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NBFC Compliance - NBFC Advisory

A Complete Checklist for NBFC Compliance

Running an NBFC gives you a huge opportunity in India’s growing financial landscape. But you already know this: with opportunity comes oversight. The Reserve Bank of India expects every NBFC to run tight systems, report accurate data and follow a clear set of rules known as NBFC Compliances. These rules begin the day you apply for your NBFC license, and they continue as long as your company operates.

Many NBFCs struggle not because they lack customers or funding, but because they slip on NBFC Compliances during the year. A late return. An incorrect report. A missing policy. A small KYC mistake. These things pile up fast. And if they become frequent, even your NBFC license can be questioned.

This expanded guide gives you a complete, easy-to-read breakdown of all NBFC Compliances you must follow in FY 2025–26. It includes tables, timelines, explanations, real examples and a clear compliance calendar.

Whether you are applying for an NBFC license or already running a growing NBFC, this is the roadmap you need.

Why NBFC Compliances Matter More Than Ever

NBFCs today handle digital lending, micro loans, consumer finance, MSME loans, gold loans, vehicle finance and more. With fast scale comes more responsibility. The RBI wants proof that your NBFC runs safely and plays by the rules.

Strong NBFC Compliances build trust with:

  • banks giving you credit lines,
  • rating agencies reviewing your company,
  • investors evaluating your business,
  • regulators checking your reports,
  • borrowers who trust your service,
  • and the public at large.

Weak NBFC Compliances do the opposite. They damage your brand, invite penalties and can put your NBFC license under risk.

This guide helps you build a compliance system that works daily, not just during deadlines.

Core Areas of NBFC Compliances

Here is a clearer, expanded breakdown of what NBFC Compliances cover.

NBFC License Requirements & Ongoing Obligations

Your NBFC license is your official approval from the RBI. Getting it is hard. Losing it is easy. To protect your NBFC license, you must maintain all rules that come with it.

NBFC License: Ongoing Requirements

Requirement What It Means Why It Matters
Net Owned Fund Maintain required capital Shows strength & solvency
Fit & Proper Criteria Clean record for directors Protects governance
Board Committees Audit, Risk, NRC Ensures oversight
Updated Policies KYC, AML, Credit, ALM, IT Supports NBFC Compliances
Clean Reports DNBS filings on time Supports NBFC license renewals

Your NBFC license is directly tied to these NBFC Compliances. If these slip, the license weakens.

KYC, AML and PMLA Compliance (Mandatory for All NBFCs)

The RBI wants NBFCs to know their customers, their transactions and their risk. This is central to NBFC Compliances.

Detailed KYC/AML Checklist

Area Requirement Notes
CKYCR Upload Within 10 days Mandatory
Customer Identification PAN, Aadhaar, OVDs For all new accounts
Enhanced Due Diligence For high-risk customers Politically exposed persons, etc.
CTR Monthly For cash-heavy sectors
STR Within 7 working days High RBI priority
Record Retention At least 5 years For audit and inspections

Any gaps in KYC and AML can lead to penalties and NBFC license restrictions.

Fair Practices Code (FPC)

Fair treatment of customers sits at the core of NBFC Compliances. It keeps lending ethical, lowers friction with borrowers, and strengthens your standing with the regulator.\

Snapshot of FPC Requirements

Area What You Must Do
Loan Disclosure Explain interest rates, all charges, and key terms before the borrower commits.
Sanction Letters Issue a sanction letter for every approved loan and keep the borrower’s acknowledgment on file.
Collection Rules Ensure collection practices stay respectful. No pressure tactics, threats, or harassment.
Complaint Handling Appoint a Grievance Redressal Officer, publish their contact details, and maintain proper complaint records.
Display of FPC Publish the Fair Practices Code on your website and display it at all customer-facing locations.

Customer protection is one of the strongest indicators the RBI uses to judge the long-term stability and governance quality of an NBFC.

Capital Adequacy, NPA Rules & Prudential Norms

This part of NBFC Compliances ensures your NBFC remains financially stable.

Prudential Norms Table (Detailed)

Norm Rule Why It Matters
CRAR 15% minimum Shows capital strength
NPA Classification >90 days overdue Industry standard
Provisioning Based on IRACP Protects financial health
Asset Quality No evergreening Shows true picture
Write-off Rules Follow correct process Maintains clean books

Your NBFC license depends on having strong capital and clean asset quality.

Governance & Board Responsibilities

The RBI expects NBFC boards to stay actively involved in compliance and oversight. Strong governance is a key marker of how responsibly an NBFC is being run.

