NBFC Consultant in Delhi: RBI Registration, PRAVAAH Filing and NCR-Specific Guidance

Introduction

Delhi and the National Capital Region represent one of the most concentrated hubs of financial services activity in India. From established lending companies and investment holding firms in Connaught Place and Nehru Place to fintech startups operating out of Gurugram’s Cyber City and Noida’s expressway corridor, the NCR is home to a disproportionately large share of India’s registered and aspiring Non-Banking Financial Companies (NBFCs).

The Reserve Bank of India’s Department of Regulation (Non-Banking) processes NBFC registration applications for entities incorporated in Delhi, Haryana, Himachal Pradesh, Jammu and Kashmir, Punjab, and Rajasthan through its New Delhi Regional Office. Understanding the specific procedural expectations of that office — including its physical submission requirements alongside the PRAVAAH online filing — is one of the practical advantages that a consultant with hands-on NCR experience brings to an engagement.

This guide covers the complete NBFC registration and compliance framework as it applies to promoters and businesses in Delhi and the NCR. Every section is written from the standpoint of a practising Chartered Accountant and Registered Valuer who has advised promoters on structuring, capital certification, business plan preparation, and regulatory compliance — and who understands precisely where NCR applications tend to stall and why.

CA Murli Chandak, ACA, IBBI Registered Valuer (Securities or Financial Assets, Registration No. IBBI/RV/07/2021/14408), practises from Ahmedabad and advises clients across India on NBFC registration, valuation, and post-CoR compliance. Engagements from Delhi and the NCR are accepted on a national advisory basis.

1. What Is an NBFC Consultant in Delhi?

An NBFC consultant is a qualified professional or firm that advises entities on obtaining and maintaining a Certificate of Registration (CoR) from the Reserve Bank of India under Section 45-IA of the RBI Act, 1934, and on the regulatory framework that governs their operations once registered.

In Delhi, NBFC advisory is offered by a mix of Chartered Accountants with regulatory practice backgrounds, Company Secretaries familiar with RBI filings, legal professionals specialising in banking and financial services law, and dedicated financial regulatory advisory firms. The most effective consultants bring a combination of regulatory knowledge, financial modelling capability, and hands-on experience with the PRAVAAH portal — the RBI’s designated online platform for NBFC applications.

The Delhi-NCR region has a distinctive financial ecosystem. The NCR is the primary base for several large NBFC-P2P (Peer-to-Peer Lending) platforms, NBFC-AA (Account Aggregator) licensees, and digital lending companies — categories that carry specific additional regulatory requirements beyond standard NBFC-ICC registration. It is also a significant market for investment holding companies, family office-linked lending entities, and microfinance institutions serving the peri-urban and rural belts of Haryana, Rajasthan, and western UP.

An NBFC consultant based in or experienced with the Delhi-NCR regulatory environment understands both the application framework common to all NBFC registrations nationally and the specific procedural characteristics of the RBI’s New Delhi Regional Office, which processes applications for entities incorporated in Delhi and five surrounding states.

2. The RBI’s New Delhi Regional Office: Jurisdiction and Procedural Significance

The Reserve Bank of India processes NBFC applications through its regional offices. The New Delhi Regional Office has jurisdiction over entities incorporated in Delhi, Haryana, Himachal Pradesh, Jammu and Kashmir, Punjab, and Rajasthan. This is a wide geographic catchment — one that includes Gurugram and Faridabad in Haryana as well as cities such as Jaipur and Chandigarh that generate their own flow of NBFC applications.

Beyond the online filing on the PRAVAAH portal (pravaah.rbi.org.in), NBFC applicants under this jurisdiction are typically required to submit physical copies of certain documents to the New Delhi Regional Office. The exact requirements and current submission address should be verified directly with the RBI at the time of application, as procedural specifics are updated periodically.

A key practical point: inconsistencies between what is submitted online through PRAVAAH and what is delivered physically to the regional office are one of the most commonly cited causes of initial-stage queries from the New Delhi RO. An experienced NBFC consultant will ensure that the digital and physical submissions are entirely consistent in every detail — director names, company particulars, financial figures, and document versions — before either submission is made.

The New Delhi Regional Office’s contact information, current submission address, and any departmental notifications relevant to NBFC applications are available on the RBI’s official website at www.rbi.org.in.

