Master Direction – Non-Banking Financial Company –Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 amended up to 17.02.2020.

Till now NBFC’s with an assets size up to 100 crore and NBFC with an assets size between 100 crore to 500 crore to file annual return in NBS 8 and in NBS 9 respectively, which was as under:

i. NBS 8 for NBFCs-ND with assets size between Rs.100-500 crore, and

ii. NBS 9 for NBFCs-ND with assets size below Rs. 100 crore.

But now new XBRL return system has been implemented and all NBFC companies need to follow and file their respective return in XBRL.

Sr no Existing Return New XBRL Return Frequency NBFC
1 NBS-8 DNBS02 Annually Non-NDSI NBFCs having asset size < ₹500 crore
2 NBS-9
Statutory Auditor Certificate DNBS010 Annually Return for Statutory Auditor to be filed in XBRL system through Statutory Auditor Module.

A new return reporting platform XBRL system (https://xbrl.rbi.org.in ) has been introduced in October 2019. The online parallel filing of rationalized supervisory return formats by all NBFCs in XBRL system, in addition to COSMOS system, has been started from October 25, 2019 onwards across the regions for NBFC-D and NBFC-NDSI. RBI is in the process of migrating the existing supervisory return online filing process from COSMOS platform to XBRL system.  The COSMOS supervisory returns have been rationalised as stated above.  The revised return formats are required to be filed in the XBRL system for which the necessary return installer is made available in the live XBRL system (https://xbrl.rbi.org.in) and the same may be downloaded once the USERID / Password (NBFC SUPER USERID) is provided by RBI team.

Other Important changes are as under:-

Guidelines on Liquidity Risk Management Framework:- Applicable NBFCs having an asset size of `100 crore and above, as per their last audited balance sheet, shall adhere to the set of liquidity risk management guidelines as detailed in Annex II of these Directions. However, these guidelines will not apply to Type 1 NBFC-NDs3, Non-Operating Financial Holding Companies and Standalone Primary Dealers. It will be the responsibility of the Board of each NBFC to ensure that the guidelines are adhered to. The internal controls required to be put in place by NBFCs as per these guidelines shall be subject to supervisory review. Further, as a matter of prudence, all other NBFCs are also encouraged to adopt these guidelines on liquidity risk management on voluntary basis. Framework includes A. Liquidity Risk Management Policy, Strategies and Practices B. Management Information System (MIS) C. Internal Controls D. Maturity profiling E. Liquidity Risk Measurement – Stock Approach F. Currency Risk G. Managing Interest Rate Risk H. Liquidity Risk Monitoring Tools

Multiple NBFCs:-Applicable NBFCs that are part of a corporate group or are floated by a common set of promoters shall not be viewed on a standalone basis. The total assets of the NBFCs in a group including deposit taking NBFCs, if any, shall be aggregated to determine if such consolidation falls within the asset sizes of the two categories i.e. those with asset size of below ₹ 500 crore and those with asset size of ₹ 500 crore and above. The regulations as applicable to the two categories shall be applicable to each of the non-deposit taking NBFC within the group. For this purpose, Statutory Auditors are required to certify the asset size of all the NBFCs in the Group. However, NBFC-D, within the group, if any, shall be governed under the Non-Banking Financial Companies Acceptance of Public Deposits (Reserve Bank) Direction 2016 and Non-Banking Financial Company – Systemically Important NonDeposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016as applicable to deposit taking NBFCs.

Schedule to the balance sheet:-Every applicable NBFC shall append to its balance sheet prescribed under the Companies Act, 2013, the particulars in the schedule as set out in Annex III.

NBFC on whom Indian Accounting Standard made applicable were required to follow RBI/2019-20/170 DOR (NBFC).CC.PD.No.109/22.10.106/2019-20 dated 13.03.2020 which is Implementation of Indian Accounting Standards by Non-Banking Financial Companies and Asset Reconstruction Companies wherein details guidelines were set for NBFC to follow.

Article is written by CA. Rahul Sureka, FCA, CS, LLB, DISA(ICAI)and can be reached at rahulsureka28@gmail.com or Mobile no 9773450180.

Disclaimer: This article is for general guidance on matters of interest only and does not constitute any professional advice. One should not act upon the information contained in this article without obtaining specific professional advice. Further, no representation or warranty (expressed or implied) is given as to the accuracy or completeness of the information contained in this article.

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3 Comments

  1. ABHISHEK says:

    Hi Sir,
    Thanks for the Info!
    But could you please inform the procedure for obtaining login credentials of XBRL based electronic filing platform and the financial year for which new reporting requirement will be applicable.

  2. ABHISHEK says:

    Hi Sir,
    Thanks for the Info!
    But could you please inform the procedure for obtaining login credentials of XBRL based electronic filing platform and the financial year for which new reporting requirement will be applicable.

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