NBFC Annual Compliance

Legal Analysis of NBFC Annual Compliance

Recently, RBI compliances are getting tougher for Non-Banking Financial Companies than before. Earlier NBFCs used to have privileges over banks. Compliance by RBI for NBFCs was far more lenient but it changed after the Sahara case when RBI made new compliances for NBFCs, and now it is under RBI’s continuous inspection. Some essential guidelines are Securitization of Standard Assets and Guidelines for Private Placement of NBFCs. RBI keep making efforts to protect speculation in NBFCs.

RBI publishes notifications for the additional compliance requirement for NBFCs.

Submission of Annual Statements and Returns

NBFC-ND-SI (Non-Deposit category) is needed to file an annual statement of capital funds, risk assets ratio etc. It can be submitted online as well as offline physically.

Further Capital Adequacy, Liquidity, and other disclosure norms have been incorporated in Non-Banking Financial (Non-Deposit Accepting or Holding) Companies Prudential Norms (Reserve Bank) Directions, 2007.

  • Capital Adequacy of 15% to be kept
  • Balances Sheet Disclosures

Capital to Risk (Weighted) Assets Ratio (CRAR)

  • Revealing to Realty Sector both direct and indirect
  • Maturity Patterns for assets and liabilities

Asset-Liability Management (ALM) Returns are required to be submitted by NBFC- ND-SI

ALM1- Statement of short-term dynamic liquidity Monthly
ALM2 Statement of short-term structural liquidity Half Yearly
ALM3 Statement of Interest Rate Sensitivity Half Yearly

Checklist for NBFC Non-Deposit Compliances with RBI

Annual Compliance

1. Unaudited March Monthly return/NBS7 on or before 30th June


Audited March Monthly return/NBS7 Upon completion
3. Statutory Auditors certificate on Income & Assets on or before 30th June
4. Data about Cos having FDI/Foreign Funds on or before 30th June
5. Resolution of Non-acceptance of Public Deposit Before the commencement of the new Financial year
6. File Audited Annual Balance Sheet and P&L Account One month from the date of signoff
7. Declaration of Auditors to Act as Auditors of the Company annual basis

Monthly compliance

1. Monthly Return by 7th of every month


Periodical compliances

1. Director Appointment within 30 days of appointment
2. Director Resignation (DIR-12 + Challan Receipt) within 30 days of resignation
3. Adoption of any notification in the ensuing Board Meeting & filing the certified copy with RBI -