NBFC Compliance

NBFC Return Filing Compliance Calendar- The Ultimate Guide

A Non-Banking Financial Company (NBFC) is a financial organization registered under the Companies Act of 2013 that provides loans and credit facilities to entrepreneurs and corporations.

Most common services include asset financing, leasing, and investment services. These entities are regulated by the Reserve Bank of India (RBI).

Like any other company in India, NBFCs also have certain compliance rules, such as return filings, which are governed by the RBI.

In this blog, we’ll cover the important dates for return filing for Non-Banking Financial Companies (NBFCs), key components of each form, responsibilities of entities, penalties, and instructions on filing.

Consolidated Return Calendar for Types of NBFCs

All reports must be filed through the designated RBI portal of the respective NBFC category.

Name of Return	Period of Return	Reference Deadline	Applicable To NBFCs
DNBS01- Important Financial Parameters	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	-upper layer (UL) -middle layer (ML), excluding core investment companies (CICs).
DNBS02- Important Financial Parameters (NBFCs- BL)	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	-base layer, excluding companies engaged in peer-to-peer digital lending platforms (P2Ps)
DNBS03- Important Prudential Parameters	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	-upper layer (UL) -middle layer (ML), except CICs
DNBS04A – Short Term Dynamic Liquidity (STDL)	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	-Upper layer (UL) -middle layer (ML), excluding standalone primary dealers (SPDs) -base layer (BL) with asset size of INR 100 crore and above/at a group level, except type-I NBFCs, non-operative financial holding companies (NOFHCs), and P2Ps, AAs, and mortgage guarantee companies.
DNBS04B- Structural Liquidity & Interest Rate Sensitivity- Monthly	Monthly	March 31st April 30th May 31st June 30th July 31st August 31st September 30th October 31st November 30th December 31st January 31st February 28th/29th as per the leap year.	-Upper layer (UL) -middle layer (ML), excluding standalone primary dealers (SPDs) -base layer (BL) with asset size of INR 100 crore and above/at a group level, except type-I NBFCs, non-operative financial holding companies (NOFHCs), and P2Ps, AAs, and mortgage guarantee companies.
DNBS08- CRILC-Main (NBFCs)	Monthly	March 31st April 30th May 31st June 30th July 31st August 31st September 30th October 31st November 30th December 31st January 31st February 28th/29th as per the leap year.	-Upper layer (UL) Middle layer (ML), excluding core investment companies (CICs). Base layer (BL) that are ICC, MFI, and Factors with asset size of INR 500 and above/at a group level.
DNBS09- CRILC Weekly- RDB Return	Weekly	Each Friday	-Upper layer (UL) -Middle layer (ML), except CICs – Base layer (BL) that are ICC, MFI, and Factors with asset size of INR 500 and above/at a group level.
DNBS10- Statutory Auditor Certificate (SAC) Return	Yearly	March 31st	All types of NBFCs and ARCs
DNBS11- CICs Important Financial Parameters	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	NBFC-CICs
DNBS12- CICs Important Prudential Parameters	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	NBFC-CICs
DNBS13- Overseas Investment Details	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	All kinds of NBFCs
DNBS14- P2Ps- Important Financial & Prudential Parameters	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	NBFCs- Peer-to-Peer digital lending platform companies (NBFC-P2P)
Form A Certificate	Annual	March 31st	All Non-Banking Financial Companies (NBFCs)
Financial Soundness Indicators (FSI)	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	All NBFCs
Fraud & Vigilance Monitoring
FMR-I (Report on Actual/Suspected Fraud	“As and when” basis	Whenever a fraud is detected	-Upper layer (UL) -Middle layer (ML) -Base layer (BL) that are ICC, MFI, and factors with assets worth INR 500 crore and above.
FMR-III (Update of Form FMR-1)	“as and when” needed basis	Only if any change/modification occurs in FMR-1	-Upper layer (UL) -Middle layer (ML) -Base layer (BL) that are ICC, MFI, and factors with assets worth INR 500 crore and above.
FMR-IV (Reports on Dacoities/Robberies/Theft/Burglaries)	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	-Upper layer (UL) -Middle layer (ML) -Base layer (BL) that are ICC, MFI, and factors with assets worth INR 500 crore and above.

Alternate Deadlines on Selected Returns for NBFC Filing

Type of Return	Period	Reference Deadline	Timeline
Statutory Auditor’s Certificate (SAC) Return	Yearly	March 31st	This must be filed within five days of signing of the auditor’s report in accordance with Section 134 of the companies Act of 2013, provided it shouldn’t be later than December 31st of the current year, either way.
Form A	Yearly	March 31st	This return should be submitted within one month from the appointment of a Statutory Central Auditor (SCA)/ Statutory Auditor (SA)
FMR-I	Strictly on an “as and when” basis	The date when the fraud occurs	From three from the date of incident.
FMR-II	Specific- “as and when”	In case of an update/progress on FMR I	Immediate filing
FMR IV	Quarterly	March 31st/ June 30th/ September 30th/ December 31st/	Must be filed within 15 days from the prescribed deadline.

Components of Types of Returns for NBFCs

Let’s understand the components of each form for a better understanding of the above-mentioned types of returns for NBFC annual compliance:

DNBS01: Important Financial Parameters

This report consists of assets, liabilities, debts, loan defaults, profits & loss account, real estate, capital market exposures, credit provided to various sectors, and liquidity indicators.

