NBFC Annual Compliance Services

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NBFC Annual Compliance Services

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

Our NBFC Annual Compliance Services

01

RBI Returns & Filings

Preparation and filing of NBS-1, NBS-2, NBS-7, ALM, CRILC, and other periodic RBI returns.

02

MCA / ROC Compliance

AOC-4, MGT-7, DIR-3 KYC, INC-20A, board and AGM compliance under the Companies Act.

03

Statutory Audit Support

Year-end closure, NBFC-specific disclosures, provisioning, and auditor coordination.

04

NPA & Provisioning

Asset classification, income recognition, and provisioning as per RBI norms and Ind AS.

05

Corporate Governance

Board composition, committees, risk framework, and SBR-layer governance requirements.

06

KYC / AML / PMLA

Customer due diligence, PMLA reporting, STR/CTR filings to FIU-IND, and KYC policies.

07

Tax, TDS & GST

Income tax return, advance tax, TDS returns, GST returns, and transfer pricing compliance.

08

Policy & Framework Refresh

Annual refresh of credit policy, FPC, risk, IT, outsourcing, and digital lending policies.

Key RBI Returns for NBFCs

Return Purpose Frequency
NBS-1 Quarterly return on assets, liabilities, income and expenses Quarterly
NBS-2 Prudential norms, CRAR, NPA classification & provisioning Quarterly
NBS-3 Statutory liquid assets held by NBFCs-D Quarterly
NBS-7 Structural profile, capital adequacy and asset quality Quarterly
NBS-8 / NBS-9 Annual return for NBFCs based on asset size Annually
ALM Returns Asset Liability Management and liquidity risk monitoring Monthly / Quarterly
CRILC Large exposure reporting to the Central Repository Quarterly
FC-GPR / FC-TRS FDI / transfer of shares involving foreign investors Event-based
Annual FLA Foreign Liabilities and Assets Return to RBI Annually

NBFC Annual Compliance Calendar (Key Filings)

Monthly

ALM Returns & GST

Monthly ALM reporting (where applicable) and GST returns (GSTR-1 & GSTR-3B).

Quarterly

NBS Returns & CRILC

NBS-1, NBS-2, NBS-7, ALM, and CRILC returns to RBI post each quarter-end.

Quarterly

Board Meetings

Minimum 4 board meetings a year with review of portfolio, risk, and compliance status.

30 April

TDS Q4 Deposit

Deposit of Q4 TDS and payment of closure-related statutory dues.

31 May

TDS Q4 Return

Filing of Q4 TDS return (24Q, 26Q) for the previous financial year.

30 Jun

NBS-7 & Year-End

Year-end NBS-7 and NBS-9 submissions post audited financials, where applicable.

15 Jul

Annual FLA

FLA return to RBI on foreign liabilities and assets for companies with FDI.

30 Sep

AGM & DIR-3 KYC

Annual General Meeting within 6 months of FY end and DIR-3 KYC for directors.

30 Oct

Form AOC-4

Filing of financial statements with the Registrar of Companies.

31 Oct

Tax Audit & 3CEB

Filing of tax audit and Form 3CEB (transfer pricing) where applicable.

29 Nov

Form MGT-7

Annual return filing with ROC, including shareholding and governance details.

31 Dec

ITR Filing

Income tax return filing (extended date) for companies subject to audit.

Compliance Under RBI’s SBR Framework

NBFC-BL

Base Layer

Non-deposit taking NBFCs with asset size below ₹1,000 crore; moderate compliance expectations.

NBFC-ML

Middle Layer

NBFCs with asset size ₹1,000 crore and above, deposit-taking NBFCs, and specified categories.

NBFC-UL

Upper Layer

Top NBFCs identified by RBI based on scoring methodology; face bank-like enhanced regulation.

NBFC-TL

Top Layer

Currently empty, but may be populated by RBI if systemic risks significantly increase.

Our Compliance Approach

1

Onboarding

Review CoR, MOA, past filings, policies, and previous inspection or scrutiny reports.

2

Calendar

Build a customized compliance calendar mapped to your SBR layer and activities.

3

Execution

Prepare and file monthly, quarterly, and annual RBI, ROC, tax, and GST returns.

4

Governance

Support board meetings, minutes, committees, and policy refresh cycles.

5

Monitoring

Dashboard-based tracking of compliance status, red flags, and upcoming due dates.

Why Partner with Us for NBFC Compliance

Avoid RBI penalties & supervisory actions
Stay fully aligned with SBR framework
Reduce risk of qualified audit reports
Build investor, lender & board confidence
Ready for RBI inspections at all times
Accurate NPA classification and provisioning
Smooth statutory audit and rating exercises
Predictable compliance cost and timelines

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.

Run a Clean, Audit-Ready, Fully Compliant NBFC

Partner with our specialists for end-to-end NBFC annual compliance — RBI returns, MCA filings, audit support, SBR governance, and policy refresh, all under one roof.

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