RBI Compliances of NBFC in India

NBFCs are required to submit various returns to RBI in relation to their deposit acceptance, prudential norms compliance, Asset Liability Management (ALM) etc. Detailed instructions regarding submission of returns by NBFCs have been issued through various circulars and guidelines. A list of such returns to be submitted by NBFCs-D, NBFCs-ND-SI and others is as under.

Types of NBFCs on the basis of activities and liabilities

Typically, there are three types of NBFCs based on the kind of activities and liabilities they carry on. They are as follows:
  • NBFCs accepting deposits (NBFCs-D);
  • Non-deposit taking NBFCs (NBFC-ND);
  • NBFC-ND-Systematically Important (NBFC-ND-SI).

NBFC Compliance Checklist for Non-Deposit & Deposit-taking company


S.  NoParticularsTime Limit
 Annual Compliances  
1.Unaudited March Monthly return/NBS-7On or before 30th June
2.Statutory Auditors certificate on Income & AssetsOn or before 30th June
3.Information about Companies having FDI/Foreign FundsOn or before 30th June
4.Audited March Monthly return/NBS-7Upon completion
5.File audited annual balance sheet and P&L AccountOne month from the date of signoff
6.Resolution of Non-Acceptance of Public DepositBefore the commencement of the new Financial year
7.Declaration of Auditors to Act as Auditors of the CompanyAnnual basis
 Monthly Compliance 
8.Monthly returnBy 7th of every month
 Periodical Compliances 
9.Appointment of DirectorWithin 30 days of appointment
10.Resignation of Director (DIR-12 + Challan report)Within 30 days of appointment
11.Adoption of any notification in the ensuing Board Meeting and filing the certified copy with RBI

Returns and Compliances of NBFCs registered with RBI

With reference to Master Direction – NBFC-NDs-SI and NBFC-SI deposit-taking company must file the following returns as described below:

1. Deposit-taking NBFCs are required to submit the following returns:

  • NBS-1: Every NBFC that accepts or holds public deposits should submit NBS-1 return on a quarterly basis. The purpose of filing this return is to capture financial details such as Profit and Loss account, Components of Assets and Liabilities, Exposure to sensitive sectors, etc.
  • NBS-2: NBFC which accepts public deposits are required to submit a quarterly return on Prudential Norms. The intent behind filing this return is to capture compliances related to several prudential norms such as Asset Classification, Capital Adequacy, Net Owned Funds (NOF), Provisioning, etc.
  • NBS-3: Again, it’s a quarterly return that every deposit-taking NBFC needs to file. Besides, the objective behind introducing this return is to capture information about Statutory Investments in the Liquid States. Moreover, the statutory investments include Fixed Deposits in Schedules Commercial Bank, Central or State Government Securities, etc.
  • NBS-4: It’s a kind of Annual return of critical parameters. The return must be filed by a rejected company holding public deposits. Earlier, NBS-5 was filed. However, now NBS-5 stands withdrawn as NBS-1 is filed quarterly. The objective of filing NBS-4 is to find the repayment status of the rejected NBFCs accepting public deposits.
  • NBS-6: It’s a monthly return on exposure to capital market by NBFC taking deposits with total assets equal to or more than Rs. 100 crores.
  • Half-yearly ALM returns by NBFC accepting public deposits of more than Rs. 20 crores or asset size of above Rs.100 crores.
  • Audited Balance sheet and Auditor’s Report by Non-Banking Financial Companies accepting public deposits.
  • Branch Information Return : It’s a quarterly return that every NBFC which accepts or holds public deposits needs to submit.

2. NBFCs-ND-SI is required to submit the following returns:

  • NBS-7: It’s a quarterly statement of capital funds, risk asset ratio, risk-weighted assets, etc., for NBFC-ND-SI. 
  • Monthly returns on Necessary Financial Parameters of NBFCs-ND-SI must be submitted on a monthly basis.
  • ALM returns: ALM (Asset-Liability Management) Returns refer to multiple returns that are supposed to be submitted by NBFCs-ND-SI at several intervals as described below:
    • Statement of short term dynamic liquidity ALM [NBS-ALM1] -Quarterly;
    • Structural liquidity in format ALM [NBS-ALM2] statement – Half Yearly;
    • Interest Rate Sensitivity in format ALM – [NBS-ALM3] statement- Half Yearly;
    • Assets Liability Mismatch [ALM-YRLY] statement – Annually.
    • Branch Information Return: Every NBFCs-ND-SI must submit the branch information return on a quarterly basis.

3. Quarterly return on important financial parameters of non-deposit taking NBFCs holding assets of above Rs. 50 crores and higher but below Rs. 100 crores.

Non-deposit taking NBFCs with asset size between Rs. 50 crores and Rs. 100 crores are required to submit the basic details such as the name of the company, address, NOF, and profit/loss during the last three years quarterly.
This blog is authored by Company Secretary Ronak Gupta. He is author of many blogs and runs many websites and youtube channels. His work is dedicated to corporate laws, legal, secretarial, professional services and also in strategy formulations for corporates. Mail him at: csronakgupta23@gmail.com or call at :9910226715

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