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RBI returns for NBFCs: which return, who files it, and what each one is built from

CS Manoj Famra · 2026-10-09 · 8 min read (estimated)

Three questions get conflated whenever NBFC returns are written about: which returns exist, which ones apply to me, and where do the figures come from. They have different answers and the third is the one that costs time, because a return is not a form — it is an assertion about the books, and the books have to be able to produce it twice and get the same answer.

This page takes the returns one at a time. Applicability and timing come from the Reserve Bank's 2024 Directions. The note on what each return is built from is an operational observation, not a regulatory requirement, and is marked as such.

The governing text, and the date that matters

Master Direction — Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 — RBI/DoS.DSG/2023-24/110 and DoS.DSG.No.10/33.01.001/2023-24, dated 27 February 2024.

What it did:

  • Repealed the Master Direction — Non-Banking Financial Company Returns (Reserve Bank)

Directions, 2016, and the clauses listed in its Annex II.

  • Consolidated around twenty scattered reporting instructions into one document.
  • Harmonised the filing timelines. Most quarterly DNBS returns moved from 15 days to 21 days

from the reference date. DNBS04B moved from 10 days to 15. And DNBS02 moved from annual within 60 days to quarterly within 21 days — the single biggest change for a Base Layer NBFC.

  • Applies to all NBFCs. Housing Finance Companies are excluded, as are Regional Rural Banks from

the bank category.

If a filing guide describes DNBS02 as annual, it is describing the position before February 2024. Two of the most-cited ones still do, and they disagree with each other.


Every return, and who has to file it

Financial and prudential — the core set

DNBS01 — Important Financial Parameters. Quarterly, within 21 days. Assets and liabilities, profit and loss, sensitive-sector exposure and sectoral credit. Applies to: NBFC-Upper Layer and NBFC-Middle Layer, except CICs.

Built from: the trial balance, plus a sectoral classification of the loan book. The sectoral split is the part that is rarely a report and usually a spreadsheet — it needs every loan to carry a classification at origination, because deriving it afterwards from purpose text is guesswork.

DNBS02 — Important Financial Parameters (NBFCs – BL). Quarterly, within 21 days. Financial details and compliance with prudential norms. Applies to: NBFCs in the Base Layer, except P2Ps.

Built from: the trial balance and the asset classification register. If you are a Base Layer NBFC this is your return, and the frequency change in 2024 is the one to diarise.

DNBS03 — Important Prudential Parameters. Quarterly, within 21 days. Prudential norms — capital adequacy, provisioning. Applies to: NBFC-UL and NBFC-ML, except CICs.

Built from: the asset classification at the quarter-end day-end position, and the provision computed on it. Classification is a day-end event (RBI/2021-2022/125, 12 November 2021), so a provisioning figure recomputed at 11am on a later date will not reproduce the number you filed. The quarter-end position has to be retained, not recalculated — why that matters.

Liquidity

DNBS04A — Short Term Dynamic Liquidity (STDL). Quarterly, within 21 days. Applies to: NBFC-UL; NBFC-ML except standalone primary dealers; and NBFC-BL with asset size of ₹100 crore and above, solely or at group level. Excludes Type-I NBFCs, NOFHCs, P2Ps, Account Aggregators and Mortgage Guarantee Companies.

DNBS04B — Structural Liquidity and Interest Rate Sensitivity. Monthly, within 15 days. Same applicability as DNBS04A.

Built from: projected cash flows by bucket. Which means contractual repayment schedules, not balances — a system that stores only outstanding amounts cannot produce this without rebuilding every schedule.

Credit information

DNBS08 — CRILC-Main. Monthly, within 15 days. Credit information on borrowers with aggregate exposure of ₹5 crore and above. Applies to: NBFC-UL; NBFC-ML except CICs; and NBFC-BL entities that are ICC, MFI or Factors with asset size of ₹500 crore and above.

DNBS09 — CRILC Weekly (RDB return). Weekly — reference date Friday, due on or before the Wednesday following. Large borrowers who defaulted, or moved out of default, during the week. Same applicability as DNBS08.

Built from: exposure aggregated per borrower across accounts, not per account. A borrower with four facilities below the threshold individually can cross ₹5 crore in aggregate, and the return is about the borrower.

Core Investment Companies

DNBS11 — Important Financial Parameters. Quarterly, within 21 days. NBFC-CICs. DNBS12 — Important Prudential Parameters. Quarterly, within 21 days. Adjusted net worth, provisioning. NBFC-CICs.

