Compliance
NBFC compliance checklist: what is required, by how often it is required
CS Manoj Famra · 2026-10-09 · 10 min read (estimated)
Most compliance checklists are arranged by subject — returns here, KYC there, governance somewhere below. That is how the law is written and it is not how the work is done. The question a compliance officer actually has on a Monday morning is what falls due this week, and a list arranged by subject cannot answer it without being read end to end.
So this one is arranged by frequency. Each item names the direction it comes from and that direction's date, because a compliance list without sources is an assertion, and an NBFC cannot file an assertion.
One thing to settle before the list. If you are working from a checklist written before
27 February 2024, its filing deadlines are wrong. On that date the Reserve Bank issued the
[Master Direction — Reserve Bank of India (Filing of Supervisory Returns) Directions,
2024](https://www.rbi.org.in/scripts/BS_ViewMasDirections.aspx?id=12613)
(RBI/DoS.DSG/2023-24/110 and DoS.DSG.No.10/33.01.001/2023-24), which repealed the Master
Direction — Non-Banking Financial Company Returns (Reserve Bank) Directions, 2016 and harmonised
every timeline in it. Several widely-circulated calendars still carry the pre-2024 dates.
What the frequency rule actually is
This is the part worth memorising, because once you have it you can date any return without looking anything up. Paragraph 4.4 of the 2024 Directions sets the timeline by periodicity, not by return:
| Periodicity | Reference date | Due |
|---|---|---|
| Weekly | Friday of the week | "On or before Wednesday of the following week" |
| Fortnightly | 15th and last day of the month | "Within 7 days from the Reference Date" |
| Monthly | Last day of the month | "Within 15 days from the Reference Date" |
| Quarterly | Last day of the calendar quarter | "Within 21 days from the Reference Date" |
| Half-yearly | 31 March and 30 September | "Within 21 days from the Reference Date" |
| Yearly | 31 March | "Within 21 days from the Reference Date" |
Two riders. Audited returns are due "within 5 working days from the date of signing of the Auditor's report". And paragraph 4.4.2 provides alternate timelines for the returns listed in Annex IV, which override the table above — the Statutory Auditor Certificate is one of them, and it is dealt with under Annual below.
The quarterly figure is the one most often got wrong. It is 21 days, not 15. It was 15 before February 2024 for most of these returns, and that is why the older calendars disagree.
Weekly
DNBS09 — CRILC Weekly (RDB return). Large borrowers who defaulted, or came out of default, during the week. Reference date is the Friday; due on or before the Wednesday following.
Who files it: NBFC-Upper Layer; NBFC-Middle Layer except CICs; and NBFC-Base Layer entities that are ICCs, MFIs or Factors with asset size of ₹500 crore and above. A Base Layer NBFC below that threshold does not file it at all.
Monthly
DNBS04B — Structural Liquidity and Interest Rate Sensitivity. Due within 15 days of month end.
DNBS08 — CRILC-Main. Credit information on borrowers with aggregate exposure of ₹5 crore and above. Due within 15 days of month end. Same applicability as DNBS09.
Credit information reporting to the credit information companies. This one is not in the Supervisory Returns Directions — it sits under the Credit Information Companies (Regulation) Act, 2005 and the directions made under it, and its cadence was tightened to a fortnightly minimum by the Reserve Bank in 2024. Check the current cadence against the CIC directions before relying on a monthly assumption; it is the single most commonly out-of-date line in circulating checklists, and I have not verified the current text for this page.
Quarterly
Reference date is the quarter end — 30 June, 30 September, 31 December, 31 March — and the return is due within 21 days. So: 21 July, 21 October, 21 January, 21 April.
Which return you file depends on your layer, and that is the whole of the design:
| Return | Covers | Who files |
|---|---|---|
| DNBS01 | Assets and liabilities, profit and loss, sensitive-sector and sectoral exposure | NBFC-UL and NBFC-ML, except CICs |
| DNBS02 | Financial details and compliance with prudential norms | NBFCs in the Base Layer, except P2Ps |
| DNBS03 | Prudential parameters — capital adequacy, provisioning | NBFC-UL and NBFC-ML, except CICs |
| DNBS04A | Short Term Dynamic Liquidity | NBFC-UL; NBFC-ML except standalone primary dealers; NBFC-BL with asset size ₹100 crore and above |
| DNBS11 / DNBS12 | CIC financial and prudential parameters | NBFC-CICs |
| DNBS13 | Overseas investment details | All NBFCs — and a NIL return is required where there are none |
| DNBS14 | P2P financial and prudential parameters | NBFC-P2Ps |
| FMR-IV | Dacoities, robberies, theft, burglaries | Same applicability as FMR-I |
DNBS02 is the one to get right if you are a Base Layer NBFC, and it is also the one the stale calendars misstate most often. Under the 2024 Directions it is quarterly, within 21 days. Before February 2024 it was an annual return due within 60 days. Two widely-cited filing guides still describe it the old way, and they contradict each other.
DNBS13 catches people out because a NIL return is still a return. An NBFC with no overseas investment has a quarterly filing obligation it may not know about.
Half-yearly
Reference dates 31 March and 30 September, due within 21 days.
Annual
DNBS10 — Statutory Auditor Certificate (SAC). Reference date 31 March. This is an Annex IV return, so the alternate timeline applies: due within 5 working days of the date of signing of the auditor's report under section 134 of the Companies Act, 2013 — and in any case not later than 31 December of the same year. Filed by the statutory auditor. Applies to all NBFCs and ARCs of ₹500 crore and above.