3. Do You Need an NBFC Licence? The 50-50 Test Applied to NCR Businesses

The threshold question for any promoter is whether their proposed business model actually requires NBFC registration. Under the RBI Act, a company is considered principally engaged in financial activities — and therefore required to register — if it satisfies both limbs of what is commonly referred to as the 50-50 test:

• The company’s financial assets constitute more than 50 per cent of its total assets; and
• The income from financial assets constitutes more than 50 per cent of the company’s gross income.

Both conditions must be satisfied simultaneously. This test is prescribed under the RBI’s Master Direction — Non-Banking Financial Company — Registration, Exemptions and Framework for Scale Based Regulation Directions, 2025 (RBI notification dated 28 November 2025, Reference No. RBI/2025-26/88 DoR.FIN.REC.51/03.10.001/2025-26).

For the range of businesses common to the NCR, the application of this test is not always straightforward:

• Fintech and digital lending platforms that originate loans on their own books (as opposed to operating in a loan service provider capacity for a bank or existing NBFC) will typically meet both limbs and require registration as an NBFC-ICC.
• Investment holding companies in which a family group holds shares of group entities may or may not meet the financial assets test depending on whether the shareholdings are classified as financial assets and what the remaining balance sheet composition looks like.
• Real estate-linked entities that also provide builder finance or structured debt may have financial income that crosses the 50 per cent income threshold depending on the accounting treatment of revenues.
• Entities that make loans to group companies on an incidental basis (treasury management within a corporate group) are often not required to register, subject to the specific facts and applicable exemption criteria.

An eligibility assessment conducted by a qualified NBFC consultant before any registration process is commenced is an essential first step. Commencing financial activities that require NBFC registration without a CoR is a violation of Section 45-IA of the RBI Act, 1934 and attracts regulatory consequences including directions to cease operations, penalties, and potential prosecution.

4. NBFC Categories Most Relevant to Delhi-NCR Promoters

The RBI recognises multiple NBFC categories, each defined by the nature of activities permitted and the regulatory framework applicable. For businesses operating in or from the NCR, the following categories are most frequently encountered in practice:

NBFC Category	Principal Activity	NCR Relevance
NBFC-ICC (Investment and Credit Company)	Lending, investment, asset financing	Digital lenders, personal and SME loan companies, investment holding companies — the standard registration category for most lending businesses
NBFC-MFI (Micro Finance Institution)	Microfinance lending to low-income borrowers	MFI platforms serving the NCR’s peri-urban and adjacent rural population of Haryana, western UP, and Rajasthan
NBFC-P2P (Peer-to-Peer Lending Platform)	Online marketplace for lending between individuals and businesses	A category of particular concentration in the NCR; subject to the RBI’s Master Directions – NBFC-Peer to Peer Lending Platform and the significant August 2023 amendments that revised permissible fund flows and restricted contingency fund usage — a material compliance area for existing P2P licensees in the NCR
NBFC-AA (Account Aggregator)	Consent-based financial data aggregation	Several Account Aggregator licensees are incorporated in Delhi and the NCR; this category requires a separate CoR and is subject to the RBI’s Master Directions – Non-Banking Financial Company – Account Aggregator
NBFC-Factor	Factoring of trade receivables	Trade finance and supply chain financing businesses operating from the NCR’s manufacturing and logistics corridors

Selecting the correct category at the time of application is one of the foundational decisions of the registration process. An incorrect category selection can result in the application being returned for restructuring, with consequential delays and additional professional costs. The choice of category also determines the ongoing compliance framework, capital adequacy requirements, and permissible business activities.

5. Eligibility Criteria for NBFC Registration

Before an application is filed, the promoter and the proposed entity must satisfy the eligibility criteria prescribed by the RBI. The principal requirements are as follows.

5.1 Minimum Net Owned Fund

The RBI prescribes a minimum Net Owned Fund (NOF) of Rs. 10 crore for NBFC-ICC, NBFC-MFI, and NBFC-Factor registrations under the Scale Based Regulation framework. The NOF is computed as the aggregate of paid-up equity capital and free reserves, less accumulated losses and deferred revenue expenditure.

The NOF must be fully paid-up and unencumbered — it cannot be pledged or used as collateral for any borrowing. Computation errors are common and include treating revaluation reserves as eligible (they are not), failing to deduct accumulated losses from prior years, and incorrectly classifying preference share capital.

As a Chartered Accountant and Registered Valuer, the NOF computation and its certification forms part of the documentation I assist clients with — ensuring that the figure presented to the RBI is accurate, appropriately supported, and consistent with the audited financial statements.

