The Reserve Bank of India has issued Master Directions on the ‘Filing of Supervisory Returns’ by all Supervised Entities on February 27, 2024. In this article, we will focus on the changes applicable to NBFCs. It has provided a summary of changes to the existing circulars / Directions introduced, a list of circulars/notifications repealed with the issuance of these Directions w.r.t supervised entities, a list of applicable returns to be filed, alternate timelines for submission of select Returns, details of online portals for submission of returns by Supervised Entities.
Let’s start by familiarizing ourselves with several terms that are used frequently in the Master direction.
Supervised Entities:
Entities which are being governed under this Master direction are referred to as Supervised Entities.
1. Commercial Banks* – Public Sector Banks (PSBs), Private Sector Banks (PVBs), Small Finance Banks (SFBs), Payment Banks (PBs), Local Area Banks (LABs) and Foreign Banks (FBs).
2. Primary (Urban) Co-operative Banks.
3. All India Financial Institutions (Exim Bank, NABARD, NHB, SIDBI and NABFID).
4. Non-Banking Financial Companies engaged in the business of financial institutions as contained in clause (f) of Section 45 I of the RBI Act, 1934*
*Note: Regional Rural Banks, Housing Finance Companies (HFCs)], and all Asset Reconstruction Companies (ARCs) are excluded from the ambit of this circular.
Supervisory Returns refer to all periodic/ad-hoc data submitted to RBI in formats prescribed from time to time.
CRILC refers to a database, i.e., Central Repository of Information on Large Credits (CRILC) as specified in the framework ‘Early Recognition of Financial Distress, Prompt Steps for Resolution and Fair Recovery for Lenders.
CIMS refers to an online platform, i.e., Centralized Information Management System of the RBI for return submission, data dissemination and other related purposes.
The Circular has provided timelines for submission of returns w.r.t each of the supervised entities specifically under Annexure III.
We will focus on submission of returns by NBFCs under this Article.
This circular repeals Master Direction- Non-Banking Financial Company Returns (Reserve Bank) Directions, 2016 dated September 29, 2016.
As per RBI’s notification DoR.FIN.REC.No.45/03.10.119/2023-24 dated October 19, 2023 (Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023), the Regulatory structure for NBFCs shall comprise of four layers. Accordingly, the schedule of returns for NBFCs has been revised to reflect the applicability of these four layers and the revised framework. The revised applicability is as follows:
| Sr. No. | Return Name | Periodicity | Reference Date | Timeline for submission |
| 1. | DNBS10 Statutory Auditor’s Certificate (SAC) Return
The certificate shall be based on audited books of accounts of the applicable entity, for the preceding financial year. |
Yearly | 31st March [Within 5 working days from the date of signing of the Auditor’s report in terms of section 134 of the Companies Act, 2013, but not later than December 31st of same year, in any case]. | All NBFCs |
| 2. | Form A Certificate
The certificate to be submitted by NBFCs regarding appointment of Statutory Central Auditor (SCA)/ Statutory Auditor (SA) in prescribed format as mentioned in the RBI’s notification on ‘Appointment of Statutory Central Auditors (SCAs)/Statutory Auditors (SAs) of Commercial Banks (excluding RRBs), UCBs and NBFCs (including HFCs)’ |
Yearly | 31st March [Within one month from the date of appointment of Statutory Central Auditor (SCA) / Statutory Auditor (SA)]. | All NBFCs |
–
| Sr. No. | Return Name | Periodicity | Reference Date | Applicability |
| 1. | DNBS01
The return contains components of assets and liabilities, profit and loss account, exposure to sensitive sectors, sectoral credit etc. |
Quarterly | 31st March/ 30th June/ 30th September/ 31st December | NBFC – Upper Layer (NBFC-UL), NBFC – Middle Layer (NBFC-ML) [except NBFC-Core Investment Companies (CICs)] |
| 2. | DNBS02
The return contains financial details, viz. components of assets and liabilities, profit, and loss account etc. as well as for complying with various prudential norms. |
Quarterly | 31st March/ 30th June/ 30th September/ 31st December | NBFCs in Base Layer [except Peer-to-Peer Lending platform Companies (NBFC – P2Ps)] |
| 3. | DNBS03
The return contains prudential norms, e.g., capital adequacy, provisioning etc. |
Quarterly | 31st March/ 30th June/ 30th September/ 31st December | NBFC-UL, NBFC -ML [except NBFC-CICs] |
| 4. | DNBS04A
Return on Short Term Dynamic Liquidity |
Quarterly | 31st March/ 30th June/ 30th September/ 31st December | NBFC-UL, NBFC-ML [except Standalone Primary Dealers (SPDs)], and
iii. NBFC-BL with asset size of ₹100 crore and above solely or at Group level, [excluding Type-I NBFCs, and Non-Operative Financial Holding Companies (NOFHCs), P2Ps, AAs, and Mortgage Guarantee Companies] |
