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.
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.
| LAYER | WHO IS IN IT | COMPLIANCE IMPACT |
|---|---|---|
| Base Layer | Non-deposit-taking NBFCs below ₹1,000 crore of assets; P2P, account aggregators and NBFCs without public funds or customer interface | Core prudential, KYC, conduct and reporting requirements |
| Middle Layer | All deposit-taking NBFCs, and non-deposit NBFCs with assets of ₹1,000 crore or more; standalone primary dealers and IDF-NBFCs | Additional governance, ALM, concentration and disclosure requirements; RBI statutory auditor appointment norms |
| Upper Layer | NBFCs identified by RBI’s scoring model, including the top 10 by asset size | Enhanced 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.
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).
| RETURN | WHO FILES | FREQUENCY | DUE |
|---|---|---|---|
| DNBS-01 Important financial parameters | Middle and Upper Layer (not CICs) | Quarterly | 21 days after quarter-end |
| DNBS-02 Important financial parameters | Base Layer (not P2P) | Quarterly | 21 days after quarter-end |
| DNBS-03 Important prudential parameters | Middle Layer (not CICs or SPDs) and Upper Layer | Quarterly | 21 days after quarter-end |
| DNBS-04A Short-term dynamic liquidity | Upper and Middle Layer; Base Layer with assets of ₹100 crore or more | Quarterly | 21 days after quarter-end |
| DNBS-04B Structural liquidity and interest rate sensitivity | Same as DNBS-04A | Monthly | 15 days after month-end |
| CRILC | Upper and Middle Layer (not CICs); Base Layer ICC, MFI or Factor with assets of ₹500 crore or more | Monthly | 15 days after month-end |
| DNBS-09 Defaulted borrowers | As applicable | Weekly | By Wednesday of the following week |
| DNBS-13 Overseas investment details | All NBFCs (NIL if none) | Quarterly | 21 days after quarter-end |
| FMR Fraud monitoring return | Upper and Middle Layer; Base Layer with assets of ₹500 crore or more | When a fraud is classified | 14 days after classification |
| DNBS-10 Statutory auditor certificate | All NBFCs, filed by the statutory auditor on CIMS | Annual | 5 working days after signing the audit report, and by 31 December |
| Form A certificate | All NBFCs | Annual | 1 month after appointing the statutory auditor |
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:
RBI compliance runs alongside the filings every company makes. For an NBFC these often carry more weight, because lenders and RBI read them.
Our corporate secretarial team handles board meetings, EGMs and ROC filings for mid-sized NBFCs that outsource this work.
We review your books, controls and systems, and show you what your own Decision Brief would say. Each month Regi also writes The CFO Desk, a LinkedIn newsletter for owners running businesses in the Gulf, overseas and India.