Board-Level Compliance Checklist

Area Board Duty Frequency
Risk Review Review credit risk, market risk, and portfolio quality; track early-warning indicators. Quarterly
ALM Oversight Examine liquidity gaps, stress scenarios, and funding stability. Quarterly
Audit Review Look at internal audit findings, compliance gaps, and the status of corrective actions. Quarterly
Policy Approval Approve and update core policies: Credit Policy, IT & Cybersecurity Policy, KYC/AML Policy, Recovery Policy, Outsourcing Policy, Fair Practices Code, and others required by RBI. Annual
Fit & Proper Checks Ensure directors meet RBI’s Fit & Proper criteria and update declarations as required. Event-based

Boards that stay on top of these responsibilities avoid regulatory surprises and protect the NBFC’s license in the long run.

The Core Filing Work: DNBS Returns

DNBS returns are the most critical part of NBFC Compliances. They replaced the old NBS system. Every NBFC with an NBFC license must file these returns across monthly, quarterly, annual and event-based timelines.

Below is the full FY 2025–26 calendar.

NBFC Compliance Calendar FY 2025–26

Monthly Compliances

Return / Filing Due Date Applies To Notes
CIC Reporting 10th of every month All NBFCs Must match credit/loan book.
NESL Updates Within 7 days of the event All NBFCs Mandatory default and debt information.
CKYCR Upload Within 10 days All NBFCs RBI checks timeliness.
CTR Filing Monthly All NBFCs PMLA requirement.
DNBS-04B (Structural Liquidity & Interest Rate Sensitivity) Within 10 days NBFC-D, NBFC-ND-S Monthly liquidity position.
CERSAI Immediate All NBFCs Register creation/modification of security interest.

Quarterly Compliances

All DNBS quarterly returns → Due within 21 days from the end of each quarter.

Return Quarter-End Due Date Applies To Purpose
DNBS-01 30 Jun, 30 Sep, 31 Dec, 31 Mar Within 21 days All NBFCs Quarterly financial parameters.
DNBS-03 Same Within 21 days NBFC-D, NBFC-ND-SI ALM data.
DNBS-04A (STDL) Same Within 21 days NBFC-D, NBFC-ND-SI Short-term dynamic liquidity.
DNBS-07 Same Within 21 days ARCs Recovery and asset information.
DNBS-11 Same Within 21 days CIC-ND-SI Financial parameters.
DNBS-12 Same Within 21 days CIC-ND-SI Prudential parameters.
DNBS-13 Same Within 21 days NBFCs with foreign investments/assets Overseas investment details.
DNBS-14 Same Within 21 days NBFC-P2P Platform and exposure information.

CRILC Reporting (Updated)

Return Frequency Due Date Applies To Notes
DNBS-08 (CRILC – Main) Quarterly Within 21 days NBFCs with exposure ≥ ₹5 crore High-impact supervisory return.
DNBS-09 (CRILC – RDB) Weekly Immediate weekly cycle (RDB) NBFCs covered under CRILC Your Excel sheet shows this is a weekly return, not quarterly.

Annual Compliances

Annual Filing Deadline Applies To Notes
DNBS-02 30 May NBFC-ND Annual financial and prudential data.
DNBS-010 (SAC Return) 31 Oct All NBFCs Mandatory auditor certification.
Auditor Certificate Annual All NBFCs Required for RBI supervision.
Annual Policy Review Annual All NBFCs Update credit, risk, KYC, liquidity, and governance policies.

Event-Based Compliances

Event Filing Timeline Notes
SMA-2 Exposure DNBS-09 or CRILC reporting Immediate RBI treats this as high-priority.
Rejection of Deposit Application DNBS-05 Event-based Only for deposit-taking NBFCs.
Suspicious Activity STR Within 7 working days Mandatory under PMLA.
Shareholding Change > 26% RBI Intimation Immediate Part of licensing conditions.
Any Director Appointment/Resignation RBI Intimation Immediate Fit & Proper documentation required.
Change in Registered Office RBI Intimation Immediate Needs supporting documents.

These event-based NBFC Compliances are often missed, but they have the highest impact on your NBFC license.

How NBFC Compliances Protect Your NBFC License

Your NBFC Compliances do more than check boxes. They:

  • tell the RBI that your company is stable,
  • keep your customers safe,
  • protect lenders and partners,
  • maintain your credit score with banks,
  • and directly support your NBFC license status.

Many NBFCs lose their NBFC license because they:

  • filed DNBS returns late,
  • reported wrong CIC data,
  • failed KYC uploads,
  • ignored ALM gaps,
  • used unfair recovery methods,
  • or did not submit STRs and CTRs.

