NBFC GUIDE · COMPLIANCE

NBFC compliance checklist and calendar for FY 2026-27

What a Base Layer or Middle Layer NBFC must file, maintain and review through the year under RBI’s consolidated directions, plus the Companies Act and tax filings that run alongside.

By Regi Tom Antony, FCA, MBA (Australia), ACMA (UK), CGMA (USA), CISA (USA) · Former Group CFO/COO (OSRAM/Siemens, Westcon Group) · Published 4 November 2026

IN SHORT

An NBFC’s annual compliance has four parts: continuous requirements (net owned fund, capital adequacy, KYC, fair practices code and fraud reporting), periodic RBI returns such as DNBS-02 or DNBS-01, DNBS-13 and the annual DNBS-10 statutory auditor certificate under RBI’s Supervisory Returns Directions, 2026, annual board review of policies, and Companies Act and tax filings. Which items apply depends on the NBFC’s layer under RBI’s Scale Based Regulation Directions, 2025.

01 · START HERE

Step 1: confirm your layer

RBI’s Non-Banking Financial Companies – Registration, Exemptions and Framework for Scale Based Regulation Directions, 2025 (28 November 2025) place every NBFC in a layer, and the layer decides much of the compliance load.

LAYERWHO IS IN ITCOMPLIANCE IMPACT
Base LayerNon-deposit-taking NBFCs below ₹1,000 crore of assets; P2P, account aggregators and NBFCs without public funds or customer interfaceCore prudential, KYC, conduct and reporting requirements
Middle LayerAll deposit-taking NBFCs, and non-deposit NBFCs with assets of ₹1,000 crore or more; standalone primary dealers and IDF-NBFCsAdditional governance, ALM, concentration and disclosure requirements; RBI statutory auditor appointment norms
Upper LayerNBFCs identified by RBI’s scoring model, including the top 10 by asset sizeEnhanced capital, governance and disclosure, on a 24-month transition

Group NBFCs’ assets are consolidated to test the ₹1,000 crore threshold. See scale-based regulation explained for the full rules.

02 · ALL YEAR

Step 2: continuous compliances

  • Net owned fund (NOF) and capital adequacy (CRAR) maintained at all times. NBFC-ICC, NBFC-MFI and NBFC-Factor move to a minimum NOF of ₹10 crore by 31 March 2027 under the glide path.
  • KYC and anti-money laundering: customer due diligence, CKYCR uploads within the prescribed time, and FIU-IND reports where applicable.
  • Fair practices code displayed on the website and in branches, with a working grievance redressal mechanism.
  • Fraud reporting to RBI as soon as a fraud is identified.
  • Change in directors or management intimated to RBI within the prescribed time, and prior approval for changes in control.
  • Asset classification and provisioning applied every month, not only at year-end.
03 · THE CALENDAR

Step 3: the RBI returns calendar

RBI’s Non-Banking Financial Companies – Supervisory Returns Directions, 2026 (31 July 2026) set out which returns each NBFC files and when. Returns are filed online; due dates run from the reference date (week, month or quarter end).

RETURNWHO FILESFREQUENCYDUE
DNBS-01 Important financial parametersMiddle and Upper Layer (not CICs)Quarterly21 days after quarter-end
DNBS-02 Important financial parametersBase Layer (not P2P)Quarterly21 days after quarter-end
DNBS-03 Important prudential parametersMiddle Layer (not CICs or SPDs) and Upper LayerQuarterly21 days after quarter-end
DNBS-04A Short-term dynamic liquidityUpper and Middle Layer; Base Layer with assets of ₹100 crore or moreQuarterly21 days after quarter-end
DNBS-04B Structural liquidity and interest rate sensitivitySame as DNBS-04AMonthly15 days after month-end
CRILCUpper and Middle Layer (not CICs); Base Layer ICC, MFI or Factor with assets of ₹500 crore or moreMonthly15 days after month-end
DNBS-09 Defaulted borrowersAs applicableWeeklyBy Wednesday of the following week
DNBS-13 Overseas investment detailsAll NBFCs (NIL if none)Quarterly21 days after quarter-end
FMR Fraud monitoring returnUpper and Middle Layer; Base Layer with assets of ₹500 crore or moreWhen a fraud is classified14 days after classification
DNBS-10 Statutory auditor certificateAll NBFCs, filed by the statutory auditor on CIMSAnnual5 working days after signing the audit report, and by 31 December
Form A certificateAll NBFCsAnnual1 month after appointing the statutory auditor
Most return errors are not late filings but figures that do not tie to the books. Reconcile the loan management system, general ledger and return data before each filing.
04 · BOARD

