate Social Responsibility Policy) Amendment Rules, 2021. Government of India Gazette Mirror. https://www.sukhjitgroup.com/assets/uploads/files/pages/pdfs/88a4f-csr-mca-notification-dt-22-01-2021-companies-csr-policy-amendment-rules-2021.pdf
• Ministry of Corporate Affairs. (2025). Development Sector-Wise and State-Wise Corporate Social Responsibility Disclosures: Lok Sabha Unstarred Question No. 39 Annexure-II. Parliament of India. https://sansad.in/getFile/loksabhaquestions/annex/186/AU39_PgypUR.pdf?source=pqals
• Ministry of Corporate Affairs. (2026). National Corporate Social Responsibility Data Registry (FY 2023-24 Filings). Government of India National Data Portal. https://www.mcacdm.nic.in/csr-data.php
• Ministry of Corporate Affairs. (2026). Annual filings by companies on development CSR expenditure totals over 1,44,159 crores in last five FYs (2019-20 to 2023-24). Press Information Bureau (PIB), Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2226018&reg=3
• Ostrom, E. (2009). Beyond Markets and States: Polycentric Governance of Complex Economic Systems (Nobel Prize Lecture Essay). Royal Swedish Academy of Sciences. Open-access text available via the official Nobel Prize Archive Repository: https://www.nobelprize.org/uploads/2018/06/ostrom_lecture.pdf
• Sattva Consulting. (2025). India CSR Outlook Insights. Sattva Ecosystem Research Briefs. https://www.sattva.co.in/csr-outlook-2025/
• The Institute of Company Secretaries of India (ICSI). (2021). Company Law Corner Statutory Bulletin (Companies CSR Amendment Provisions). ICSI Enforcement Registry. https://www.icsi.edu/media/webmodules/FEBRUARY_COMPANY_LAW_CORNER.pdf

A Note on My Background

SK Saiful is based in Kolkata, India. He currently works at Fortify Health, a GiveWell-supported nonprofit incubated by Ambitious Impact (formerly Charity Entrepreneurship), focused on reducing iron-deficiency anaemia in India through wheat flour fortification as a cost-effective public nutrition intervention. Before that, he was a Research Associate at International Management Institute Kolkata. He was also part of the Don Lavoie Fellowship for AY 2023-24 at the Mercatus Center, grounded in Hayekian institutional analysis and Ostromian governance frameworks.

His research interests sit at the intersection of EA cause areas in global health and development, impactful philanthropy, and thinking through how to drive poverty alleviation through high-impact, evidence-driven interventions at scale.