Form A Certificate. Certificate on appointment of the Statutory Central Auditor or Statutory Auditor. Reference date 31 March, and the Annex IV timeline is within one month of the date of appointment. All NBFCs.
As and when it happens
FMR-I — report on actual or suspected frauds. Annex IV timeline: within three weeks of the date of detection. NBFC-UL, NBFC-ML, and Base Layer ICCs, MFIs and Factors of ₹500 crore and above.
FMR-III — update of FMR-I. Due immediately on a progress update.
The standing obligations that are not returns
A return is a thing you file. These are things that must be true continuously, and an inspection tests them by asking for the document and the board resolution behind it.
Know Your Customer. The governing text for an NBFC is now the Non-Banking Financial Companies — Know Your Customer Directions, 2025, dated 28 November 2025 (RBI/DOR/2025-26/361). It applies to all categories of NBFC across all layers unless otherwise specified, and does not apply to an NBFC with no customer interface. It was amended on 29 December 2025 (RBI/2025-26/160), which added an explanation to paragraph 63 on responsibility for records in the Central KYC Records Registry: the regulated entity that last uploaded or updated a customer's KYC information in CKYCR is responsible for verifying identity and address, and an NBFC that downloads and relies on such a record need not re-verify, where the record is current and compliant with the PML Act and Rules.
If your KYC policy still cites the 2016 Master Direction, that is the thing to look at first. I have not verified from the 2025 Directions' own repeal clause whether the 2016 NBFC KYC direction was expressly repealed or superseded — the Reserve Bank's repeal of the equivalent commercial bank direction on the same date is clearly documented, but the NBFC position I could not confirm from primary text. Confirm it before amending a policy document on the strength of this paragraph.
Scale Based Regulation. The framework an NBFC's obligations hang off is the Master Direction — Reserve Bank of India (Non-Banking Financial Company — Scale Based Regulation) Directions, 2023 (RBI/DoR/2023-24/106, DoR.FIN.REC.No.45/03.10.119/2023-24), dated 19 October 2023 and updated as on 17 July 2025, issued in supersession of the 2016 NBFC-NSI and NBFC-SI/Deposit-taking directions. Your layer decides which of the returns above you file, and the applicability column in each table is unreadable without knowing it.
I have deliberately not reproduced the Net Owned Fund threshold, the CRAR minimum or the layer placement criteria here. They are in the Directions' PDF, which I did not read for this page, and every figure for them that circulates in secondary sources is one I could not verify. A wrong capital figure in a compliance checklist is worse than an absent one.
Asset classification and income recognition. Classification is computed in the day-end process for the relevant date, and an NPA is upgraded only when the entire arrears of interest and principal are paid — RBI/2021-2022/125, DOR.STR.REC.68/21.04.048/2021-22, dated 12 November 2021. That is covered at length in why an NPA figure run at 11am differs from the same figure at day-end.
Penal charges. A penal amount is a charge, not interest, and may not be capitalised — the April 2024 position, covered in penal charges are not interest.
The Key Facts Statement. What must be disclosed, and how the APR in it is built — the KFS requirement and what goes in the APR.
What this page does not cover, and why
- Companies Act and tax filings. An NBFC is a company and files AOC-4, MGT-7, DIR-3 KYC, TDS
returns and GST like any other. They are real obligations and they are not RBI's; a checklist that mixes them in without saying so produces the impression that the Reserve Bank sets the AGM date.
- Deposit-taking obligations. The returns above are the non-deposit position. A deposit-taking
NBFC has more, and the set differs enough that mixing them would mislead.
- HFCs. Housing Finance Companies are excluded from the 2024 Supervisory Returns Directions'
NBFC category. Their returns are a separate regime and nothing on this page applies to them.
- Anything I could not source. Noted inline above rather than paraphrased into confidence.
A note on sourcing
The scope, the repeal and the frequency table above were read from the Reserve Bank's own Master Directions page for the 2024 Directions. The Annex III return list — which return, who files it — was read from a verbatim reproduction of the Directions rather than from the Reserve Bank's own PDF. It is consistent with the primary page on every point the two overlap, but before you rely on an applicability threshold for a filing decision, open Annex III and check the row.
Regulation moves. Every direction cited here carries its date so you can tell how old this page is relative to what you are reading it against.
Frequently asked questions
Are quarterly NBFC returns due in 15 days or 21 days?
Twenty-one days from the reference date, under paragraph 4.4 of the RBI (Filing of Supervisory Returns) Directions, 2024. It was fifteen for most of these returns before 27 February 2024, which is why older checklists disagree — and why a calendar quoting fifteen days can be dated at a glance.
Which returns does a Base Layer NBFC actually file?
DNBS02 quarterly, DNBS13 quarterly including a NIL return where there are no overseas investments, and Form A annually on auditor appointment. DNBS04A and DNBS04B begin at an asset size of Rs 100 crore; the CRILC returns, the fraud returns and the Statutory Auditor Certificate begin at Rs 500 crore. Below those thresholds the rows do not apply.
Does an NBFC with no overseas investment still file DNBS13?
Yes. A NIL return is required. It is the obligation most often missed, for the obvious reason that there is nothing to report.
Do these obligations apply to a Housing Finance Company?
No. HFCs are excluded from the NBFC category in the 2024 Directions, and their returns are a separate regime.
Related: RBI compliance for NBFCs · NBFC category and layer · Scale based regulation layers
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