Harun Raaj & AssociatesHarun Raaj & Associates
Business Finance & Credit

Credit Rating Advisory

Credit Rating Advisory

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Regulatory Framework

SEBI (Credit Rating Agencies) Regulations, 1999 (notified vide S.O. 594(E) dated 7 July 1999): the regulatory framework governing registration, obligations, and rating processes of Credit Rating Agencies (CRAs) operating in the Indian securities market. CRAs must hold SEBI registration and follow prescribed rating-process, monitoring, and disclosure norms before assigning or reviewing ratings on debt instruments, bank facilities, or corporate credit profiles. For MSME borrowers, the NSIC (National Small Industries Corporation) Performance and Credit Rating Scheme subsidises a substantial part of the rating fee charged by empanelled rating agencies — up to 75% of the fee, with the subsidy amount capped at one of ₹40,000, ₹30,000, or ₹25,000 depending on the applicant's annual turnover band. A favourable rating obtained under this SEBI-regulated framework improves a borrower's standing with banks and NBFCs for facility sanction and pricing, and — for eligible MSME units — makes the rating exercise itself substantially subsidised under the NSIC scheme. Advisory scope under this service covers assessment of rating readiness, coordination with an empanelled CRA, and preparation of the financial and operational disclosures the CRA's rating process requires under the SEBI 1999 Regulations.

Overview

A credit rating is an independent assessment of a company's creditworthiness — its ability and willingness to meet its debt obligations — issued by a rating agency registered with SEBI under the SEBI (Credit Rating Agencies) Regulations 1999. The rating is expressed as a symbol — investment grade or speculative — and it is the number the lending market uses to price the company's credit risk: banks, bond investors, suppliers and trade creditors all read it.

For a company, the rating is a working capital asset. A good rating lowers the interest rate on bank facilities, opens the bond market, and shortens negotiation with trade creditors. A rating process also forces the company's financials into the discipline of a structured review — projections, cash flows, management depth and industry position — which is itself valuable even when the rating is not what the management hoped.

The cost of avoiding a rating is invisible and permanent: the company borrows at the unrated price, and unrated borrowers are priced as riskier than their actual position justifies. Where a rating exists, the gap between the company's true position and its pricing is narrower; where it does not, the lender's assumption is the price.

This service is for companies preparing for their first rating or managing an existing one — for bank facilities, bonds, or counterparty credibility. We prepare the information memorandum and financial projections the agency needs, coordinate the rating process and the agency's queries, advise on the levers that improve the rating — capital structure, liquidity, working capital — and manage the annual surveillance that keeps the rating current.

How It Works

  1. 1

    Rating Readiness Review

    We review the company's financials, projections and structure for the rating exercise.

    Harun Raaj & Associates does this3-5 days
  2. 2

    Information Pack Preparation

    We prepare the information memorandum, projections and management presentation for the agency.

    Harun Raaj & Associates does this1-2 weeks
  3. 3

    Agency Coordination

    We coordinate the agency's process — meetings, queries and site review.

    Harun Raaj & Associates does this2-4 weeks
  4. 4

    Rating Report Review

    We review the draft rating rationale and support your response to the agency.

    Harun Raaj & Associates does this1 week
  5. 5

    Surveillance & Improvement

    We manage the annual surveillance and advise on the levers to improve the rating over time.

    Harun Raaj & Associates does thisAnnual

Frequently Asked Questions

Which SEBI regulations govern credit rating agencies in India?
Credit Rating Agencies are regulated under the SEBI (Credit Rating Agencies) Regulations, 1999. All ratings on listed debt instruments, commercial paper, and fixed deposits must be obtained from a SEBI-registered CRA. The RBI Master Circular on Rating of Debt Instruments additionally mandates ratings for bank loan exposures above Rs 5 crore for Basel II/III capital adequacy purposes.
Is a credit rating mandatory before issuing Non-Convertible Debentures (NCDs)?
Yes. Under SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021, Regulation 7 requires a minimum investment-grade credit rating from at least one SEBI-registered CRA for any public issue of NCDs. For private placement under Regulation 23, a rating is mandatory if the NCDs are proposed to be listed on a recognised stock exchange.
What financial documents does a rating agency typically require from a company?
CRAs follow their own information frameworks but typically require audited financial statements for the last 3-5 years prepared under Schedule III of the Companies Act, 2013, projected cash flow statements, loan sanction letters, the Memorandum and Articles of Association, and a management discussion note. For bank loan ratings, the RBI circular DBR.BP.BC.No.41/21.04.141/2015-16 specifies the credit information format applicable to borrowers.
Can a company withdraw or migrate its rating to a different CRA, and what rules apply?
Yes. SEBI circular SEBI/HO/DDHS/CIR/P/2019/155 dated December 26, 2019 sets out the framework for rating migration and withdrawal. The issuer must disclose the last outstanding rating to the incoming CRA, and the outgoing CRA must publish a press release upon migration. Ratings cannot be withdrawn to avoid a downgrade — under the circular, the outgoing CRA must continue publishing the outstanding rating for 6 months if the issuer stops cooperating.
How does a credit rating affect the cost of External Commercial Borrowings (ECB)?
Under the RBI ECB Master Direction (RBI/FED/2018-19/67, updated periodically), the all-in-cost for ECB is capped at the benchmark rate (Term SOFR) plus a permitted spread. A stronger credit rating from an internationally recognised agency can reduce the negotiated spread and help the borrower remain within the RBI all-in-cost ceiling. For rupee-denominated ECBs (Masala Bonds), a domestic rating from a SEBI-registered CRA is mandatory under the ECB framework.

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