DNBS02: (Important Financial Parameters-NBFC-BL)

This return includes financial statements, including balance sheets, total assets & liabilities, expense reports, profit & loss statements, asset classification, and NPA exposure norms in accordance with RBI.

DNBS03: (Important Prudential Parameters)

The data is reported on performing & non-performing assets, total lending, capital adequacy ratio (CAR), risk analysis, and liquidity.

DNBS04A & DNBS04B: (Asset Liability Management):

must contain information on asset liability mismatches (ALMs), interest rate sensitivity (IRS), liquidity risk. The report must be filed under two returns, namely Short-Term Dynamic Liquidity and Structural Liquidity and Interest Rate Sensitivity.

DNBS08: (CRILC Main NBFCs):

NBFCs must furnish information, including total amount due, repayment status and account type against borrowers with INR 5 crore and above credit or loan. If no such borrower is present, then the said entity must report the return as “NIL” for that month.

DNBS09: (CRILC Return on Defaulted Borrowers):

This must be filed for borrowers with loan amount INR 5 crore and above on Friday each week, provided they fail to pay in a given week or reverse the default in the same week. In case there’s no default at all, then the NBFC must file a “NIL” return for the week.

DNBS010 (Statutory Auditor’s Certificate):

according to the RBI, this return must be filed by a statutory auditor of the respective NBFC every year after due audit process of the previous fiscal year.

DNBS011 (Core Investment Companies):

Financial Parameters: a core investment (NBFC) must disclose their assets & liabilities, profits & losses, and exposure risks.

DNBS012 (Core Investment Companies):

Prudential Parameters: you must submit details on adjusted net worth, stressed & non-stressed assets, leverage ratios, and group investments.

DNBS013 (Overseas Investment):

All types of NBFCs (irrespective of their type, company size, or capital investment) must furnish any foreign investment on this return, if applicable. If there are no such transactions in any particular quarter, then the company must submit a “NIL” return.

DNBS014 (Peer-to-Peer Lending Platform):

if your NBFC is a Peer-to-Peer lending platform that provides loans to individuals and corporations then you must file this return. The report must include information on balance sheets, income statements, expense reports, profit & loss, capital adequacy, and portfolio management.

Form A Certificate:

this report is submitted if your NBFC has appointed a Statutory Central Auditor (SCA) or Statutory Auditor (SA) in accordance with the RBI’s applicable laws, regulations, and subsequent amendments.

Financial Soundness Indicators (FSI):

this return explains the health and stability of your financial system. The report is shared with the International Monetary Fund in a manner as prescribed by the authority. Data includes asset quality, earnings, and sensitivity to market exposure.

FMR-I (Actual & Suspected Frauds):

primary reporting on frauds or suspected fraudulent activities in NBFCs.

FMR-III (update on FMR I):

this filing contains data on frauds of heavy/large value and must be filed as and when there’s any alteration, change, or development of any type that may occur in FMR-I.

FMR-IV (Reports on Dacoities or Theft):

consolidated details on burglaries, dacoities, robberies, or theft.

Key Instructions for NBFC Return Filing via Online

The Reserve Bank of India has introduced various online portals for applicable NBFC return filing. The same can be done through their website.

Each NBFC is provided access to their individual super login credentials with definite access rights, which they can at their accord can create multiple users, such as maker and checker. The NBFCs can track the status of their respective returns on their portal. 

The Form a Certificate- all NBFCs can only be filed through email/in-person as prescribed by the RBI, until a protocol is made for online returns.

Points to Remember for NBFC Return Filing

• All reports must be through the entity’s own sources, accurate, and complete.
• The returns must be filed through an automated system.
• The entities should maintain the primary sources for data generation.
• All NBFCs must create appropriate channels and take effective measures to modify or correct any or all data entries.
• The Non-Banking Financial Companies must install proper IT infrastructure for accurate and proper data integration.

Are there Penalties for Noncompliance of NBFC Return Rules?

The Reserve Bank of India may take appropriate action, including imposing fines and penalties in pursuant of the following legislation:

• Reserve Bank of India Act of 1934;
• Banking Regulations Act of 1949; and
• Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act of 2002

Common Abbreviations Used for NBFC Compliance

Given below are the common abbreviations used for NBFC Compliance-

NBFC- BL: Base Layer

NBFC- ICC: Investment Core Company

NBFC- MFI: Micro Finance Institution

NBFC-ML: Middle Layer

NBFC-P2P: Peer to Peer Digital Lending Platform

NBFC-SPD: Standalone Primary Dealer

NBFC-UL: Upper Layer

FMR- Fraud Monitoring

FSI: Financial Soundness Indicator

CIC: Core Investment Company

CRILC: Central Repository of Information on Large Credits

Conclusion

Whether you’re a digital lender, primary dealer, or an investment core company, you must submit your monthly, quarterly, or yearly returns to avoid penalties or revocation of your NBFC license.

It is a well-known fact that the Non-Banking Financial Company (NBFC) compliance could be mentally taxing and complicated, but it’s not impossible, which is where we come in. As India’s top most compliance service provider, we’ll ease your filing burden so that you can focus on your business and revenue generation.

From Form A & Statutory Auditor Certification filing to financial parameters & Fraud Monitoring submission, and then some more, our NBFC experts go all in. Take a beat and contact us straight away to plan ahead of the filing seasons.  

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Frequently Asked Questions