Get Your NBFC Compliance Managed with eFileSeva | We Help You Do It Right!
Running an NBFC after registration is a regulated responsibility. From the day you receive your Certificate of Registration (CoR), your company must comply with Chapter III-B of the RBI Act, 1934 (Sections 45-IA, 45-IB & 45-IC), RBI's Master Directions — including the Scale-Based Regulation (SBR) framework effective October 2022 (updated by the RBI's June 2026 Amendment Directions) — and the KYC/AML framework. The typical calendar includes the NBS-7 quarterly return within 15 days of the quarter end, the NBS-1 annual return, the Statutory Auditor's Certificate and ALM returns, the annual KYC return, Credit Information Company reporting, plus MCA filings such as AOC-4, MGT-7 and DIR-3 KYC and the full income-tax and GST cycle. eFileSeva helps NBFCs stay compliant and penalty-free — from the monthly and quarterly return engine to the statutory audit, board governance, and RBI inspection readiness.
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Key Details for NBFC Compliance
eFileSeva provides end-to-end NBFC compliance management — mapping your company to the right regulatory layer, operating the monthly/quarterly/annual return engine, coordinating the statutory audit and policy framework, and preparing you for RBI's inspection — across all NBFC categories, SBR layers, and RBI regional offices.
| # | Topic | Details |
|---|---|---|
| 1 | Choose the Right Compliance Regime | Mapping your NBFC to the correct compliance set is the first step — its SBR layer (Base / Middle / Upper), whether it accepts deposits, whether it is a CIC or NBFC-MFI/IFC, its asset size, and its group structure. eFileSeva prepares a tailored compliance calendar for your company. |
| 2 | Compliance Frequency |
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| 3 | Compliance Cost | The cost comprises professional fees for the compliance team — return preparation and filing, audit coordination, and governance support. RBI charges no filing fee for NBFC returns; the real cost of non-compliance is RBI's scrutiny and monetary penalties. eFileSeva provides transparent pricing with no hidden charges and a fixed-fee annual compliance retainer. |
| 4 | Regulatory vs Statutory Compliance | An NBFC faces a dual compliance burden: regulatory compliance with the RBI (returns, prudential norms, KYC/AML, governance) and statutory compliance with the MCA, Income-tax and GST authorities (audit, annual filings, taxes). Missing either set attracts separate penalties. |
| 5 | Key Returns & Forms | RBI: NBS-7 (quarterly), NBS-1 (annual), Statutory Auditor's Certificate (annual, not later than 31 December), ALM returns, branch information returns. MCA: AOC-4, MGT-7, DIR-3 KYC, ADT-1. Others: KYC annual return (KYC-AR), CIC data submission, TDS/ITR, GSTR-3B & GSTR-9. |
| 6 | Key Sections & Directions | Sections 45-IA, 45-IB and 45-IC of the RBI Act, 1934; RBI's Master Direction on KYC (2016) and prudential norms; the Scale-Based Regulation (SBR) Directions (October 2022, as amended — including the June 2026 Amendment Directions on Upper Layer identification); and the Fair Practices Code and digital-lending guidelines. |
| 7 | Governance Under SBR | Middle and Upper Layer NBFCs must appoint an independent Chief Compliance Officer (CCO), and NBFCs of the applicable size need audit and risk management committees, internal audit, and a board-approved policy set. NBFCs with asset size of ₹100 crore and above must appoint an Internal Ombudsman and are covered by RBI's Integrated Ombudsman Scheme (2021). |
| 8 | Compliance Management Services |
After the compliance set-up, eFileSeva assists with:
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*Deadlines are per RBI's Master Directions and may be updated by circular; the exact applicability depends on your NBFC's layer and asset size.
