What is the SBR framework?

Scale Based Regulation (2022) categorizes NBFCs into Base, Middle, Upper and Top Layer based on asset size and significance — different compliance intensity for each.

What are the major returns?

NBS-1 (annual financial), NBS-2 (quarterly branch), NBS-ALM (asset-liability), CIC reporting, KYC reports, fraud reporting and audit-related filings.

Are there penalties for non-compliance?

Yes — RBI compounding fees, supervisory action, certificate cancellation in extreme cases. MCA penalties under Companies Act for ROC defaults.

Annual Compliances for NBFC

Non-Banking Financial Companies (NBFCs) face dual regulatory regime — RBI under various Master Directions and MCA under Companies Act, 2013. Annual compliance involves multiple statutory returns, audits, prudential reporting and XBRL filings.

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Overview

Understanding Annual Compliances for NBFC

NBFC compliance is among the most demanding in Indian corporate landscape. Beyond regular Companies Act compliance (annual filings, board / general meetings, audited financials), NBFCs must comply with RBI Master Directions covering capital adequacy, asset classification, provisioning, leverage ratio, KYC / AML, fair practices, IT framework and risk management. Statutory returns include ALM (Asset-Liability Management) returns (NBS-ALM1, NBS-ALM2), Branch Information Returns (NBS-2), Important Financial Parameters (NBS-1), Returns on Sources & Application of Funds, Statutory Auditors\' Certificate (SAC), Adverse Audit Comments and various event-based filings (changes in shareholding, directors, premises). Reporting categories vary by NBFC type — NBFC-D, NBFC-ND, NBFC-MFI, NBFC-Factor, NBFC-IFC, etc. Our team handles the full annual compliance calendar — coordinating between auditor, company secretary, and regulatory filings — to ensure no return is missed and no penalty is incurred. We also support Statutory Auditors\' Certificate (SAC), Adverse Audit Comments responses and RBI inspection / audit defence.

Why Legal Door

Built for Outcomes, Trusted Pan-India

Specialist lawyers, transparent pricing and end-to-end execution from first call to final order.

NBFC Specialist Team

CAs and CSs with NBFC compliance focus — not generalists.

Calendar-Driven Delivery

Quarterly compliance calendar with owner assignment and SLA tracking.

XBRL Filing Capability

XBRL preparation and validation for AOC-4 NBFC and other XBRL returns.

Inspection Defence

RBI on-site / off-site inspection responses and remedial action plans.

What We Cover

Key Highlights

NBS-1 — Important Financial Parameters (annual)

NBS-2 — Branch Information (quarterly)

NBS-ALM1 / ALM2 — Asset-Liability Management

Statutory Auditors' Certificate (SAC)

Adverse Audit Comments (AAC)

AOC-4 NBFC (XBRL) — financial statements

MGT-7 — annual return

DPT-3 — return of deposits

CIC reporting (CRILC, fraud reporting)

KYC / AML / FATCA / CRS compliance

IT Risk and IS Audit

Capital adequacy (CRAR) and leverage ratio reporting

Fair Practices Code compliance

Annual report disclosures

Our Process

How We Help You

A straightforward, transparent path from first call to resolution.

1Compliance Calendar

Identify all applicable RBI returns + Companies Act filings for your NBFC type and size.

2Periodic Returns

Monthly / quarterly / annual returns prepared and filed on COSMOS / XBRL platforms.

3Annual Audit

Coordinate with statutory auditor for SAC, AAC and audited financials.

4Board & General Meetings

Convene meetings; minutes drafted; resolutions filed.

5ROC Filings

AOC-4 NBFC (XBRL), MGT-7, DPT-3 within statutory timelines.

Checklist

Documents Required

Audited financial statements
Statutory Auditors' Report and SAC
Board minutes and resolutions
KYC / AML policies and updates
IT and risk management policies
Branch and personnel data
Loan / deposit / asset classification details

Legal Framework

Applicable Laws & Regulations

Key statutes, rules and judicial precedents that govern this service.

RBI Master Direction — NBFC-Systematically Important Non-Deposit Taking Company

Prudential norms for NBFC-ND-SI.

RBI Master Direction — Non-Banking Financial Company-Non-Systemically Important Non-Deposit Taking Company

For smaller NBFCs.

Companies Act, 2013

Statutory filings, board / general meetings, audit.

RBI Scale Based Regulation (SBR), 2022

NBFC categorization into Base, Middle, Upper, Top Layer.

Avoid These Mistakes

Common Pitfalls

Costly errors we routinely help clients fix — or better, avoid altogether.

Missing RBI Returns

RBI returns have specific due dates; missing attracts compounding and supervisory action.

Wrong NBFC Categorization

Compliance varies by category (NBFC-D vs ND, ICC vs MFI). Wrong categorization triggers wrong filings.

CRAR / Leverage Below Norms

Falling below CRAR norms invites severe RBI action including business restrictions.

KYC / AML Lapses

KYC / AML deficiencies are RBI inspection findings; significant fines now common.

FAQs

Common Questions

Everything you need to know before you begin

NBFCs face additional RBI compliance — periodic returns, prudential norms, capital adequacy, KYC / AML, fair practices, IT risk — on top of standard Companies Act compliance.

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