5.2 Entity Structure

The applicant must be a company incorporated under the Companies Act, 2013. Partnership firms, limited liability partnerships, and proprietorships are not eligible for NBFC registration. A new private limited company must be incorporated if no suitable existing entity is available.

5.3 Memorandum of Association Objects

The Memorandum of Association (MOA) must expressly include objects permitting the proposed NBFC activities. If an existing company’s MOA does not cover these activities, an amendment must be carried out under the Companies Act, 2013 before the RBI application is filed. Filing the RBI application with an MOA that does not cover the proposed activities is a common error that triggers an initial-stage query.

5.4 Fit and Proper Criteria for Directors and Promoters

The RBI applies fit-and-proper criteria to all directors and major shareholders of the proposed NBFC. This assessment covers financial soundness, integrity, absence of criminal convictions or adverse regulatory findings, and relevant professional or business experience. Any director or promoter associated with a company whose prior NBFC application was rejected, or who has been subject to adverse regulatory action by any financial regulator, may not meet the fit-and-proper standard.

For NCR promoters, it is worth noting that the secondary market for NBFC shell companies — entities that are purportedly already registered and available for acquisition — is more active in the NCR than in most other cities. Promoters should exercise significant due diligence before acquiring any entity represented as an NBFC or as having a pending NBFC application. A prior rejection by the RBI attaches to the entity and to associated individuals, not merely to the application. Verify the CoR status of any entity directly on the RBI’s official NBFC list before proceeding with any acquisition.

6. Company Incorporation and Structuring for NCR Promoters

The corporate structure of the applicant entity directly affects the speed and outcome of the registration process. Key structuring considerations for NCR promoters include the following.

6.1 New Incorporation vs. Existing Company

A new private limited company will need to be incorporated where no suitable entity exists. The incorporation process through the MCA’s SPICe+ form is relatively straightforward, but the name, objects, and authorised capital must be planned in advance with NBFC registration in mind. Attempting to use an existing company with an incompatible history or object clause typically results in additional steps and time.

6.2 Promoter Shareholding and Source of Funds

The source of funds used to capitalise the company to the required NOF level is subject to detailed examination by the RBI. For NCR promoters, the most common source-of-funds challenge arises in two contexts: promoters whose capital originates substantially from real estate receipts or family property sales, and promoters whose capital is contributed by a holding company or family trust structure. In both cases, the chain of documentation must trace the funds to their legitimate source across each intermediate transaction.

Incomplete or poorly documented source-of-funds declarations are the single most common cause of substantive queries from the RBI’s New Delhi Regional Office. Preparing this documentation correctly at the outset — rather than in response to an RBI query — significantly shortens the overall processing timeline.

6.3 Director and Shareholder KYC

All directors and shareholders holding five per cent or more of the equity must provide comprehensive KYC documentation. For promoters with business interests across multiple jurisdictions — common among the NCR’s business families — foreign address proof, overseas entity structures, and FATF compliance (particularly for shareholders from jurisdictions subject to enhanced due diligence) can add complexity that should be anticipated early.

7. Business Plan Preparation: What the RBI Examines

The business plan is the centrepiece of any NBFC application and the primary document on which the RBI forms its view of the viability and regulatory fitness of the proposed entity. A business plan that is internally inconsistent, aspirational rather than grounded, or vague on risk management and governance will invite detailed questioning and potentially rejection.

For Delhi-NCR-based businesses, the business plan must address the following with specificity:

7.1 Business Model and Products

The nature of financial activities proposed, the specific products or instruments to be offered, target customer segments, ticket sizes, and the underwriting or investment methodology. For digital lending businesses — heavily concentrated in the NCR — the business plan must reflect awareness of the RBI’s Guidelines on Digital Lending (September 2022), including the requirements on disbursement and repayment flows, the role of Lending Service Providers, and the prohibition on first-loss default guarantee structures involving NBFC funds that circumvent the regulatory framework.

7.2 Five-Year Financial Projections

Projected balance sheets, profit and loss statements, loan book growth trajectory (for lending NBFCs), capital adequacy ratio maintenance, funding strategy, and non-performing asset assumptions and provisioning policy. Projections that show loan book growth without a credible funding strategy, or capital adequacy ratios that hover at the minimum without adequate headroom, will be scrutinised.

