• Routine Compliance
• Event based compliances
• Opinions
• Retainerships
• NBFC Compliance Audit

What are the RBI compliance requirements for NBFCs?

An RBI-regulated NBFC is expected to hold a valid Certificate of Registration, maintain prescribed capital levels, and operate within the governance and prudential norms set for its regulatory layer. Key requirements include:

• Certificate of Registration (CoR) from the RBI under Section 45-IA of the RBI Act, 1934, before commencing NBFC business.
• Minimum Net Owned Funds (NOF) and a Capital to Risk-Weighted Assets Ratio (CRAR) of at least 15%, as applicable to the NBFC’s category.
• Classification into the Base, Middle, Upper or Top Layer under the RBI Regulatory framework, with compliance obligations that scale up accordingly.
• Board-approved policies covering the Fair Practices Code, KYC/AML, fit-and-proper criteria for directors, Interest rate, credit policy, and grievance redressal.
• Asset classification and provisioning in line with the RBI’s non-performing asset (NPA) recognition norms.
• Periodical return filing with the RBI and replying to the RBI mails and Inspection queries/observations.
• Additional governance requirements for larger NBFCs, including a Chief Risk Officer and enhanced disclosure standards for Upper Layer entities.

Because the RBI updates these norms periodically, including recent changes to the Upper Layer identification criteria and NPA recognition timelines, NBFCs benefit from a compliance advisor who tracks regulatory changes on an ongoing basis rather than reviewing requirements only once a year.

What compliances apply to NBFCs in India?

NBFC compliance is not limited to RBI filings alone. Depending on its structure, ownership and activities, an NBFC is typically subject to the following categories of compliance:

RBI Regulatory Compliances

Conditions attached to the Certificate of Registration, prudential norms, SBR-linked governance requirements, and directions issued through RBI master circulars and notifications

KYC, AML and Fair Practices Code

Customer due diligence and reporting obligations under the Prevention of Money Laundering Act (PMLA), along with a board-approved Fair Practices Code governing lending conduct and grievance redressal.

Companies Act and Secretarial Compliances

Statutory filings with the Registrar of Companies, maintenance of statutory registers and minutes, and board and shareholder meeting compliance under the Companies Act, 2013.

FEMA and Cross-Border Compliance

Where an NBFC has foreign shareholding, external commercial borrowings, or overseas transactions, compliance under the Foreign Exchange Management Act (FEMA) applies in addition to RBI’s NBFC-specific regulations.

How can an NBFC maintain regulatory compliance?

Consistent compliance is best achieved through a structured, ongoing process rather than a once-a-year exercise. NBFCs that manage compliance effectively typically:

• Maintain a compliance calendar that tracks RBI, ROC and other due dates across routine and event-based filings.
• Build board-level oversight, with periodic compliance updates placed before the Board or its committees.
• Review and refresh internal policies – Fair Practices Code, KYC, risk management – at least annually, or whenever the RBI issues updated directions.
• Conduct periodic internal or compliance audits to identify and close gaps proactively.
• updating Website with the relevant disclosure and by uploading the mandatory policies on the website of the Company.
• Engage an experienced compliance advisor or retainer to interpret new RBI circulars and translate them into internal action points.

This combination of internal discipline and external advisory support is what allows an NBFC to stay audit-ready at all times, rather than struggling ahead of an inspection or renewal.

What are the reporting requirements for NBFCs?

NBFCs are required to file a range of periodic returns with the RBI, most of which are submitted electronically in XBRL format through the RBI’s CIMS portal. Common reporting requirements include:

• Periodic statutory returns such as DNBS-1, DNBS-2, DNBS-3, CRILC, DNBS09, and DNBS13- depending on the NBFC’s category and asset size.
• Statutory Auditors’ Certificate (SAC), filed annually to confirm continued eligibility to carry on NBFC business.
• Asset Liability Management (ALM) returns (DNBS04A, DNBS04B) for NBFCs meeting the applicable asset thresholds.
• Capital adequacy, NPA returns, filed at prescribed interval
• Additional disclosures for Upper Layer NBFCs, including risk-based capital adequacy
• Fraud reporting to the RBI as and when occurred
• Reporting to the CICs for consumer and commercial data.

Missing a reporting deadline – even inadvertently – can invite regulatory queries or penalties, which is why most NBFCs prefer to have their return calendar managed by a team that tracks both the deadlines and the underlying regulatory changes.