NBFC Annual Compliance — RBI Regulatory Filing and Compliance Calendar

Q: What are the key RBI returns an NBFC must file annually?

Key returns include NBS-1 (quarterly for deposit NBFCs), NBS-2 (annual investments), NBS-7 (quarterly CRAR), ALM returns, and audited balance sheet submission within one month of AGM.

Q: What is the minimum CRAR requirement for NBFCs?

Minimum CRAR is 15% for NBFC-ND-SI and NBFC-D, with at least 10% in Tier-1 capital. CRAR must be maintained continuously and reported quarterly.

Q: What are the NPA classification norms for NBFCs?

From October 2022, loans overdue more than 90 days are classified as NPA. Sub-standard: NPA up to 12 months. Doubtful: sub-standard over 12 months. Loss: irrecoverable.

Q: What is the Fair Practices Code (FPC) for NBFCs?

The RBI mandates a Board-approved FPC covering loan transparency, non-coercive recovery, customer grievance redressal, and prohibition of discrimination. It must be displayed in offices and on the website.

Q: What are the penalties for non-filing of RBI returns?

Up to ₹5 lakh for initial default and ₹25,000 per day for continuing default under Section 58G. Persistent non-compliance can trigger CoR cancellation proceedings.

Comprehensive NBFC annual compliance management — covering all RBI periodic returns, statutory filings, capital adequacy reporting, Fair Practices Code compliance, and audit coordination to keep your NBFC fully compliant throughout the year.

RBI Periodic Returns

Filing of all mandatory RBI returns — NBS-1, NBS-2, NBS-7, ALM returns, branch information returns — on the XBRL/COSMOS portal within prescribed deadlines, with penalty avoidance.

Statutory Audit Coordination

Coordination of the annual statutory audit, preparation of audit-ready accounts, and management of the auditor's certificate requirements for RBI submission — including the NOF certificate and asset classification compliance report.

Capital Adequacy & Asset Quality

Quarterly computation and monitoring of Capital to Risk-Weighted Assets Ratio (CRAR), NPA identification and provisioning, and concentration risk tracking — ensuring adherence to RBI prudential norms.

KYC & AML Compliance

Implementation and monitoring of KYC norms, AML policy compliance, suspicious transaction reporting to FIU-IND, and adherence to PMLA obligations — reducing the risk of regulatory action on AML deficiencies.

Board & Governance Compliance

Support for board meeting compliance, audit committee functioning, independent director requirements, and corporate governance disclosures mandated by the RBI's scale-based regulatory framework.

RBI Inspection Support

Preparation for and support during RBI onsite and offsite inspections — pre-inspection compliance reviews, document organisation, management briefing, and inspection observation response drafting.

NBFC Compliance Calendar — Key Annual Obligations

NBFCs face a dense compliance calendar with monthly, quarterly, half-yearly, and annual obligations to the RBI, Ministry of Corporate Affairs, Income Tax Department, and SEBI (for listed NBFCs). Key milestones include quarterly NBS returns, monthly ALM statements for larger NBFCs, annual audited financial statement submission to the RBI, annual capital adequacy certification, and FIU-IND annual report submission. Missing any of these can attract penalties and supervisory scrutiny.

Frequently Asked Questions

What are the key RBI returns an NBFC must file annually? +

Key annual RBI returns include: NBS-1 (quarterly return for deposit-taking NBFCs); NBS-2 (annual return on investments in government securities); NBS-7 (quarterly capital adequacy return for NBFC-ND-SI and NBFC-D); ALM-1 and ALM-2 (asset-liability management returns for applicable NBFCs); and the audited balance sheet submission within one month of the AGM. Base Layer NBFCs file fewer returns than Middle and Upper Layer entities.

What is the minimum CRAR requirement for NBFCs? +

The minimum Capital to Risk-Weighted Assets Ratio (CRAR) for NBFC-ND-SI and NBFC-D is 15%, of which Tier-1 capital must be at least 10%. For NBFC-Base Layer entities, CRAR of 15% is required with no bifurcation between Tier-1 and Tier-2. CRAR must be maintained on a continuous basis and reported quarterly. Breach of minimum CRAR triggers supervisory action.

What are the NPA classification norms for NBFCs? +

With effect from October 2022, the RBI aligned NBFC NPA classification norms with banks. A loan asset is classified as NPA when it is overdue for more than 90 days (previously 180 days for many NBFCs). Sub-standard assets are those classified as NPA for up to 12 months; doubtful assets have been sub-standard for over 12 months; and loss assets are those identified as irrecoverable. Provisioning requirements apply to each category.

What is the Fair Practices Code (FPC) for NBFCs? +

The RBI mandates that all NBFCs adopt a Board-approved Fair Practices Code covering: transparent loan application processing; clear communication of loan terms; non-coercive recovery practices; customer grievance redressal mechanisms; and prohibition of discriminatory practices. The FPC must be displayed in NBFC offices and uploaded to the NBFC's website. Violations are a common finding in RBI inspections.

What are the penalties for non-filing of RBI returns? +

Under Section 58G of the RBI Act, NBFCs that fail to comply with return filing requirements can be penalised up to ₹5 lakh for the initial default and up to ₹25,000 per day for continuing default. Persistent non-compliance can also result in the RBI issuing show cause notices, imposing restrictions on business activities, or initiating proceedings for cancellation of the Certificate of Registration.

Stay Compliant — Never Miss an RBI Deadline Again

Full-service NBFC annual compliance management — returns, audits, capital adequacy, and RBI inspection support.

F.A.Q.

What is GSTR-9 and why is it required?

GSTR-9 is an annual GST return that summarizes all transactions reported during the financial year. It is required to ensure proper reconciliation and compliance with GST laws.

Who is required to file GSTR-9?

All regular GST-registered taxpayers are required to file GSTR-9, except composition dealers, casual taxable persons, and non-resident taxpayers.

What is the due date for filing GSTR-9?

The due date is generally 31st December following the end of the relevant financial year, unless extended by the government.

What details are included in GSTR-9?

It includes details of outward supplies, inward supplies, input tax credit claimed, taxes paid, and adjustments made during the year.

Is GSTR-9 mandatory for all taxpayers?

GSTR-9 is mandatory for most regular taxpayers, but certain small taxpayers may get exemptions based on turnover thresholds notified by the government.

What happens if GSTR-9 is not filed on time?

Late filing may result in penalties and late fees, along with potential compliance issues or notices from GST authorities.