7.3 IT Systems and Cybersecurity

The RBI expects NBFC applicants — particularly those proposing technology-driven business models — to demonstrate that they have an adequate IT infrastructure and cybersecurity framework in place. For fintech businesses in the NCR that rely on a digital-only delivery model, the absence of a credible IT architecture description in the business plan is a recurring cause of queries. The RBI’s Master Directions on Information Technology Framework for the NBFC Sector set out the applicable requirements, and alignment with these directions should be reflected in the business plan from the outset.

7.4 Governance and Risk Management

Proposed board composition, qualifications of key management personnel, risk management framework, internal audit structure, and compliance function. The RBI’s Master Directions — Corporate Governance in NBFCs set out the governance requirements applicable post-registration, and demonstrating that the proposed structure is already aligned with these requirements at the application stage strengthens the overall submission.

8. How to Apply Through the PRAVAAH Portal

The Reserve Bank of India’s PRAVAAH portal (pravaah.rbi.org.in) is the mandatory platform for all NBFC registration applications. There is no alternative submission route. The PRAVAAH process involves the following sequence:

1. Create the applicant entity’s login on PRAVAAH with the company’s credentials.
2. Select the correct application type for the NBFC category being applied for.
3. Populate all data fields with information that is exactly consistent with the documents to be uploaded — any discrepancy between what is entered on the portal and what appears in a supporting document is a ground for query.
4. Upload all required documents in the prescribed format, file type, and size specifications.
5. Pay the application fee and complete the submission.
6. Record the Company Application Reference Number (CARN) for tracking purposes.
7. Complete physical submission requirements to the RBI New Delhi Regional Office where applicable.
8. Monitor application status and maintain readiness to respond to RBI queries promptly.

The physical submission to the New Delhi Regional Office — where required alongside the online filing — must mirror the PRAVAAH submission exactly. Discrepancies in any document version, director name format, or financial figure between the two submissions are a specifically noted cause of initial-stage queries from the New Delhi RO. Ensuring consistency between the two is a core part of the consultant’s pre-submission review process.

9. Where NCR Applications Stall: Four Specific Risk Areas

Based on practical experience with NBFC applications processed through the RBI’s New Delhi Regional Office, the following are the most common points at which Delhi and NCR applications encounter delays.

9.1 Source-of-Funds Documentation for Capital Originating from Real Estate or Family Capital

NCR promoters frequently capitalise their NBFC from proceeds of real estate sales, family property partition, or distributions from a HUF. Each of these requires a documented chain of evidence: sale deed, registration receipts, mutation records where applicable, and bank transfer records from the point of receipt to the point of capital infusion. Presenting only the bank certificate evidencing current account balance, without the upstream chain, will invite a detailed source-of-funds query.

9.2 Fintech Business Plans Without Credible IT Infrastructure Description

The NCR hosts a significant number of fintech and digital lending applicants whose proposed business model relies entirely on a technology-based origination and servicing platform. Business plans that describe the technology in generic terms — “we will use a proprietary algorithm” or “we will implement a digital KYC system” — without specifying the platform architecture, vendor relationships, data localisation compliance, and cybersecurity governance do not meet the RBI’s expectations for technology-driven NBFCs. This is one of the most consistent feedback themes on NCR-originating fintech applications.

9.3 PRAVAAH-to-Physical Submission Mismatch

The requirement to submit physical documents to the New Delhi Regional Office alongside the PRAVAAH online filing means there are two sets of submissions that must be maintained in exact correspondence. Version differences in documents — where an amended document is uploaded to PRAVAAH after the physical set has been dispatched, or vice versa — create inconsistencies that generate initial-stage queries. A consultant managing both submissions end-to-end can eliminate this risk.

9.4 NBFC-P2P and NBFC-AA Applicants Underestimating Category-Specific Requirements

Promoters seeking NBFC-P2P or NBFC-AA registration frequently structure their applications as if these were standard NBFC-ICC applications with a technology angle. They are not. Each category carries distinct prudential requirements, permissible activity restrictions, and documentation obligations. NBFC-P2P applicants must address the RBI’s August 2023 amendments to P2P directions — which significantly tightened fund flow requirements and restricted the use of escrow accounts — in both their business plan and their proposed operating procedures. Applications that do not reflect these requirements as of the current regulatory position will be queried on these points specifically.

