NBFC GUIDE · AUDIT

How to get an NBFC statutory audit done smoothly

Why NBFC audits overrun, what the statutory auditor and RBI expect, and the year-round preparation that lets the audit close and the annual report be adopted on time.

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 statutory audit closes on time when the books are reconciled before the auditor arrives: loan system to general ledger and bank, co-lending and Business Correspondent partners, and income against TDS and fees against GST. Audit readiness also needs complete PBC (prepared by client) schedules, documented asset classification, provisioning and Ind AS workings, and closed internal audit findings. Timely adoption of the audited accounts and annual report matters because lenders and investors read them before renewing or increasing funding.

01 · THE PROBLEM

Why NBFC audits overrun

  • The loan management system and the general ledger do not agree at year-end.
  • Control accounts such as foreclosure, disbursement payable and collection suspense carry old, unexplained balances.
  • Co-lending and Business Correspondent partner balances differ from the partners’ confirmations.
  • Asset classification and provisioning are computed late, or the workings are not documented.
  • Interest income does not reconcile with TDS credits, or fees with GST returns.
  • Internal audit findings from the year are still open.

Each of these turns into auditor queries, adjustments and delay. For an NBFC that depends on borrowings, a late audit means late annual returns, late lender submissions and harder funding conversations.

02 · RBI REQUIREMENTS

What RBI adds to an NBFC audit

  • The statutory auditor files the annual statutory auditor certificate (DNBS-10) on RBI’s CIMS portal within five working days of signing the audit report, and no later than 31 December, under the Supervisory Returns Directions, 2026.
  • RBI’s NBFC Statutory Audit Directions, 2026 (31 July 2026) set the appointment rules: a continuous three-year term, a six-year bar on reappointment, a maximum of eight NBFC audits per firm in a year, and joint audit by at least two firms once total assets reach ₹15,000 crore. Non-deposit NBFCs with assets below ₹1,000 crore may keep their existing procedure.
  • Under the same directions, there must be a gap of at least one year between non-audit work for the NBFC, including internal audit, and appointment as statutory auditor. Tax audit, statutory certificates and audit of interim financial statements are treated as not normally creating a conflict.
This is why RTA keeps CFO, internal audit and audit support separate from the statutory audit itself, consistent with section 144 of the Companies Act, 2013.
03 · READINESS

A year-end audit readiness checklist

  1. Close and reconcile the three streams: LOS and LMS to control and other ledgers and bank; co-lending and BC partners; and statutory records (income against TDS in Form 26AS and AIS, fees against GST).
  2. Clear or explain every control account balance, with ageing.
  3. Prepare asset classification, provisioning and, where Ind AS applies, expected credit loss workings with the data behind them.
  4. Obtain balance confirmations from lenders, co-lending partners and BC partners.
  5. Assemble the PBC schedules the auditor asked for last year, updated, before fieldwork starts.
  6. Close internal audit findings, or document management’s response.
  7. Agree a timetable with the auditor, the audit committee and the board for adoption of the accounts.
04 · AUDIT SUPPORT

What statutory audit support looks like in practice

Audit support means one person who owns the audit for the NBFC: tracking the PBC list, answering queries the same week, coordinating with operations and branches, reviewing draft financial statements and disclosures, and closing management letter points afterwards. It works best on top of a monthly close and a head office internal audit, so the year-end holds no surprises.

QUESTIONS

Frequently asked questions

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How can an NBFC make its statutory audit smoother?

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Reconcile the loan system to the general ledger and bank, partner balances and statutory records before the audit, clear control account balances, document provisioning and Ind AS workings, prepare PBC schedules in advance, close internal audit findings, and agree a timetable with the auditor and the board.
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Can an NBFC’s internal auditor also be its statutory auditor?

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Not at the same time. Section 144 of the Companies Act, 2013 restricts the services a statutory auditor can provide, and RBI’s NBFC Statutory Audit Directions, 2026 require a gap of at least one year between non-audit work, including internal audit, and appointment as statutory auditor.
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What does the statutory auditor of an NBFC file with RBI?

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The statutory auditor files the annual statutory auditor certificate (DNBS-10) on RBI’s CIMS portal, based on the audited books, within five working days of signing the audit report and no later than 31 December. The NBFC also files a Form A certificate within one month of appointing the auditor.
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Which NBFCs must follow RBI’s statutory auditor appointment rules?

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RBI’s NBFC Statutory Audit Directions, 2026 apply to NBFCs, including housing finance companies. Non-deposit NBFCs with assets below ₹1,000 crore may continue their existing procedure. The directions set a three-year term, a six-year reappointment bar, a limit of eight NBFC audits per firm, and joint audit from ₹15,000 crore of total assets.
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Why does timely adoption of the annual report matter for an NBFC?

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NBFCs depend on borrowings. Lenders, investors and rating agencies rely on audited financial statements before renewing or increasing funding, so a delayed audit can delay funding and weaken the NBFC’s standing.
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What is statutory audit support?

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Statutory audit support is help for the NBFC’s finance team, not the audit itself: reconciled books, PBC schedules, provisioning workings, a single point of contact for auditor queries, review of financial statements and disclosures, and closure of management letter points.

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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.