NBFC Compliance in India: Everything You Need to Know
Stay Compliant & Penalty-Free, Every Quarter
An NBFC's obligations begin on the day the Certificate of Registration is issued and never stop: Sections 45-IA, 45-IB and 45-IC of the RBI Act, 1934 require the company to maintain its net owned fund, prudential ratios and reserve fund, while RBI's Master Directions prescribe the KYC/AML framework, fair practices, reporting, and governance. Under the Scale-Based Regulation (SBR) framework — effective October 2022 and amended in June 2026 — obligations are calibrated to the company's layer and asset size.
At the heart of the compliance calendar is reporting through the COSMOS portal: the NBS-7 quarterly return on important financial parameters within 15 days of the quarter end, the annual NBS-1 return, ALM returns (short-term dynamic liquidity and structural liquidity/interest-rate sensitivity), the Branch Information Return, and the Statutory Auditor's Certificate — due one month from the finalisation of the balance sheet and not later than 31 December. NBFCs also file the annual KYC return, submit borrower data to at least one Credit Information Company, and comply with the anti-money-laundering reporting to FIU-IND.
On the statutory side, the Companies Act, 2013 requires the statutory audit, an AGM within 6 months of the year end, and filings of AOC-4 (30 days from the AGM), MGT-7 (60 days from the AGM), DIR-3 KYC and ADT-1, while the income-tax and GST cycle adds TDS, advance tax, the return of income and GSTR-3B/GSTR-9. Board governance — meetings, committees, policies such as KYC/AML, risk management and fair practices — completes the framework. Where the company's asset size crosses ₹100 crore, an Internal Ombudsman becomes mandatory, and Middle/Upper Layer NBFCs must appoint an independent Chief Compliance Officer.
eFileSeva helps you map the exact obligations of your NBFC, run the return engine, coordinate the audit, maintain the policy and governance framework, and stay inspection-ready — making NBFC compliance simple, timely, and fully compliant.
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Disclaimer
eFileSeva is a professional corporate compliance consultancy and service provider. We are not the Reserve Bank of India, the Ministry of Corporate Affairs, or the Registrar of Companies and do not approve returns, issue certificates, or conduct inspections. All approvals, acknowledgements, and regulatory actions are undertaken solely by the RBI, MCA, ROC, CBDT, CBIC, and the respective government authorities. Our role is to assist clients with consultation, documentation, return filing, audit coordination, and end-to-end process support.
Areas of NBFC Compliance We Manage
NBFC compliance is not a single filing — it is a continuous set of obligations across regulatory, statutory, taxation, and governance domains. Each area carries its own calendar, authority, and penalty risk. eFileSeva manages every area with a single accountable team.
RBI Returns & Reporting
The COSMOS engine — NBS-7 quarterly within 15 days, NBS-1 annual, ALM returns (short-term dynamic liquidity, structural liquidity), branch information return, and the annual Statutory Auditor's Certificate by 31 December.
Learn MoreStatutory Audit & Assurance
Coordination of the statutory audit under the Companies Act, 2013, the NOF and CRAR certifications, income-tax audit (Form 3CA-3CD where applicable), audit committee functioning, and internal audit arrangements per the SBR layer.
Learn MoreKYC, AML & PMLA
Implementation of RBI's KYC Master Direction (2016) — customer due diligence, CKYC reporting, the annual KYC return, suspicious/cash transaction reporting to FIU-IND, and the appointment of a Principal Officer for the AML framework.
Learn MoreGovernance & Board Framework
Board meeting management and minutes, the board-approved policy set (KYC, credit, risk, recovery, fair practices), committee compositions, the Chief Compliance Officer for Middle/Upper Layers, and the Internal Ombudsman for NBFCs with assets of ₹100 crore and above.
Learn MoreIncome-tax & GST
The complete tax cycle — monthly TDS compliance, advance tax instalments, the return of income (ITR-6), tax audit where thresholds apply, and GSTR-3B / GSTR-9 filings — with transfer-pricing reporting (Form 3CEB) where foreign investors or transactions exist.
Learn MoreMCA Filings & CIC Reporting
Corporate filings — AOC-4 (30 days from AGM), MGT-7 (60 days from AGM), DIR-3 KYC (by 30 September), ADT-1 — plus regular borrower-data submission to Credit Information Companies and changes in shareholding and directors.