10. Commonly Required Documents for NBFC Registration

Document Category	Specific Documents
Company Documents	Certificate of Incorporation, Memorandum of Association, Articles of Association, Board Resolution authorising the application, latest audited financial statements
Director and Promoter KYC	PAN, Aadhaar or other approved identity proof, address proof, photographs, CIBIL or credit bureau report, educational qualifications, professional experience details, banker’s report
Shareholder Information	Shareholding pattern, list of shareholders above the relevant threshold, source-of-funds declaration with supporting evidence
Net Owned Fund Documentation	Audited financials, NOF computation certified by Statutory Auditor, bank statements evidencing capital infusion, no-lien certificate from the bank
Business Plan and Projections	Comprehensive business plan as described in Section 7 above; five-year projected financials
Policy Documents	Fair Practices Code, KYC/AML Policy, IT Policy (for technology-driven models), risk management framework

The document requirements vary by NBFC category and are updated periodically by the RBI. The current requirements should be verified against the PRAVAAH portal’s application checklist at the time of application.

11. RBI Scrutiny and Query Management

After a complete application is submitted through PRAVAAH and physical documents are received by the New Delhi Regional Office, the application enters the RBI’s examination process. This involves initial screening for completeness, followed by substantive examination of eligibility, business plan viability, governance adequacy, and documentation consistency.

The RBI may issue queries at any point during the examination. These queries require timely, accurate, and complete responses. The quality of query responses is one of the primary factors within the applicant’s control that influences the overall timeline.

An experienced NBFC consultant will manage the query-response process: reviewing the query, determining what additional documentation or clarification is required, drafting the response with the same level of care as the original application, and ensuring submission within the timelines communicated by the RBI.

If the application satisfies all eligibility criteria and the RBI is satisfied with the business plan and documentation, the Certificate of Registration is issued. No entity may commence or continue activities requiring NBFC registration before the CoR is received.

12. Professional Fees for an NBFC Consultant in Delhi

NBFC consultant fees in Delhi vary considerably depending on the scope of engagement, the NBFC category, the complexity of the promoter structure, and whether the engagement extends to post-registration compliance.

As a general guide based on the current market and the services described in this article:

• A standard NBFC-ICC registration engagement — covering eligibility assessment, documentation, and PRAVAAH filing through to receipt of the CoR — is typically priced in the range of Rs. 1.5 lakh to Rs. 3.5 lakh, depending on the complexity of the application and the promoter structure.
• Comprehensive engagements that include business plan preparation, detailed financial modelling, RBI query management, and post-registration compliance setup attract higher fees, in the range of Rs. 3.5 lakh to Rs. 7 lakh or more.
• Specialist category registrations (NBFC-P2P, NBFC-AA) that carry additional documentation and regulatory requirements are typically priced at the higher end of the range.
• Ongoing post-registration compliance advisory — return filings, regulatory monitoring, policy updates — is generally structured as a separate retainer engagement.

Fee levels should be evaluated in the context of the scope of work, the consultant’s track record, and the professional accountability involved. No reputable NBFC consultant can guarantee issuance of the CoR — that decision rests entirely with the RBI. Any representation to the contrary should be treated with scepticism.

13. Timelines: What to Expect

The overall timeline from engagement to receipt of the CoR involves two distinct phases:

• Consultant preparation phase: For an applicant who can provide all required information and documentation promptly, preparation and filing typically takes four to eight weeks. Where company incorporation, MOA amendment, or complex source-of-funds documentation is required, this phase may take longer.
• RBI processing phase: The RBI’s examination and query-resolution process for a clean, complete application filed through the New Delhi Regional Office typically takes three to four months from the date of a complete submission. Applications with substantive issues — promoter eligibility questions, business plan weaknesses, or incomplete source-of-funds documentation — can take significantly longer, and may in some cases be returned for resubmission.

Promoters should plan for an overall process of approximately five to six months from the date of engaging a consultant to the potential receipt of the CoR, assuming a well-prepared application with no significant eligibility issues. This timeline should be factored into any business launch planning.

