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Business Compliance & Labour Lawvia RBI CIMS Portal (rbi.org.in) — NBFC Returns

NBFC Compliance Returns — RBI Regulatory Filings & Prudential Compliance

Comprehensive compliance calendar and return filing for Non-Banking Financial Companies — NBS-7 (quarterly), CRILC, ALM returns, NBS-9 (annual), DNBS-10 (FPC), net-owned funds computation, and Fair Practices Code compliance under RBI Master Directions.

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STARTING FROM₹24,999
TYPICAL TIMELINE30 days
DOCS REQUIRED4 documents
APPLICABLE TOCompany

Regulatory Framework

RBI Act, 1934: Section 45-IA — mandatory registration for NBFCs; Section 45-IC — reserve fund requirement (20% of net profit); Section 58B — penalty for non-compliance with RBI directions. Reserve Bank of India Master Direction – Non-Banking Financial Companies – Systemically Important Non-Deposit Taking Company (RBI/DNBR/2016-17/44) and its amendments: Chapter IV — prudential norms; Chapter V — capital adequacy (minimum 15% CAR for ND-SI); Chapter VI — exposure norms; Chapter VII — asset classification and provisioning (IRACP); Chapter VIII — leverage ratio. NBFC Scale-Based Regulation (SBR): RBI Circular RBI/2021-22/112 dated 22 October 2021, effective 1 October 2022. CRILC: RBI Master Circular DBOD.No.BP.BC.96/21.04.048/2013-14 extended to NBFCs vide RBI/DNBR/2015-16/46. ALM returns: RBI/2014-15/527 DNBR.CC.PD.No.007/03.10.38/2014-15. Net Owned Fund minimum ₹10 crore for NBFC-ICC: RBI/2022-23/168 DNBR.PD.(PRD).CC.No.120/03.10.001/2022-23.

Overview

Non-Banking Financial Companies (NBFCs) registered with the Reserve Bank of India are subject to an extensive regulatory compliance framework. Unlike banks, NBFCs have varying compliance obligations depending on their asset size, deposit-taking status, and RBI classification under the Scale-Based Regulation (SBR) framework. Missing regulatory return deadlines attracts penalties under Section 58B of the RBI Act, 1934.

Core NBFC Returns and Compliance Obligations:

1. NBS-7 — Quarterly Return (for NBFC-ND-SI with asset size ≥₹500 crore and NBFC-D):
The NBS-7 return captures capital adequacy ratio (CAR), asset classification and provisioning, leverage ratio, and prudential norms compliance. Due within 15 days of the end of each quarter (June 30, September 30, December 31, March 31). Filed on RBI's XBRL-based CIMS portal (Centralised Information Management System).

2. CRILC — Central Repository of Information on Large Credits:
All NBFCs with asset size ≥₹100 crore must report all borrowers with aggregate credit exposure of ₹5 crore and above to CRILC on a quarterly basis (due within 21 days of quarter end). CRILC is used by RBI for early warning on large credit concentrations.

3. ALM Returns — Asset Liability Management:
NBFC-ND-SI (asset size ≥₹100 crore) and all deposit-taking NBFCs must file ALM returns — NBS-ALM-1 (maturity profile of assets and liabilities), NBS-ALM-2 (structural liquidity), and NBS-ALM-3 (interest rate sensitivity) — quarterly, within 20 days of quarter end.

4. NBS-9 — Annual Return:
Annual return capturing financial position, income, expenditure, NPAs, and capital adequacy. Due within 60 days of the close of the financial year (by 30 June for March FY-end NBFCs). Filed on CIMS.

5. DNBS-10 — Fair Practices Code (FPC) Return:
Annual self-certification of adherence to the Fair Practices Code for NBFCs issued by RBI. Covers interest rate transparency, loan appraisal process, disbursement conditions, and grievance redressal.

6. Net-Owned Fund (NOF) Computation:
All NBFCs must maintain minimum NOF: ₹10 crore for NBFC-ICC, NBFC-P2P, NBFC-AA, NOFHC; ₹2 crore for Standalone Primary Dealers. NOF = Tier I capital - amounts invested in shares of subsidiaries/group companies - book value of debentures/bonds issued by subsidiaries. Annual NOF certificate from statutory auditor required.

7. Master Direction on NBFC-SI (RBI/DNBR/2016-17/44):
Governs asset classification, provisioning, capital adequacy, leverage, concentration norms, exposure limits, and reporting for systemically important NBFCs.

How It Works

  1. 1

    NBFC Classification & SBR Tier Assessment

    Determine the NBFC's classification under the Scale-Based Regulation framework: Base Layer (NBFC-BL: asset size <₹1,000 crore), Middle Layer (NBFC-ML: asset size ≥₹1,000 crore or deposit-taking), Upper Layer (NBFC-UL: top 10 by asset size or designated by RBI), or Top Layer (exceptional). Each tier has different compliance obligations, capital adequacy requirements, and governance norms. Identify deposit-taking (NBFC-D) vs. non-deposit-taking systemically important (NBFC-ND-SI: asset size ≥₹500 crore) status for return applicability.

    Government3-5 days
  2. 2

    Return Calendar Setup — CIMS Portal Access & Mapping

    Map all applicable returns to the NBFC's profile on the RBI CIMS portal: NBS-7 (quarterly, if asset size ≥₹500 crore), CRILC (quarterly, if asset size ≥₹100 crore), ALM returns (quarterly, if asset size ≥₹100 crore), NBS-9 (annual), DNBS-10 (annual FPC). Set up return calendar with due dates: NBS-7 due 15 days after quarter end; CRILC due 21 days; ALM returns due 20 days; NBS-9 due 60 days after FY end. Register NBFC on CIMS and configure user access for CA.