Overseas investment

DNBS13 — Overseas Investment Details. Quarterly, within 21 days. All NBFCs — and a NIL return is required where there are no overseas investments.

This is the return most often missed, for the obvious reason: an NBFC with nothing to report assumes there is nothing to file.

Peer-to-peer

DNBS14 — P2Ps. Quarterly, within 21 days. Financial and prudential parameters. NBFC-P2Ps.

Asset Reconstruction Companies

DNBS07 — ARCs Important Financial Parameters. Quarterly, within 21 days. Assets and liabilities, acquired assets, recovery status. ARCs only — included here because ARCs are covered by the same Directions.

Audit certificates

DNBS10 — Statutory Auditor Certificate (SAC). Yearly, reference date 31 March. Annex IV timeline: within 5 working days of the date of signing of the auditor's report under section 134 of the Companies Act, 2013, and not later than 31 December. Filed by the statutory auditor. Applies to: all NBFCs and ARCs of ₹500 crore and above.

Form A Certificate. Annual, reference date 31 March. Certificate on appointment of the Statutory Central Auditor / Statutory Auditor. Annex IV timeline: within one month of the date of appointment. All NBFCs.

Fraud and incident

FMR-I — actual or suspected frauds. As and when detected; 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. Immediately on a progress update. Same applicability. FMR-IV — dacoities, robberies, theft, burglaries. Quarterly. Same applicability.

Also listed

Financial Soundness Indicators (FSI). Quarterly. Consolidated indicators furnished to the IMF.


The two thresholds worth writing on a wall

Almost every applicability question above reduces to these:

  • ₹100 crore — DNBS04A and DNBS04B begin to apply to a Base Layer NBFC.
  • ₹500 crore — the CRILC returns (DNBS08, DNBS09), the fraud returns (FMR-I, III, IV) and the

Statutory Auditor Certificate begin to apply.

Below ₹100 crore, a Base Layer NBFC's return set is small: DNBS02 quarterly, DNBS13 quarterly including NIL, Form A annually, and nothing else from the list above.

What makes a return hard, and it is not the form

Three figures cause most of the re-work, and all three are about the shape of the records rather than the filing:

  1. The quarter-end classification has to be retained. Classification is computed in the day-end

process; re-deriving it from today's balances produces a different number. If the only way to get the figure you filed is to recompute it, you cannot defend it.

  1. Exposure aggregates per borrower. CRILC is borrower-level. Account-level books have to be able

to roll up by borrower identity, which is a data question that has to be answered at onboarding.

  1. The sectoral split has to exist at origination. DNBS01 wants sectoral credit. Inferring it

afterwards from free-text purpose fields is the single most common source of a return that cannot be reproduced.

A longer treatment of the systems side — why a return assembled in a spreadsheet eventually disagrees with the ledger — is in how to generate RBI returns without re-keying the book.

Sourcing

Scope, repeal and the periodicity timelines were read from the Reserve Bank's own Master Directions page. The Annex III return list, its coverage descriptions and the applicability thresholds were read from a verbatim reproduction of the Directions rather than from the Reserve Bank's PDF. They agree with the primary page on every point the two overlap, and the structure matches. Before you rely on a threshold to decide whether a return applies to you, open Annex III and read the row.

The built from notes are operational observation, not regulation. Nothing in the Directions prescribes where a figure must come from inside your systems.

Written 9 October 2026.

Frequently asked questions

Is DNBS02 an annual or a quarterly return?

Quarterly, within 21 days of the quarter end. It moved from annual-within-60-days under the 2024 Supervisory Returns Directions, and it is the largest single change for a Base Layer NBFC. Two widely-cited filing guides still describe it the old way and contradict each other.

What asset-size thresholds decide which returns apply?

Two. Rs 100 crore brings DNBS04A and DNBS04B into play for a Base Layer NBFC; Rs 500 crore brings the CRILC returns, the fraud returns and the Statutory Auditor Certificate.

Is CRILC reported per account or per borrower?

Per borrower, aggregated across accounts, for exposures of Rs 5 crore and above. A borrower with four facilities each below the threshold can cross it in aggregate, which is why account-level books have to be able to roll up by borrower identity.

Why can a provisioning figure not be recomputed later?

Because classification is computed in the day-end process for the relevant date. A figure re-derived from today's balances will not reproduce the one filed, so the quarter-end position has to be retained rather than recalculated.


Related: NBFC compliance checklist · NBFC compliance calendar · NBFC category and layer · NBFC returns calendar tool

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