14. Post-Registration Compliance: Obligations After the CoR

The Certificate of Registration marks the beginning of a comprehensive and ongoing compliance framework, not the end of the regulatory process. Post-registration obligations for all NBFCs include the following:

• Periodic regulatory returns to the RBI on monthly, quarterly, half-yearly, and annual cycles — covering assets and liabilities, capital adequacy, borrowings, NPA data, and other prescribed information.
• Capital adequacy maintenance at or above the prescribed Capital to Risk-weighted Assets Ratio (CRAR) at all times.
• Statutory auditor certification of annual returns and prescribed statements.
• Board and governance compliance under the RBI’s Master Directions on Corporate Governance in NBFCs, including minimum board meeting frequency, required committee constitution, and the appointment of a Chief Compliance Officer for qualifying entities.
• KYC and AML compliance under the RBI’s Master Directions on KYC and the Prevention of Money Laundering Act, 2002.
• Fair Practices Code observance and maintenance of a board-approved code governing lending and collection practices.
• Monitoring of RBI circulars and amendments to the applicable Master Directions — the regulatory framework for NBFCs has been subject to significant updates under the Scale Based Regulation framework introduced in 2022, and ongoing monitoring is essential.

An NBFC consultant who provides post-registration compliance support can be a valuable long-term advisory partner — particularly for entities that plan to raise external capital, expand their business geographically, or seek an upgrade in their regulatory category.

15. Why Choose CA Murli Chandak as Your NBFC Consultant for Delhi

CA Murli Chandak brings a Chartered Accountant’s and Registered Valuer’s perspective to NBFC advisory — a combination that matters because the RBI’s evaluation of an NBFC application is, at its core, an assessment of financial soundness, governance adequacy, and business viability. The most common causes of application delays are financial documentation errors (NOF computation, source-of-funds, projections) and business plan weaknesses — areas where a qualified CA with financial modelling and valuation experience is better placed than a generalist consultant.

Key aspects of the engagement approach:

• Eligibility assessment before commitment: A thorough analysis of whether registration is required, which category is appropriate, and whether the promoter and entity meet the eligibility criteria — conducted before any application cost is incurred.
• NOF computation and certification: As a Chartered Accountant, I assist with the preparation of the NOF computation and liaise with the Statutory Auditor on certification requirements, ensuring the figure is accurate and defensible.
• Business plan preparation: In-house preparation of the business plan and financial projections, aligned with RBI expectations and internally consistent across all sections.
• PRAVAAH filing and physical submission coordination: End-to-end management of both the online filing and the physical submission to the New Delhi Regional Office, with a pre-submission consistency review across both sets of documents.
• RBI query management: Professional drafting and timely submission of responses to RBI observations.
• National advisory practice: Engagements from Delhi and the NCR are served on a national advisory basis from Ahmedabad, with communication by video, telephone, and document exchange — an arrangement that has worked effectively for clients across multiple cities.

16. What to Check Before Engaging an NBFC Consultant in Delhi

The quality of NBFC advisory services varies significantly. Before committing to an engagement, the following due diligence steps are advisable:

• Track record of completed registrations: Ask specifically about NBFC CoRs successfully obtained, the categories covered, and whether the consultant has handled registrations under the New Delhi Regional Office’s jurisdiction.
• In-house business plan capability: Confirm whether the business plan and financial projections are prepared by the consultant directly or outsourced. Outsourcing introduces inconsistency risk.
• PRAVAAH experience: Confirm direct, hands-on experience with the portal — not merely awareness of the process.
• Query-response process: Ask specifically how the consultant manages RBI queries after filing — who drafts the responses, and what the turnaround commitment is.
• Professional credentials: Verify the qualifications of the individuals who will actually work on the assignment, not only the firm’s general promotional materials.
• Scope and fee clarity: A well-structured engagement letter should define the scope, milestones, fee structure, and what is included and excluded. Vaguely scoped engagements create disagreements at the point when the hard work begins.

17. Frequently Asked Questions

Q1. What is the minimum capital required to register an NBFC in Delhi?

The minimum Net Owned Fund required for NBFC-ICC, NBFC-MFI, and NBFC-Factor registrations is Rs. 10 crore. This must be in the form of paid-up equity capital and free reserves, fully paid-up and unencumbered. The minimum NOF for NBFC-P2P is Rs. 2 crore (subject to verification of the current requirement under the applicable Master Directions at the time of application).

Q2. Which RBI office processes NBFC applications from Delhi?

NBFC registration applications from companies incorporated in Delhi are processed through the RBI’s New Delhi Regional Office, which also has jurisdiction over entities incorporated in Haryana, Himachal Pradesh, Jammu and Kashmir, Punjab, and Rajasthan.

Q3. Is PRAVAAH mandatory for all NBFC applications?

Yes. PRAVAAH (pravaah.rbi.org.in) is the mandatory and only accepted platform for NBFC registration applications. Applications submitted through any other means are not valid under the current regulatory framework.

