TL;DR
- An NBFC compliance checklist has four parts: RBI supervisory returns filed on CIMS under the Supervisory Returns Directions 2026, prudential and governance duties under the Scale Based Regulation Directions 2025, KYC and FIU-IND reporting, and the annual Companies Act filings.
- Monthly returns are due within 15 days and quarterly returns within 21 days, and at least 20% of net profit goes to the statutory reserve each year.
Quick Answer: An NBFC compliance checklist is the list of RBI returns, prudential and governance duties, KYC reports and Companies Act filings an NBFC must meet. Under the Supervisory Returns Directions 2026, monthly returns are due within 15 days and quarterly returns within 21 days. At least 20% of net profit goes to the statutory reserve each year.
The Reserve Bank of India (RBI) replaced most non-banking financial company (NBFC) Master Directions with consolidated Directions on 28 November 2025 and 31 July 2026. Any checklist built before those dates cites repealed instruments and older return names. This checklist uses the text in force on 28 October 2026.
NBFC compliance checklist at a glance
| Part | What it covers | Current source |
|---|---|---|
| RBI returns | DNBS-series returns filed on CIMS, by layer | Supervisory Returns Directions 2026 |
| Prudential | Layer, net owned fund, statutory reserve | Scale Based Regulation Directions 2025; RBI Act s.45-IC |
| Governance | Compliance function, CCO, Fair Practices Code, Internal Ombudsman | Compliance Function Directions 2026 and related Directions |
| KYC and AML | Customer due diligence, periodic updation, reports to the Financial Intelligence Unit-India (FIU-IND) | NBFC KYC Directions 2025; PML Rules 2005 |
| Company law | AGM, financial statements, annual return, auditor | Companies Act 2013 |
Which RBI Returns Does an NBFC File and When Are They Due?
Every NBFC except an HFC files supervisory returns under the Supervisory Returns Directions 2026, dated 31 July 2026. Returns go on CIMS, RBI's Centralised Information Management System. Paragraph 21 lists them and paragraph 22 sets the timelines.
| Return | Who files | Periodicity | Due |
|---|---|---|---|
| DNBS-01 Important Financial Parameters | Upper and Middle Layer, except CICs | Quarterly | Within 21 days |
| DNBS-02 Important Financial Parameters | Base Layer, except P2P | Quarterly | Within 21 days |
| DNBS-03 Important Prudential Parameters | Upper Layer; Middle Layer except CICs and SPDs | Quarterly | Within 21 days |
| DNBS-04A Short Term Dynamic Liquidity | Upper and Middle Layer, and Base Layer of ₹100 crore and above, with exclusions | Quarterly | Within 21 days |
| DNBS-04B Structural Liquidity and Interest Rate Sensitivity | Same as DNBS-04A | Monthly | Within 15 days |
| CRILC (DNBS-08) | Upper and Middle Layer except CICs; Base Layer ICC, MFI and Factor of ₹500 crore and above | Monthly | Within 15 days |
| DNBS-09 Return on Defaulted Borrowers | Same as CRILC | Weekly | By the Wednesday of the following week |
| DNBS-10 Statutory Auditor Certificate | All NBFCs, filed by the statutory auditor | Yearly | Within 5 working days of the audit report, and no later than 31 December |
| DNBS-13 Overseas Investment Details | All NBFCs, with a NIL return if none | Quarterly | Within 21 days |
| Fraud Monitoring Return | Upper and Middle Layer, and Base Layer of ₹500 crore and above | As and when | Within 14 days |
| FMR-4 | Same as the Fraud Monitoring Return | Quarterly | Within 15 days |
| Form A Certificate | All NBFCs | Yearly | Within one month of the statutory auditor's appointment |
Older names such as NBS-1 and NBS-7 no longer appear on RBI's list of returns, which now uses the DNBS series alongside returns such as CRILC and FMR.
Which Prudential and Governance Obligations Apply Under Scale Based Regulation?
The layer decides most of them. The Scale Based Regulation Directions 2025, updated as on 1 July 2026, place non-deposit-taking NBFCs below ₹1,000 crore in the Base Layer and those of ₹1,000 crore and above in the Middle Layer. Since 24 June 2026, NBFCs with assets of ₹1,00,000 crore and above are identified by RBI for the Upper Layer under paragraph 24, with a 24-month transition.
Which Prudential Items Go on the Checklist?
- Statutory reserve: at least 20% of net profit each year, before any dividend, under section 45-IC of the RBI Act 1934. A withdrawal is reported to RBI within 21 days.
- Net owned fund: ₹10 crore by 31 March 2027 for investment and credit companies, MFIs and factors, on the glide path in paragraphs 39 to 42.