| DNBS04B
Return on Structural Liquidity and Interest Rate Sensitivity. |
Monthly | 31st March/ 30th April/ 31st May/ 30th June/ 31st July/ 31st August/ 30th September/ 31st October/ 30th November/ 31st December/ 31st January/ 28th or 29th February as applicable | NBFC-UL, NBFC-ML [except Standalone Primary Dealers (SPDs)], and NBFC-BL with asset size of ₹100 crore and above solely or at Group level, [excluding Type-I NBFCs, and Non-Operative Financial Holding Companies (NOFHCs), P2Ps, AAs, and Mortgage Guarantee Companies] | |
| 5. | DNBS08 CRILC-Main (NBFCs)
The return contains certain credit information in respect of borrowers who are having aggregate exposure of ₹5 Crore and above with NBFCs |
Monthly | 31st March/ 30th April/ 31st May/ 30th June/ 31st July/ 31st August/ 30th September/ 31st October/ 30th November/ 31st December/ 31st January/ 28th or 29th February as applicable | NBFC-UL, NBFC -ML (except NBFC-CICs), and NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above solely or at Group level |
| 6. | DNBS09-CRILC Weekly – RDB return.
NBFCs may report certain information on large borrowers (having aggregate exposure of ₹5 crores and above with them), in case they do not have large borrower with default move-in/ move-out positions, it shall submit a ‘NIL’ return. |
Weekly | Friday of the Week | NBFC-UL, NBFC -ML (except NBFC-CICs), and NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above solely or at Group level |
| 8. | DNBS11-CIC’s | Quarterly | 31st March/ 30th June/ 30th September/ 31st December | NBFC-CICs |
| 9. | DNBS12-CICs – Important Prudential Parameters | Quarterly | 31st March/ 30th June/ 30th September/ 31st December | NBFC-CICs |
| 10. | DNBS13 – Overseas Investment Details | Quarterly | 31st March/ 30th June/ 30th September/ 31st December | All NBFCs |
| 11. | DNBS14- P2Ps– Important Financial & Prudential Parameters | Quarterly | 31st March/ 30th June/ 30th September/ 31st December | NBFCs- Peer-to-Peer Lending platform Companies (NBFCs-P2P) |
| 12. | FMR – I (Report on Actual or Suspected Frauds) | On occurrence of such event | As and when the fraud is detected.
(Within three weeks from the Reference Date.) |
NBFC-UL, NBFC -ML, and NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above |
| 13. | FMR – III (Update of Form FMR-I)
This return captures progress report on frauds of large value and it is to be filed as and when any development occurs in FMR-I details. |
On occurrence of such event | As and when any development occurs in FMR-1 details.
(Immediate). |
NBFC-UL,
NBFC -ML, and NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above |
| 14. | FMR – IV (Report on Dacoities / Robberies / Theft / Burglaries)
This return captures consolidated information on dacoities/robberies /theft/ burglaries. |
Quarterly | 31st March/ 30th June/ 30th September/ 31st December (Within 15 days from the Reference Date). | NBFC-UL, NBFC -ML, and NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above |
RBI has introduced various online portals for filing of all the applicable online returns by the SEs. Each SE is provided with a Super User Credential with defined access rights who, in turn, can create other users (with different roles such as Maker and Checker) for their entity with required access rights. Entities can monitor the status of their returns’ submission on the portal. Form A Certificate is to be submitted by NBFC’s in physical form.
Conclusion: The RBI’s latest directions on the filing of supervisory returns mark a significant enhancement in the regulatory framework for NBFCs and other supervised entities. By consolidating reporting requirements and specifying clear timelines and online submission protocols, these directions are set to significantly improve the ease and efficiency of compliance. The introduction of a structured online platform for submissions further aids in ensuring accuracy and timeliness in regulatory reporting. As entities adapt to these changes, the overarching goal remains to foster a more transparent, accountable, and stable financial environment. This initiative reflects the RBI’s commitment to leveraging technology and streamlined processes to enhance regulatory oversight and support the dynamic landscape of India’s financial services sector.
*****
Disclaimer: This article provides general information existing at the time of preparation and we take no responsibility to update it with the subsequent changes in the law. The article is intended as a news update and Affluence Advisory neither assumes nor accepts any responsibility for any loss arising to any person acting or refraining from acting as a result of any material contained in this article. It is recommended that professional advice be taken based on specific facts and circumstances. This article does not substitute the need to refer to the original pronouncement.
Author Bio