Learn MoreNot Sure Which Compliance Obligations Apply to Your NBFC?
eFileSeva's experts will map your company to its SBR layer and build a complete, tailored compliance calendar in a single consultation.
Get Free ConsultationWho Needs NBFC Compliance & What Triggers It
Every NBFC with a Certificate of Registration has ongoing obligations, but the depth of compliance depends on specific triggers. eFileSeva helps you identify the triggers applicable to your company and complete the requirements without delays.
Hold a Valid Certificate of Registration
Every NBFC holding a CoR from RBI must comply with Chapter III-B of the RBI Act, 1934 and RBI's Master Directions — from the first quarter after registration. Non-compliant companies face RBI scrutiny, monetary penalties, and in serious cases, cancellation of the CoR under Section 45-IA.
SBR Layer — Base, Middle or Upper
Under the SBR Directions (October 2022, as amended in June 2026): the Base Layer covers non-deposit-taking NBFCs with assets below ₹1,000 crore; the Middle Layer covers NBFCs with assets of ₹1,000 crore and above and deposit-taking NBFCs; and the Upper Layer is now identified by asset size of ₹1,00,000 crore and above. Each layer carries progressively stricter obligations.
Deposit-Taking NBFC (NBFC-D)
An NBFC accepting public deposits carries the heaviest compliance load — maintenance of liquid assets (Section 45-IB), a reserve fund (Section 45-IC), an investment-grade credit rating, deposit returns and ALM reporting — over and above the standard prudential framework.
Asset-Size Thresholds
Asset size triggers several obligations: NBFCs of ₹100 crore and above need an Internal Ombudsman and enhanced ALM reporting, and can invoke SARFAESI for eligible secured loans; the ₹500 crore mark historically marked systemically important non-deposit-taking NBFCs, and may bring internal-audit and governance expectations in line.
Group / CIC / Specialised Status
A Core Investment Company, NBFC-MFI, NBFC-IFC or NBFC-Factor carries category-specific norms (e.g., 30% CRAR for a systemically important CIC; sectoral deployment ratios for IFCs), and group companies may trigger aggregation rules for asset-size tests.
Foreign Investment & Group Reporting
Foreign investors and overseas investments add FEMA reporting, transfer-pricing documentation (Form 3CEB where applicable), and the overseas-investment return to RBI — while any overseas subsidiary triggers additional consolidated reporting to the regulator.
Inspection & Supervisory Action
RBI's risk-based supervision may trigger an inspection, and any query, show-cause notice, or direction must be answered within the prescribed time. eFileSeva maintains the data room and supports the response process throughout any supervisory interaction.
Ready to Get Your NBFC Compliant?
eFileSeva's experts will map your obligations, build the compliance calendar, and manage every return and filing on time.
Get Started TodayDocuments Required for NBFC Compliance
The working documents vary by the return and the filing, but the core set below powers the entire compliance calendar. eFileSeva helps you verify and prepare them in a single, audit-ready file structure.