    Government2-3 days
  3. 3

    NBS-7 Quarterly Return — CAR, NPA & Provisioning Computation

    Compute the Capital Adequacy Ratio (CAR): Tier I + Tier II capital as a percentage of risk-weighted assets. Minimum CAR: 15% for NBFC-ND-SI, 10% for NBFC-D. Classify asset portfolio per IRACP norms: Standard, Sub-standard (NPA for >90 days), Doubtful, Loss assets. Compute provisioning: Standard (0.4% for systemically important, 0.25% for others), Sub-standard (10%), Doubtful (20-100% depending on age), Loss (100%). Verify leverage ratio (≤7 for NBFC-ND-SI, i.e., total outside liabilities / owned funds). File NBS-7 on CIMS within 15 days of quarter end.

    Government5-7 days
  4. 4

    CRILC Reporting & ALM Returns Filing

    Prepare CRILC data: all borrowers with aggregate credit exposure ≥₹5 crore — capture facility details, outstanding amount, NPA status, days past due. File on CIMS within 21 days of quarter end. Prepare ALM returns: NBS-ALM-1 (maturity buckets for assets and liabilities: 1-14 days, 15-30 days, 31-90 days, 3-6 months, 6-12 months, 1-3 years, 3-5 years, >5 years), NBS-ALM-2 (structural liquidity gap analysis), NBS-ALM-3 (interest rate sensitivity — RSA vs RSL). Flag negative liquidity gaps exceeding RBI tolerance limits.

    Government5-7 days
  5. 5

    NBS-9 Annual Return, NOF Certificate & FPC Compliance

    Prepare NBS-9 annual return: balance sheet summary, P&L, income breakdown (interest, fee, investment), NPA schedule, capital funds, provisioning coverage. File on CIMS within 60 days of FY end. Compute Net-Owned Funds (NOF): Tier I capital minus investments in subsidiaries and group company instruments. Issue NOF certificate as statutory auditor. Prepare and file DNBS-10 Fair Practices Code annual return: confirm adherence to RBI FPC circular — interest rate communication to borrowers, loan appraisal and sanction disclosures, disbursement conditions, KYC compliance, and grievance redressal mechanism.

    Government7-10 days

Frequently Asked Questions

Which NBFCs are required to file NBS-7 returns?
NBS-7 is a quarterly return applicable to: (i) NBFC-ND-SI (Non-Deposit Taking Systemically Important NBFCs) — those with asset size of ₹500 crore or more; and (ii) all deposit-taking NBFCs (NBFC-D) regardless of asset size. NBFCs with asset size below ₹500 crore and which are non-deposit taking are not required to file NBS-7 but must file NBS-9 (annual). Under the Scale-Based Regulation framework effective from October 2022, Middle Layer and Upper Layer NBFCs have enhanced reporting obligations including NBS-7, CRILC, and ALM returns.
What is the minimum Capital Adequacy Ratio required for NBFCs?
The minimum Capital Adequacy Ratio (CAR) varies by NBFC type: (i) NBFC-ND-SI (asset size ≥₹500 crore): minimum 15% CAR — Tier I must be at least 10% independently; (ii) NBFC-D (all deposit-taking NBFCs): minimum 15% CAR — Tier I must be at least 12%; (iii) Asset Finance Companies and Loan Companies with asset size <₹500 crore: minimum 15% CAR. CAR = (Tier I Capital + Tier II Capital) / Risk-Weighted Assets × 100. Risk weights: 100% for most credit exposures; capital market exposures may carry higher risk weights.
What is Net-Owned Fund (NOF) and what is the minimum requirement?
Net-Owned Fund (NOF) is the foundation of an NBFC's capital base. NOF = (Paid-up equity capital + Preference shares + Free reserves + Share premium) minus (Accumulated losses + Deferred revenue expenditure + Other intangible assets) minus (Investments in shares of subsidiaries/group companies + Book value of debentures/bonds issued by subsidiaries/group companies). Minimum NOF for NBFC-ICC (Investment and Credit Company): ₹10 crore (as per RBI circular RBI/2022-23/168). NBFCs that fail to meet minimum NOF are in breach of registration conditions and must submit a roadmap to RBI. Annual NOF certificate from the statutory CA auditor is required.
What is CRILC and who must report to it?
CRILC (Central Repository of Information on Large Credits) is a database maintained by RBI where financial institutions report details of all borrowers with aggregate credit exposure of ₹5 crore and above. NBFCs with asset size of ₹100 crore or more must report to CRILC quarterly within 21 days of the end of the quarter. The report captures: borrower name and PAN, credit facility type, outstanding amount, classification (Standard/SMA-0/SMA-1/SMA-2/NPA), and days past due. CRILC is used by RBI for early detection of stress in the credit system and by financial institutions to check a borrower's credit health before lending.
What are the penalties for non-filing or delayed filing of NBFC returns?
Non-filing or delayed filing of mandatory NBFC returns attracts penalties under Section 58B of the RBI Act, 1934. RBI has the power to impose monetary penalties of up to ₹5 lakh for first violations and up to ₹25 lakh for continuing violations (per day after the first default). In practice, RBI also issues Compounding Orders for specific violations and can impose directions on the NBFC or, in extreme cases, cancel its Certificate of Registration. The introduction of RBI's Risk-Based Supervision (RBS) for NBFCs means return filing delays are flagged during supervisory examinations and affect the NBFC's CAMELS rating, which can trigger increased supervisory scrutiny.

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