NBFC COMPLIANCE CHECKLIST – RBI
A Non-Banking Financial Company (NBFC) is a financial institution regulated by the RBI and registered under the Companies Act, 2013. NBFCs without holding a banking licence, can undertake investment, lending, hire-purchase, or other financial activities.
As NBFCs are part of financial systems, they must adhere to strict RBI compliance to safeguard financial stability, protection of customer, and system safety.
RBI compliance are necessary to keeps your NBFC licensed and operational.
Key compliances
Initial requirement:
REGISTRATION: A Certificate of Registration (CoR) u/s 45-IA of THE RBI ACT, 1934 must be obtained from RBI by every NBFC with a NET OWNED FUND (NOF) of minimum INR 10 crore.
(the minimum NOF criteria applies to new entrants from the very beginning).
Governance & Risk Management:
- Minimum CRAR must be maintained by NBFCs .
- Board composition, independent directors, audit committees, risk committees are in place.
- Internal Controls like Risk policies, internal audit functions, compliance documentation are in place.
KYC, AML & Customer Protection:
- Know Your Customer (KYC) norms and anti-money laundering (AML) requirements under the PMLA must be complied.
- Suspicious Transaction Reports (STRs) must be reported.
- Digital/e-KYC procedures acceptable under RBI guidance.
- Transparent pricing, loan processing, grievance redressal these fair practice codes are strictly followed.
Operational & IT Compliance:
- Cybersecurity frameworks.
- Data protection and IT risk policies were made as per Personal Data Protection laws.
- IT audits must be conducted and regular assessments of tech risks.
RBI Compliance for NBFCs
Annual compliances
| FORM | PARTICULARS | DUE DATE | REGULATING DOCUMENT |
| DNBS10 | All NBFCs and ARCs are required to file Statutory Auditors Certificate (SAC) for continued regulatory compliances | 31st Dec | Master Direction-RBI(filing of supervisory returns) direction 2024. |
| DNBS02 | NBFC–BL are required to file Prudential Norms and financial details like components of asset and liabilities | 21stApril 21s July 21st oct 21st jan | Master Direction-RBI(filing of supervisory returns) direction 2024. |
| Declaration | NBFC-ICC gives Declaration of Board Resolution for not accepting or holding any Public Deposits. | 30th April | Master Direction- NBFC Acceptance Of Public Deposit Direction ,2016 |
| Form A Certificate | All NBFCs has to file regarding appointment of statutory central auditor (SCA) / statutory auditor (SA). | 21st April | Master Direction- RBI (filing of supervisory returns) direction 2024. |
| ANNEX-VII | NBFCs,CI,CIC,ARC ,Banks are required to file the provisions of Credit Information Reporting Mechanism subsequent to cancellation of licence or certificate of registration. | 10TH April | Master Direction- RBI (Credit Information Reporting) Direction 2025 |
HALF YEARLY COMPLIANCES
| FORM | PARTICULARS | DUE DATE | REGULATING DOCUMENT |
| Statement Of Interest Rate Future (IRF)Transactions | NBFCs participating in interest rate future exchange for hedging their underlying exposure has to file IRF Transactions . | 30th April 31st Oct | Master Direction-Scale based regulation |
| CIC Half-Yearly CI compliance report | NBFCs,CI,CIC,ARC ,Banks are required to file this report which contains the list of credit institutions not adhering to fortnightly data submission timelines | 31 March 30 Sept | Master Direction- RBI (Credit Information Reporting) Direction 2025 |
| CIC Half-Yearly Non complaint report | NBFCs,CI,CIC,ARC ,Banks are required to file this report which furnish list of Credit Institutions (CI) who do not respond in timely manner | 31 March 30 Sept | Master Direction- RBI (Credit Information Reporting) Direction 2025 |
| Credit Institution (CI) level Data Quality Index (DQI) and Industry Level DQI | NBFCs,CI,CIC,ARC ,Banks have to submit monthly data on Credit Institution (CI) level Data Quality Index (DQI) and Industry Level DQI | 31 March 30 Sept | Master Direction- RBI (Credit Information Reporting) Direction 2025 |
Quarterly Compliances
| FORM | PARTICULARS | DUE DATE | REGULATING DOCUMENT |
| Annex X | NBFCs having asset size of 100 crore or more have to report on securities pledged by the borrowers for availing loans | 30 June 30 Sept 31 Dec 31 Mar | Master Direction-Scale based regulation |
| DNBS01 | NBFC –UL, NBFC-ML except NBFC-CIC have to file their financial details namely components of asset and liabilities, P&L , exposure to sensitive sectors | 21stApril 21stJuly 21stOct 21stJan | Master Direction- RBI(filing of supervisory returns)direction 2024. |
