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NBFC Compliance - NBFC Advisory

Running an NBFC? Here’s Your Complete Guide to Annual RBI Compliances

If you’re running an NBFC license, you already know how much the stability of your business depends on NBFC compliance. It isn’t something you deal with at the end of a quarter. It isn’t something you delegate without oversight. It’s the backbone of your nbfc licence and, in many ways, the strongest indicator of your organisation’s integrity.

The RBI isn’t trying to slow you down with rules. The goal is simple: the RBI wants every NBFC license to work in a clean, honest, and disciplined way so customers stay safe and the financial system stays strong. But in practice, the filings, returns, disclosures, and policy updates pile up across the year and if you don’t have a system in place, it becomes easy to slip.

This guide helps you stay ahead. It lays out the annual NBFC compliances every NBFC must follow and gives you a clear compliance calendar you can actually use. Whether your NBFC is small, growing, or well established, this structure helps you stay compliant without the year-end rush.

Why Annual NBFC Compliances Matter

A compliant NBFC is a trusted NBFC. Simple as that.

The RBI looks at your filings not as paperwork but as signs of whether your organisation is being run responsibly. When your reports are correct, your numbers match, and your policies are updated, the RBI can see that you run your NBFC with proper control.

Strong NBFC compliance helps you:

  • Build better relationships with lenders and investors
  • Stay off the regulator’s radar
  • Avoid penalties and warnings
  • Make audits smoother and faster
  • Strengthen your corporate governance
  • Protect your licence

On the other hand, missed filings, even unintentionally, raise questions. And once the RBI starts questioning your compliance culture, it takes time and effort to regain that confidence. A registered company that mishandles NBFC Compliances risks delays, scrutiny, and potential impact on its NBFC license.

A Closer Look at the RBI’s Key Annual Compliances

DNBS Returns

These filings help the RBI check your cash position, loan quality, risks, provisions, and how stable your NBFC is. Depending on your classification, these may be monthly, quarterly, or annual.

CRILC Reporting

If your exposure crosses the RBI threshold, you must submit CRILC data. These reports help the regulator track early warning signs of borrower stress.

CIC (Credit Bureau) Reporting

Accurate monthly reporting to credit bureaus is essential. Delays or errors don’t just impact you—they affect your customers’ credit history and raise questions about your internal systems.

AGM-Linked Filings

Once your AGM is complete, filings like AOC-4 NBFC, MGT-7, MGT-15, and ADT-1 help you stay compliant under the Companies Act.

Annual Policy Reviews

Your Board must review and approve key policies every year, including:

  • KYC
  • AML
  • Fair Practices Code
  • Outsourcing
  • IT and Cybersecurity
  • Recovery
  • Risk Management

Outdated or poorly drafted policies are one of the most common red flags during inspections and weaken NBFC Compliances, risking questions around the NBFC license.

Event-Based Compliances

These may occur any time during the year and must be filed promptly:

  • Change in directors
  • Change in shareholding or control
  • Appointment or resignation of auditor
  • Charge creation or satisfaction
  • Filing STR/CTR to FIU-IND
  • Appointment of KMP
  • Change in registered office

A registered company often misses these because they don’t treat them with urgency, but they are vital for maintaining NBFC Compliances and retaining an NBFC license.

Common Mistakes NBFCs Make

Here’s what we see often in the industry:

  • Policies not reviewed or approved annually
  • DNBS returns containing numbers that don’t match the audited financials
  • Registers and board minutes not updated throughout the year
  • Event-based filings delayed or ignored
  • Inconsistent CIC data
  • Rushed filings leading to mistakes

These mistakes don’t happen because NBFCs don’t care. They happen because there’s no structured NBFC Compliances system in place inside the registered company, which can jeopardize the NBFC license.