Financial & Audit Documents
- Audited financial statements and statutory auditor's report
- NOF certificate & CRAR computation sheet (quarterly)
- Loan register, NPA & provisioning statements, ALM data
- Register of fixed assets, investments and deposits
- Board minutes & resolutions supporting the financials
RBI Returns & Certificates
- Certificate of Registration (CoR) and COSMOS login credentials
- NBS-7 / NBS-1 data packs as prepared by the internal team
- Statutory Auditor's Certificate (DNBS-10) — signed & sealed
- Branch information and liquidity statements
- Income-tax and GST return acknowledgements
KYC, AML & Customer Records
- KYC records & CKYC details of all borrowers
- AML/CFT policy, risk classification & STR/CTR register
- Principal Officer & KYC compliance officer details
- CIC data submission reports (borrower-level)
- Grievance register & Internal Ombudsman records
Governance, Policies & Corporate Records
- Board-approved policies — KYC/AML, credit, risk, recovery & fair practices
- Committee charters (audit, risk) & meeting minutes
- Statutory registers (members, charges, directors) & AOC-4/MGT-7 files
- CCO / Internal Ombudsman appointment letters & compliance reports
Pro Tip
Build an audit-ready data room from day one — one folder per return, one register per policy — and reconcile the loan book, NPA classification and provisioning every month end, not quarter end. Track your asset-size triggers (₹100 crore — Internal Ombudsman & ALM reporting; ₹1,000 crore — Middle Layer) on a rolling basis, since they change your obligations. File NBS-7 within 15 days of the quarter end even if provisional, fix the auditor's certificate with a 31 December internal deadline, and keep the DIR-3 KYC calendar (30 September) separate from AOC-4/MGT-7 deadlines. Finally, minute every board decision on policy — RBI's inspections are decided on the paper trail.
The Annual NBFC Compliance Calendar
eFileSeva runs the NBFC compliance calendar for you, quarter after quarter. While exact dates depend on your layer and asset size, the following is a typical annual cycle for a non-deposit-taking NBFC.
April – June
File NBS-7 for Q4 (by 15 April), recompute NOF and CRAR, complete TDS/GST for the quarter, review provisioning, and kick off the statutory audit of the previous financial year.
July – September
Finalise audited financials, hold the AGM within 6 months of the year end, file AOC-4 (30 days from AGM) and DIR-3 KYC (by 30 September), and file NBS-7 for Q1 by 15 July.
October – December
File MGT-7 within 60 days of the AGM, the return of income (ITR-6), file NBS-7 for Q2 by 15 October, and close the Statutory Auditor's Certificate — not later than 31 December.
January – March
File NBS-7 for Q3 by 15 January, complete GSTR-9, run the annual KYC return, review policies, refresh the plan for the year ahead, and prep the data room for any RBI inspection.
Compliance Is Continuous
Unlike a one-time registration, NBFC compliance never stops — the calendar above runs every financial year, with quarterly NBS-7 due within 15 days of each quarter end and the annual audit, filings and certificates completing the cycle. eFileSeva runs the calendar on autopilot and flags every deadline with a checkpoint well in advance.
Process to Get Your NBFC Compliant
NBFC compliance is managed, not "done once". From mapping your obligations to running the return engine, coordinating the audit, and staying inspection-ready, eFileSeva provides complete support at every stage.
Compliance Health Check & Calendar Set-Up
We map your NBFC to its SBR layer and category, list every applicable return, filing, policy, and committee obligation, and deliver a year-round compliance calendar with owners and deadlines.
Monthly & Quarterly Return Engine
We run the recurring engine — NBS-7 within 15 days of the quarter end, ALM and liquidity statements, branch information return, CIC data submission, TDS and GST returns — from a single source of data.
Annual Audit & Financial Close
We coordinate the statutory audit, compute and certify NOF and CRAR, review provisioning and asset classification, and support the audit committee — ensuring the audited financials back every return.
Annual Filings & Certificates
We file the annual set — NBS-1, the Statutory Auditor's Certificate (before 31 December), the KYC return, plus AOC-4, MGT-7, DIR-3 KYC, ADT-1 and the income-tax return — and keep acknowledgements in the compliant data room.
Governance, Policies & Inspection Readiness
We maintain board minutes and policies, support the CCO and Internal Ombudsman setup, refresh the policy set with RBI updates, and keep the data room audit-ready for any RBI query, review, or inspection.
