NBFCs are financial institutions that offer various banking services without constituting the legal definition of a bank. They are primarily governed by the Reserve Bank of India (RBI) and are critical in bridging credit gaps across diverse sectors of the economy.
As of March 31, 2024, RBI reported approximately 9,000 registered Non-Banking Financial Companies (NBFCs) operating in India. These NBFCs are categorized under the Scale-Based Regulation (SBR) framework into four distinct layers based on their size, complexity, and systemic importance:
1. Base Layer (NBFC-BL): Comprising about 96.2% of the total NBFCs, these entities are non-systemically important and typically include smaller NBFCs. Despite their large numbers, they account for only about 6% of the sector’s total assets.
2. Middle Layer (NBFC-ML): These are systemically important NBFCs, including all deposit-taking NBFCs and non-deposit-taking NBFCs with significant asset sizes. They represent approximately 3.7% of the total number of NBFCs but hold about 68.8% of the sector’s total assets.
3. Upper Layer (NBFC-UL): Identified by the RBI as systemically significant based on specific parameters, there are currently 15 NBFCs in this category, including prominent names like Bajaj Finance, LIC Housing Finance, and Tata Capital. These entities are subjected to enhanced regulatory requirements.
4. Top Layer (NBFC-TL): This layer is currently unoccupied but is reserved for NBFCs that may pose extreme systemic risks in the future.
While the vast majority of NBFCs in India are non-systemically important and fall under the Base Layer, a small fraction, approximately 3.8% are classified as systemically important, falling under the Middle and Upper Layers. These systemically important NBFCs play a crucial role in the financial ecosystem due to their substantial asset holdings and broader economic impact.
Major categories of NBFCs include:
- Investment and Credit Companies (ICC)
- Infrastructure Finance Companies (IFCs)
- Microfinance Institutions (MFIs)
- Housing Finance Companies (HFCs)
- Infrastructure Debt Fund (IDF-NBFC)
- Core Investment Company (CIC)
- Non-Banking Financial Company – Factors (NBFC-Factors)
- Mortgage Guarantee Companies (MGC)
- Standalone Primary Dealers (SPDs)
- Non-Operative Financial Holding Company (NOFHC)
- NBFC – Account Aggregator (NBFC-AA)
- NBFC – Peer to Peer Lending Platform (NBFC-P2P)
NBFC COMPLIANCE CALENDAR
Applicable to: NBFC – Base Layer (BL) & Middle Layer (ML)
A. Ongoing / Event-based Compliances
| Sr. | Compliance | Applicability | Timeline | Portal / Authority | Remarks |
| 1 | Maintenance of CRAR and NOF | BL & ML | Continuous | Internal / RBI | As per scale-based regulation |
| 2 | Fair Practices Code (FPC) | BL & ML | Continuous | Website / Board | Display on website & branches |
| 3 | KYC / AML compliance | BL & ML | Continuous | FIU-IND / RBI | As per Master Directions |
| 4 | CKYCR upload | BL & ML | Within prescribed time | CKYCR | Customer-wise |
| 5 | Reporting frauds | BL & ML | Immediate | RBI | As per RBI fraud framework |
| 6 | Change in directors / management | BL & ML | Within 30 days | RBI Pravah | Prior / post intimation as applicable |
B. Monthly Compliances
| Sr. | Compliance | Due Date | Applicable Layer | Portal / Authority |
| 1 | DNBS04B- Structural Liquidity & Interest Rate Sensitivity | 15 days from reference date | BL with
asset size of ₹100 crore and above solely |
RBI – CIMS |
| 2 | Reporting of complaints to RBI CMS | Monthly | BL & ML | RBI CIMS |
| 3 | FIU-IND reporting (CTR / STR, if applicable) | Monthly | BL & ML | FIU-IND |
| 4 | ALM statements (if applicable) | 10th of next month | ML | FIU- IND |
C. Quarterly Compliances
| Sr. | Compliance | Quarter | Due Date | Applicable Layer | Portal |
| 1 | Statutory Returns (DNBS-02) | Q1–Q4 | 21 days from reference date | BL & ML | RBI CIMS |
| 2 | Statutory Returns (DNBS-13) | Q1–Q4 | 15 days from reference date | BL & ML | RBI CIMS |
| 3 | DNBS04A- Short Term Dynamic Liquidity | Q1–Q4 | 15 days from reference date | BL with
asset size of ₹100 crore and above solely |
RBI CIMS |
| 4 | ALM – Structural Liquidity | Q1–Q4 | 30 days | ML | RBI CIMS |
D. Half-Yearly Compliances
| Sr. | Compliance | Period | Due Date | Applicable Layer | Portal |
| 1 | Half-yearly ALM disclosures | Sep / Mar | 30 days | ML | RBI / Website |
E. Annual Compliances
| Sr. | Compliance | Due Date | Applicable Layer | Portal / Authority |
| 1 | DNBS-10 | Within 5 working days from the date of signing of the Audit Report, but not later than 31st Dec. | BL-ML | RBI – CIMS |
| 2 | Auditor’s Certificate on prudential norms | With annual returns | BL & ML | RBI |
| 3 | Board-approved policies review (FPC, KYC, Risk, IT, Outsourcing etc) | Annually | BL & ML | Board |
Note: Calendar is indicative and subject to RBI Master Directions, Scale Based Regulation (SBR), and company-specific conditions.
India’s Non-Banking Financial Companies (NBFCs) are evolving from alternative lenders to key enablers of financial inclusion and innovation. With over 9,000 registered entities and credit accounting for 13.6% of GDP in FY24, NBFCs are rapidly expanding their reach into underserved markets, MSME financing, digital lending, green finance, and embedded financial services. As the sector integrates technology and adapts to regulatory reforms, it presents unprecedented growth potential.
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