- 2026 exemption: from 1 July 2026, qualifying NBFCs with no public funds, no customer interface and assets below ₹1,000 crore are exempt from sections 45-IA and 45-IC.
Which Governance Items Go on the Checklist?
Middle and Upper Layer NBFCs must run a compliance function with a Chief Compliance Officer under the Compliance Function Directions 2026, explained in the guide to NBFC Chief Compliance Officer rules. NBFCs with a customer interface adopt a Board-approved Fair Practices Code. An Internal Ombudsman is required for deposit-taking NBFCs with 10 or more branches, and for non-deposit-taking NBFCs with assets of ₹5,000 crore or more and a public customer interface. HFCs, CICs, IDF-NBFCs, IFCs, NOFHCs, primary dealers and MGCs are excluded from both limbs.
Which KYC and FIU-IND Items Go on the Checklist?
| Item | Requirement | Provision |
|---|---|---|
| Periodic KYC updation | At least every 2, 8 or 10 years for high, medium or low risk | Para 42(1), NBFC KYC Directions 2025 |
| Designated Director and Principal Officer | Appointed, with details to FIU-IND and RBI | Paras 14 and 15 |
| Cash transaction report | By the 15th of the succeeding month | Rule 8(1), PML Rules 2005 |
| Suspicious transaction report | Promptly, once the Principal Officer is satisfied | Rule 8(2), PML Rules 2005 |
Which Annual ROC Filings Does an NBFC Company Make?
An NBFC incorporated as a company also files under the Companies Act 2013, on the same timeline as any other company.
| Filing | Deadline | Provision |
|---|---|---|
| Annual general meeting | Within six months of the financial year end, so by 30 September | Section 96(1) |
| Financial statements (Form AOC-4) | Within 30 days of the AGM | Section 137(1) |
| Annual return (Form MGT-7 or MGT-7A) | Within 60 days of the AGM | Section 92(4) |
| Auditor appointment (Form ADT-1) | Within 15 days of the meeting that appoints the auditor | Fourth proviso to section 139(1) |
The general ROC compliance for a private limited company applies alongside, as does the DIR-3 KYC cycle for each director.
What Does a Month-by-Month NBFC Compliance Calendar Look Like?
Most RBI items recur on a fixed clock, so the calendar is built from periodicity rather than from fixed dates.
| When | Items |
|---|---|
| Every week, by Wednesday | DNBS-09 Return on Defaulted Borrowers, where applicable |
| By the 15th of each month | Monthly returns such as DNBS-04B and CRILC; cash transaction report to FIU-IND |
| Within 21 days of each quarter end | DNBS-01 or DNBS-02, DNBS-03, DNBS-04A and DNBS-13 |
| By 30 September | Annual general meeting for a March year end |
| Within 30 and 60 days of the AGM | Form AOC-4, then Form MGT-7 or MGT-7A |
| Within 5 working days of the audit report (31 December at the latest) | DNBS-10 statutory auditor certificate |
| Each financial year end | Transfer of at least 20% of net profit to the statutory reserve |
Tax deductions add their own quarterly cycle, set out in the TDS return due dates.
How Is an NBFC Checklist Kept Current?
By re-checking the source behind each line whenever RBI amends a Direction, which in 2026 has happened several times. A compliance management platform holds each line as an obligation with an owner, a due date and the CIMS or Registrar of Companies (ROC) acknowledgement as evidence. The features such a system needs are covered in the guide to NBFC compliance software.
LexComply does not file returns with RBI, FIU-IND or the Registrar; the NBFC files them. You can get in touch to see how a checklist like this one would be tracked.
Common Mistakes to Avoid
- Copying a pre-2026 checklist. The Supervisory Returns Directions 2026 and the Compliance Function Directions 2026, both of 31 July 2026, replaced the earlier instruments.
- Still filing under NBS-1 or NBS-7. RBI's list of returns now carries the DNBS series, filed on CIMS.
- Using parametric scoring for the Upper Layer. Paragraph 24 of the SBR Directions, as substituted on 24 June 2026, sets the Upper Layer at ₹1,00,000 crore of assets.
- Filing ADT-1 after every AGM. The fourth proviso to section 139(1) ties it to the meeting that appoints the auditor.
- Counting days for STRs. Rule 8(2) of the PML Rules requires suspicious transactions to be reported promptly.
- Applying the Internal Ombudsman test by branches alone. The 10-branch test applies to deposit-taking NBFCs; others are tested at ₹5,000 crore of assets with a public customer interface.
Legal Disclaimer
This article is general information on Indian financial regulation and company law, current as at the date shown above. It is not legal advice and does not take account of any particular NBFC's facts. Obtain professional advice before acting on any position described here.