Strong NBFC Compliances mean smooth operations, better ratings and a safe NBFC license.

Quick Summary – NBFC Compliances Overview

Type Examples Effect on NBFC license
Monthly DNBS-04B, CIC, CTR Very High
Quarterly DNBS-01, DNBS-03, DNBS-08 High
Annual DNBS-02, DNBS-010 Very High
Event-Based STR, DNBS-09, RBI intimation Critical

Final Thoughts & Call to Action – NBFC Advisory

NBFC Compliances are not something you “do later.” They are part of everyday work. When your NBFC Compliances are on track, your NBFC license stays strong and your company grows without fear. But managing DNBS filings, KYC rules, risk reports and policy reviews can overwhelm your team.

This is where NBFC Advisory becomes essential.
They help you:

  • build a custom NBFC Compliances calendar,
  • manage monthly and quarterly DNBS returns,
  • prepare for RBI inspections,
  • review and update policies,
  • protect your NBFC license from risks.

A strong compliance base is not just paperwork
it’s your license to operate and your path to long-term success.

Let NBFC Advisory Strengthen Your Compliance Foundation

If you’ve made it this far, you already understand one thing: NBFC Compliances are not optional. They shape the way your NBFC operates, how fast you can grow, how safely you can lend, and how confidently you can face the RBI. A clean and organized compliance system is the only way to protect your NBFC license and build a long-term business.

But managing all of this alone isn’t easy. Monthly DNBS filings, quarterly CRILC reports, policy reviews, KYC updates, CERSAI entries, audit trails, board committees—these take time, focus and experience. Many NBFCs fall behind simply because their teams are already stretched with operations and customer service.

Know More: CERSAI KYC Process Guide: Importance, Steps, and Compliance

That’s where NBFC Advisory steps in.

We help you build a compliance system that works every single day, not just at deadlines. Our team supports you with:

NBFC Compliance - NBFC Advisory

Whether you’re a new NBFC aiming to grow fast or an established company preparing for the next inspection cycle, we can help you stay ahead of the rules—and stay ahead of the competition.

If you want fewer compliance headaches, fewer last-minute filings, and full confidence that your NBFC Compliances and NBFC license are protected, now is the right moment to bring in experts.

Reach out to NBFC Advisory today.

Let’s build a compliance system that keeps you safe, steady and ready for growth.

Contact our consultants today.
📞 Call NBFC Advisory: +91 93287 18979
🌐 Visit: www.nbfcadvisory.com

What happens if an NBFC misses a DNBS return deadline?

Missing DNBS return deadlines can trigger penalties, inspection notices, and classification as a non-compliant NBFC. Frequent delays may also put your NBFC license at risk.

Are KYC and CKYCR uploads mandatory for every NBFC?

Yes. Every NBFC must complete KYC checks and upload customer data to CKYCR within 10 days. Any delay or incorrect upload is treated as a regulatory lapse under PMLA.

Does every NBFC need to maintain a Fair Practices Code (FPC)?

Yes. Maintaining and displaying an FPC is compulsory. It ensures transparent lending practices and protects both the borrower and the NBFC from disputes.

What is the difference between monthly and quarterly NBFC Compliances?
  • Monthly compliances involve operational filings like CIC reporting, CKYCR uploads, CTR, and liquidity returns.
  • Quarterly compliances include DNBS returns (01, 03, 04A, 08, etc.) that reflect financial health, portfolio quality, and systemic risk.

Both are equally important for maintaining RBI trust and protecting your NBFC license.

When should an NBFC file STR (Suspicious Transaction Report)?

An STR must be filed within 7 working days of detecting a suspicious transaction. This is mandatory for every NBFC under PMLA, non-reporting can attract severe penalties.

Does every change in shareholding require RBI approval?

Yes, if the change exceeds 26%, prior RBI approval is required. Even smaller changes should be updated in your corporate records and internal compliance logs.

What are the most common compliance mistakes NBFCs make?
  • Late DNBS filings
  • Wrong CIC reporting
  • Missing KYC uploads
  • Poor ALM monitoring
  • Outdated policies
  • Weak audit trails
  • Improper recovery practices

These mistakes quickly escalate into major regulatory issues.

How can NBFC Advisory help my NBFC stay compliant?

NBFC Advisory helps you with end-to-end compliance setup including DNBS filings, KYC/AML frameworks, policy drafting, ALM monitoring, inspection preparation, and maintaining all event-based filings. This ensures you stay fully compliant and your NBFC license remains secure.