Running an NBFC is not just about lending — it’s about running a tightly regulated financial institution under the continuous oversight of the Reserve Bank of India. From monthly and quarterly returns to annual audits, board governance, and Scale-Based Regulatory (SBR) compliance, the compliance calendar of an NBFC is unusually demanding, and any slip can attract penalties, supervisory action, or even cancellation of the Certificate of Registration.
In recent years, RBI has significantly raised the bar through the Scale-Based Regulatory (SBR) Framework, revised NPA norms, digital lending guidelines, KYC/AML tightening, and enhanced fair practices code obligations. NBFC boards and CFOs are expected to demonstrate not just compliance, but mature governance, data integrity, and real-time monitoring.
We offer end-to-end NBFC annual compliance services — covering Companies Act filings, RBI returns, NPA classification, corporate governance, statutory audit support, transfer pricing, GST, and ongoing advisory — so your NBFC stays compliant, audit-ready, and fully aligned with RBI expectations through the year.
RBI
Registered & supervised
SBR
Scale-Based Framework (2022)
CRAR
Capital adequacy monitoring
100%
Calendar-driven compliance
Regulations & Frameworks We Comply With
RBI Act, 1934
RBI Master Directions
SBR Framework
Companies Act, 2013
Fair Practices Code
KYC & PMLA
Digital Lending Guidelines
Income Tax & GST
FAQs on NBFC Annual Compliance
What are the key annual compliances for an NBFC?
Key annual compliances include statutory audit, MCA filings (AOC-4, MGT-7, DIR-3 KYC), income tax return, tax audit, transfer pricing (Form 3CEB), RBI returns (NBS-1, NBS-2, NBS-7, ALM, CRILC), FLA return for FDI-funded NBFCs, refresh of credit / risk / FPC / IT policies, and SBR-specific governance obligations.
What is the Scale-Based Regulatory (SBR) Framework?
The SBR Framework, effective from October 2022, classifies NBFCs into four layers — Base, Middle, Upper, and Top — based on size, activity, and systemic risk. Regulatory expectations — including CRAR, governance, ring-fencing, and disclosures — increase as you move up the layers. Our compliance approach is always calibrated to your applicable SBR layer.
Which RBI returns does an NBFC need to file?
Core returns include NBS-1, NBS-2, NBS-3 (for deposit-taking NBFCs), NBS-7, NBS-8/NBS-9, ALM Returns, CRILC, and annual FLA for companies with foreign investment. Additional returns apply to specialized NBFCs such as MFIs, HFCs, P2P, and Account Aggregators, as well as to entities involved in FDI/FPI transactions.
Is statutory audit mandatory for every NBFC?
Yes. Every NBFC, irrespective of turnover, is required to have its accounts audited annually by qualified statutory auditors. In addition, NBFCs must comply with specific RBI directions on rotation, joint audits (where applicable for larger NBFCs), and detailed disclosures in the auditors’ report and notes to accounts.
What is CRAR and why is it important?
CRAR (Capital to Risk-weighted Assets Ratio) measures the capital adequacy of an NBFC against its credit risk exposure. NBFCs must maintain a minimum CRAR as prescribed by RBI (typically 15% for most categories). Falling below the threshold can trigger supervisory action, restrictions on new business, and even revocation of CoR.
What are the consequences of non-compliance?
Non-compliance can lead to monetary penalties, restrictions on business, compounding proceedings under FEMA or RBI Act, adverse remarks in inspection reports, downgrades by rating agencies, difficulty in raising funds, and in serious cases, cancellation of the Certificate of Registration by RBI.
Do NBFCs need transfer pricing compliance?
Yes. NBFCs with international or specified domestic transactions with associated enterprises must comply with transfer pricing regulations under the Income Tax Act, including maintenance of TP documentation and filing of Form 3CEB certified by an accountant, within the prescribed due date each year.
How are digital lending NBFCs different in compliance?
NBFCs engaged in digital lending — directly or through Lending Service Providers (LSPs) — must additionally comply with RBI’s Digital Lending Guidelines. These cover Key Fact Statements, customer disclosures, grievance redressal, data usage, outsourcing norms, and responsibility for acts of LSPs, along with periodic LSP-specific reporting and audits.