Additional Insight: What a Healthy NBFC Compliance System Looks Like

Since we’re not listing the full calendar, here’s something more useful—what a strong internal compliance system actually looks like:

NBFC Compliance - NBFC Advisory

A Single Source of Truth

Your financials, DNBS returns, internal MIS, and audit trails should tell one consistent story. When numbers don’t align, regulators notice immediately.

Policy Ownership

Every major policy should have a clear owner inside the organisation—not just an outsourced consultant. Reviews should be logged, tracked, and approved by the Board on time.

Real-Time Event Monitoring

Director changes, share reorganisations, loan limit breaches, and charge creations should trigger instant compliance action. Waiting for month-end is a guaranteed way to miss something.

Audit-Ready Documentation

Auditors and RBI officers expect you to produce minutes, registers, board approvals, exposure details, and related documents at short notice. When everything is stored properly, inspections become routine instead of stressful.

Monthly Internal Reconciliation

Reconciling credit bureau data, provisioning, exposure, and capital adequacy every month helps avoid last-minute panic when filings are due.

Final Word

If you’re running an NBFC, your compliance rhythm defines your organisation’s reputation. A clean record doesn’t only cut penalties. It builds trust with lenders, improves how your NBFC is run, and makes growth much easier. Strong NBFC Compliances protect your NBFC license and keep your systems audit-ready.

Stay organised. Stay consistent. Stay compliant.
A well-managed NBFC doesn’t fear inspections; it’s ready for them.

Need Expert Help with NBFCs?

You don’t have to manage compliances alone. If you want your NBFC to remain audit-ready, regulator-ready, and free from last-minute stress, while protecting your NBFC license, we can help.

  • Full annual compliance management
  • DNBS return filings
  • Policy drafting and yearly updates
  • Preparation for RBI inspections
  • AGM filings and corporate compliance
  • Complete compliance calendar setup

Our team handles the complexity so you can focus on running your business.

📞 Call NBFC Advisory:+91 93287 18979
🌐 Visit: nbfcadvisory.com

If you want a customised compliance calendar or full end-to-end NBFC compliance support, reach out today. Your compliance foundation deserves expert hands.

Frequently Asked Questions (FAQs)

What is the most important annual compliance for an NBFC?
There isn’t just one RBI focuses on complete compliance. But DNBS returns, CRILC reporting (if applicable), CIC reporting, statutory audit completion, and annual policy reviews are always top priority. Missing any of these can raise red flags with the regulator.

What happens if an NBFC misses an RBI filing deadline?
Missed filings can lead to penalties, notices, closer scrutiny, and in serious cases, restrictions on operations. Frequent delays also weaken the organisation’s compliance credibility.

How often should NBFC policies be updated?
Every key policy KYC, AML, FPC, Recovery, Outsourcing, IT, Cybersecurity, Risk Management must be reviewed and approved by the Board at least once every financial year.

What is the difference between DNBS-01, DNBS-02, and DNBS-04B?

  • DNBS-01/02: Quarterly returns covering financials, assets, liabilities, and exposure.
  • DNBS-04A: Annual return for important prudential norms.
  • DNBS-04B: Monthly return for deposit-taking and non-deposit NBFCs (depending on class).

Each helps RBI monitor financial health and governance.

Do all NBFCs need to file CRILC returns?

No. Only NBFCs with borrower exposure above the RBI-specified threshold must submit CRILC data. If you cross the limit even once, reporting becomes mandatory.

What are the most commonly missed NBFC compliances?
Event-based filings (director changes, charge creation, auditor changes), CIC reporting mismatches, board minutes not updated, and delayed DNBS filings are the most frequent lapses.

Is AGM filing mandatory for every NBFC?
Yes. AOC-4 NBFC, MGT-7, MGT-15 (if applicable), and ADT-1 must be filed after the AGM to meet Companies Act requirements. Missing these affects both corporate and RBI compliance standards.

Can NBFC compliance be fully outsourced?
Yes many NBFCs outsource compliance to specialised teams to avoid errors, reduce workload, and maintain year-round consistency. However, the Board must still review and approve all key policies and reports.