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NBFC Compliance Filings at a Glance
The table below summarises the core compliance universe of a typical non-deposit-taking NBFC. eFileSeva customises this list to your asset size, layer and category.
| Filing / Return | Frequency & Deadline | Applicable Law / Authority |
|---|---|---|
NBS-7 — Quarterly Important Financial ParametersReturn on Financial Parameters |
Quarterly — within 15 days of the quarter end (15 Apr / Jul / Oct / Jan), filed through COSMOS. | Reserve Bank of India RBI Master Directions / SBR |
NBS-1 — Annual Important Financial ParametersAnnual Return |
Annually — within 60 days of the close of the financial year (or on finalisation of audited financials), filed through COSMOS. | Reserve Bank of India RBI Master Directions |
Statutory Auditor's CertificateDNBS-10 — Auditor's Certificate |
Annually — one month from the finalisation of the balance sheet, not later than 31 December; signed and certified by the statutory auditor. | RBI / Statutory Auditor RBI Master Directions |
ALM Returns — Liquidity & Interest RateSTDL, Structural Liquidity, Interest-Rate Sensitivity |
Quarterly / monthly depending on asset size — short-term dynamic liquidity within 15 days of the quarter end; structural liquidity and interest-rate sensitivity at the prescribed intervals. | Reserve Bank of India RBI ALM Directions |
KYC Annual Return (KYC-AR)Annual KYC Compliance Reporting |
Annually — the KYC compliance return filed online with RBI in the prescribed format, with the KYC/AML framework of the NBFC. | Reserve Bank of India KYC Master Direction, 2016 |
Credit Information Company DataCRIF / CIBIL / Experian / Equifax Reporting |
Regular (typically monthly/quarterly) submission of borrower-level data to the CIC(s) of which the NBFC is a member. | RBI / Credit Bureaus CIC (Regulation) Act, 2005 |
MCA Filings — AOC-4, MGT-7, DIR-3 KYC, ADT-1Annual Corporate Compliance |
AOC-4 within 30 days of the AGM; MGT-7 within 60 days of the AGM; DIR-3 KYC by 30 September; ADT-1 within 15 days of the AGM. | Registrar of Companies Companies Act, 2013 |
Income-tax & GST — TDS, ITR-6, GSTR-3B / GSTR-9Tax Compliance Cycle |
TDS returns quarterly; advance tax in instalments; ITR-6 by 31 October (30 November for transfer-pricing cases); GSTR-3B monthly by the 20th; GSTR-9 annually by 31 December. | CBDT / CBIC Income-tax Act, 1961 & CGST Act, 2017 |
Regulatory Compliance vs Statutory Compliance: What's the Difference?
An NBFC answers to two distinct worlds. Regulatory compliance is RBI's supervision of the financial business; statutory compliance is the general corporate and tax law every company follows. Compare the key differences below.
| Feature | Regulatory (RBI) | Statutory (MCA / Tax) |
|---|---|---|
| 1. Authority | Reserve Bank of India — Department of Non-Banking Supervision (DNBS). | Registrar of Companies, Income-tax Department, GST authorities. |
| 2. Legal Basis | RBI Act, 1934 (Chapter III-B) and RBI Master Directions. | Companies Act, 2013; Income-tax Act, 1961; CGST Act, 2017. |
| 3. Focus | Financial parameters, prudential norms (CRAR, NOF), KYC/AML, governance, fair practices. | Corporate records, accounts and audit, taxes, statutory registers. |
| 4. Key Filings | NBS-7, NBS-1, ALM, Auditor's Certificate, KYC-AR, CIC data. | AOC-4, MGT-7, DIR-3 KYC, ADT-1, TDS/ITR, GSTR-3B/GSTR-9. |
| 5. Portals | COSMOS (and periodic XBRL reporting for the applicable categories). | MCA21, TRACES/IT portal, GST portal. |
| 6. Certification | Statutory auditor's certificate and CA-verified data packs. | Auditor's reports, tax auditor's report, director certifications. |
| 7. Penalties | RBI monetary penalties, restrictions, cancellation of the CoR. | Late fees & prosecution under the Companies Act; interest & penalties under tax laws. |
| 8. Cadence | Monthly, quarterly and annual — tied to the regulator's calendar. | Quarterly TDS, annual corporate filings, monthly/annual GST. |
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Find answers to common questions about NBFC compliance and staying penalty-free with eFileSeva.
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