| DNBS03 | NBFC –UL, NBFC-ML except NBFC-CIC have to file Prudential Norms containing capital adequacy, provisioning etc. | 21stApril 21stJuly 21stOct 21stJan | Master Direction- RBI(filing of supervisory returns) direction 2024. |
| DNBS04A | NBFC –UL, NBFC-ML(EXCEPT SPD) , NBFC-BL with asset size of 100 crore or more excluding type I NBFC and NOFHC, P2P , AA and Mortgage Guarantee Companies have to file statement on Short Term Dynamic Liquidity( STDL) contains data on Asset Liability Mismatches (ALM) and Interest Rate Sensitivity (IRS), liquidity rate of exposure . | 21stApril 21stJuly 21stOct 21stJan | Master Direction- RBI(filing of supervisory returns) direction 2024. |
| DNBS07 | ARCs filed financial parameters which contain data on assets and liabilities ,acquisition cost, asset acquired from bank/FI , recovery status etc. | 21stApril 21stJuly 21stOct 21stJan | Master Direction- RBI(filing of supervisory returns) direction 2024. |
| DNBS13 | NBFCs are required to file Return On Overseas Investment | 21stApril 21stJuly 21stOct 21stJan | Master Direction- RBI(filing of supervisory returns) direction 2024. |
| FMR IV | All NBFCs have to submit the updated information report on robbery/ decoities /theft using online portal | 15 April 15 July 15 Oct 15 Jan | RBI(Fraud Risk Management in NBFC) Direction 2024 . |
| DNBS02 | NBFC–BL except NBFC – P2P are required to file important financial parameters | 21stApril 21stJuly 21stOct 21stJan | Master Direction- RBI(filing of supervisory returns) direction 2024. |
| Appendix VI-A | All NBFCs are required to give the public disclosure on liquidity risk management framework and liquidity position. | 30 June 30 Sept 31 Dec 31 Mar | Master Direction-Scale based regulation |
| DNBS 11 | NBFC-CIC have to file important financial parameters | 21stApril 21stJuly 21stOct 21stJan | Master Direction- RBI(filing of supervisory returns) direction 2024. |
| DNBS 12 | NBFC-CIC have to file important prudential parameters | 21stApril 21stJuly 21stOct 21stJan | Master Direction- RBI(filing of supervisory returns) direction 2024. |
| DNBS 14 | NBFC-P2P are required to file important financial and prudential parameters | 21stApril 21stJuly 21stOct 21stJan | Master Direction- RBI(filing of supervisory returns) direction 2024. |
Monthly Compliances
| FORM | PARTICULARS | DUE DATE | REGULATING DOCUMENT |
| Annex XXV | NBFC-UL are required to give reporting of large exposure | By end of each month | Master Direction-Scale based regulation |
| Annex XIX | All NBFC files information of borrowers whose secured assets is possessed . | By end of each month | Master Direction-Scale based regulation |
| DNBS04B | NBFC –UL, NBFC-ML(EXCEPT SPD) , NBFC-BL with asset size of 100 crore or more excluding type I NBFC and NOFHC, P2P , AA and Mortgage Guarantee Companies have to submit return on structural liquidity and interest rate sensitivity . | Within 15 days from end of each month | Master Direction- RBI(filing of supervisory returns) direction 2024. |
| DNBS08 | NBFC-UL are required to file CRILC main return | Within 15 days from end of each month | Master Direction- RBI(filing of supervisory returns) direction 2024. |
Weekly Compliances
| FORM | PARTICULARS | DUE DATE | REGULATING DOCUMENT |
| DNBS09-CRILC RBD | NBFCs having aggregate exposure of 5 crore or above to a single borrower reported in SMA-0 for the week | On or before Wednesday of the following week | Master Direction- RBI(filing of supervisory returns) direction 2024 |
| Annex IV | NBFCs are required to file uniform credit reporting format | Within 7 calendar days of relevant fortnight | Master Direction- RBI (Credit Information Reporting) Direction 2025 |
Event based compliances
| FORM | PARTICULARS | DUE DATE | REGULATING DOCUMENT |
| Annex II | NBFCs which has granted credit facility to borrowers have to report name of directors classified as wilful defaulters | In case of wilful default | Master Direction on treatment of wilful defaulters and large defaulters, 2025 |
| Fraud Monitoring Return | NBFCs have to report incidents of fraud in individual fraud cases . | Not later than 14 days from the classification of incident of fraud | RBI(Fraud Risk Management in NBFC) Direction 2024 |
| FMR IV | NBFC have to report instances of theft, dacoity and robbery including attempted case . | Not later than 7 days from their occurrence | RBI(Fraud Risk Management in NBFC) Direction 2024 |
| Fortnightly credit info update policy | NBFCs have to update and keep the credit information collected/maintained | As on 15th and last day of respective month | Master Direction- RBI (Credit Information Reporting) Direction 2025 |
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