The chapter examines the social and cultural factors influencing CSR in India, the key drivers shaping the legislation mandating CSR in India, and the impact of this legislation on corporate social performance. It underscores the influence of culture, values, religion, traditions, and the role of ‘Dharma’ for CSR in India. It sheds light on the dynamics of CSR over time by examining how its nature evolved from the Ghandian trusteeship model into a more strategic version of CSR in the face of increasing FDI and growth of MNCs in India. The chapter suggests that such a shift in CSR has impacted the social contributions of firms necessitating formal legislation of CSR in India. Furthermore, it highlights that the lack of a binding code at the global level along with the voluntariness of CSR has compelled the Indian government to reshape CSR to prioritise local needs. It examines the impact of this mandatory CSR legislation on CSR activities along with its limitations. The chapter concludes by discussing the role of legal transplant theory, inventive interventionism and reflexive law for the development of a global CSR policy framework.

Indonesia is the fourth most populous country in the world and a growing economic powerhouse. Although founded in 1949, it has a significant legal history and distinct legal systems based on race. In this historical context, Indonesia has seen economic boom, bust and reform as well as a more recent change from dictatorship to democracy. This chapter reviews the rich and complex history that sets the foundation for the subsequent analysis of the post-Suharto regulatory efforts to address sustainability. The chapter includes three substantial case studies examining how the central government’s mandatory sustainability for State Owned Enterprises has fared.