Q4. Does a company incorporated in Gurugram or Noida apply through the New Delhi Regional Office?

Companies incorporated in Haryana (including Gurugram and Faridabad) apply through the New Delhi Regional Office, as Haryana falls within that office’s jurisdiction. Companies incorporated in Uttar Pradesh (including Noida and Greater Noida) fall under the jurisdiction of a different RBI regional office — the applicable regional office should be verified against the RBI’s current regional office jurisdiction list at the time of application.

Q5. Can an existing company be converted into an NBFC?

Yes. An existing private limited company can apply for NBFC registration, provided it meets the eligibility criteria including the NOF minimum, fit-and-proper criteria for directors and promoters, and appropriate MOA objects. If the current MOA does not permit NBFC activities, an amendment under the Companies Act, 2013 must be completed before filing the application.

Q6. How long does NBFC registration take for a Delhi-based company?

The consultant preparation and filing phase typically takes four to eight weeks for a well-organised applicant. The RBI’s examination and processing phase typically takes three to four months for a clean, complete application. Promoters should plan for a total process of approximately five to six months, with the understanding that complex structures, multiple rounds of queries, or capital infusion delays can extend this.

Q7. What is the 50-50 test and does my business need to satisfy it?

The 50-50 test is the RBI’s threshold test for determining whether a company is principally engaged in financial activities and therefore required to register as an NBFC. Both conditions must be met: financial assets must exceed 50 per cent of total assets, and income from financial assets must exceed 50 per cent of gross income. Satisfying both limbs triggers the registration requirement, subject to applicable exemptions. An eligibility assessment is strongly advisable before any registration process is commenced.

Q8. Can I buy an existing registered NBFC shell company in Delhi?

Acquisition of a company that holds an NBFC CoR requires prior approval from the RBI under its Master Directions – Non-Banking Financial Company – Acquisition of Shareholding or Control Directions, 2025, which require prior RBI approval for any acquisition of 26 per cent or more of voting rights or acquisition of control. Promoters should also conduct independent verification of the CoR status, regulatory compliance history, and any pending regulatory action on any entity being considered for acquisition. The NCR secondary market for NBFC entities carries heightened due diligence requirements given the volume of promotional activity in this space.

Q9. Does post-registration compliance need a separate consultant?

Post-registration compliance — periodic return filings, capital adequacy monitoring, governance requirements, KYC/AML policy maintenance, and regulatory change monitoring — can be handled by the same consultant who managed the registration, or by a separately appointed compliance advisor. For entities that anticipate ongoing growth and regulatory interaction, continuity of advisory relationship is generally preferable, as it preserves institutional knowledge of the original application and the RBI’s queries and responses.

Q10. What happens if an NBFC does not file returns on time?

Failure to file prescribed returns by the due dates is a regulatory violation that can attract RBI notices, penalties, and in serious or repeat cases, directions to show cause or corrective action orders. The RBI has been consistent in issuing directions and penalties against NBFCs with compliance failures, including public notices of CoR cancellations for NBFCs that have ceased to operate or have material compliance deficiencies. Maintaining a robust compliance calendar is an essential post-registration obligation.

Conclusion

Establishing an NBFC in Delhi or the NCR is a structured, multi-stage regulatory undertaking. The process begins well before the PRAVAAH application is filed — with a careful eligibility assessment, promoter and entity structuring, capital documentation, and business plan preparation — and continues well beyond the receipt of the Certificate of Registration, through the lifecycle of ongoing compliance obligations.

For promoters in Delhi and the broader NCR, the specific characteristics of the RBI’s New Delhi Regional Office jurisdiction, the concentration of NBFC-P2P and fintech applicants in the region, the source-of-funds documentation challenges common to NCR promoters, and the dual (online and physical) submission requirement together create a set of practical considerations that distinguish Delhi registrations from those in other cities. These are manageable with the right professional guidance — but they do require attention from the outset.

CA Murli Chandak provides NBFC advisory, NOF certification, business plan preparation, PRAVAAH filing management, and post-CoR compliance support to clients across India on a national basis. Enquiries from Delhi and the NCR are welcome.

Disclaimer: This article is for general informational purposes and does not constitute legal or regulatory advice. The NBFC regulatory framework is subject to change. Readers are advised to obtain professional advice specific to their circumstances before initiating any regulatory process.