Step 4: annual board and policy reviews

RBI’s consolidated Master Directions of 28 November 2025 replaced about 3,500 circulars and guidelines, so every policy should now cite the current direction. Review at least these each year:

  • Credit and loan policy, including interest rate model and charges
  • KYC and AML policy
  • Fair practices code and grievance redressal
  • Asset liability management and liquidity risk
  • Investment policy
  • Outsourcing and IT policies, including information security
  • Co-lending policy, if you co-lend (see co-lending reconciliation)
  • Gold loan policy, if you lend against gold (see gold loan directions)
05 · ALONGSIDE

Step 5: Companies Act and tax filings

RBI compliance runs alongside the filings every company makes. For an NBFC these often carry more weight, because lenders and RBI read them.

  • Financial statements (AOC-4) and annual return (MGT-7) after the AGM
  • Charge creation and modification (CHG-1) for each new borrowing secured on assets
  • Resolutions and returns for borrowing powers, debenture issues and allotments, often needing an EGM
  • Director KYC (DIR-3 KYC), now on a three-year cycle
  • TDS returns every quarter, and GST returns on fees and charges

Our corporate secretarial team handles board meetings, EGMs and ROC filings for mid-sized NBFCs that outsource this work.

QUESTIONS

Frequently asked questions

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What are the main compliances for an NBFC in India?

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The main NBFC compliances are maintaining net owned fund and capital adequacy, KYC and anti-money laundering, the fair practices code, fraud reporting, asset classification and provisioning, periodic RBI returns such as DNBS-01 or DNBS-02, DNBS-13 and liquidity returns, the annual DNBS-10 statutory auditor certificate, annual board review of policies, and Companies Act and tax filings.
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Which RBI returns does a Base Layer NBFC file?

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Under RBI’s Supervisory Returns Directions, 2026, a Base Layer NBFC files DNBS-02 and DNBS-13 quarterly and the annual DNBS-10 statutory auditor certificate. With assets of ₹100 crore or more it also files DNBS-04A quarterly and DNBS-04B monthly, and with assets of ₹500 crore or more it files fraud monitoring returns, and CRILC if it is an ICC, MFI or Factor.
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When are DNBS-02 and DNBS-13 due?

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Both are quarterly returns due within 21 days of the end of the quarter, under RBI’s Supervisory Returns Directions, 2026. DNBS-02 is filed by Base Layer NBFCs; DNBS-13 (overseas investment details) by all NBFCs, as NIL if there are none.
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What is the minimum net owned fund for an NBFC in 2027?

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Under RBI’s Scale Based Regulation Directions, 2025, NBFC-ICC, NBFC-MFI and NBFC-Factor companies must reach a minimum net owned fund of ₹10 crore by 31 March 2027. NBFC-P2P, account aggregators and NBFCs without public funds or customer interface need ₹2 crore, and NBFC-IFC and IDF-NBFC need ₹300 crore.
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Does RBI’s November 2025 consolidation change NBFC compliance?

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On 28 November 2025 RBI issued consolidated Master Directions that replaced about 3,500 earlier circulars and guidelines. Most obligations continue, but policies, compliance checklists and board papers need to refer to the new directions, and RBI has since issued further NBFC directions, including on supervisory returns and statutory audit in July 2026.
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Who prepares an NBFC’s compliance calendar?

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The compliance officer or company secretary usually owns the calendar, with the finance team supplying return data. Mid-sized NBFCs often outsource parts of the work, such as return preparation checks, reconciliations and secretarial filings.

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Regi Tom Antony & Associates is a firm of Chartered Accountants in Kochi, Kerala, practising since 1997. We act as virtual and fractional CFO to growing businesses in India, the GCC and overseas, and advise on NRI taxation and FEMA, SME IPOs, India entry for foreign companies, tax structuring, and family office and succession planning, alongside audit, tax and compliance.