NBFC Consultant in Hyderabad: RBI Hyderabad Regional Office, PRAVAAH Filing and Telangana-Specific Guidance

Introduction

Hyderabad has emerged as one of India’s most significant centres for financial technology, pharmaceutical commerce, and information services — a combination that produces a distinctive and varied population of businesses seeking NBFC registration from the Reserve Bank of India. Digital lending platforms, pharma-sector invoice discounting businesses, microfinance institutions, and peer-to-peer lending operations have all found a home in Telangana’s capital, and each faces a regulatory pathway that demands precise preparation.

The NBFC regulatory framework in India is not static. The RBI consolidated its foundational NBFC directions into 35 Master Directions on 28 November 2025, replacing earlier scattered circulars with a unified Scale Based Regulation framework. For digital lenders specifically, the RBI (Digital Lending) Directions, 2025, issued on 8 May 2025, replaced the earlier 2022 guidelines and introduced new obligations around borrower protection, multi-lender LSP arrangements, and CIMS-based reporting of Digital Lending Apps. A consultant — or a business — working from the 2022 framework is already behind the current regulatory position.

Hyderabad also presents a jurisdictional complexity that is unique in the country and that every NBFC applicant incorporated in the region must understand before filing: the RBI now operates two separate regional offices with Hyderabad addresses. The RBI Hyderabad Regional Office has jurisdiction exclusively over the State of Telangana. A separate RBI Andhra Pradesh Regional Office, operational since 22 August 2022 and temporarily co-located at the same Secretariat Road premises, has jurisdiction over the State of Andhra Pradesh. An applicant incorporated in Vijayawada, Visakhapatnam, or any part of Andhra Pradesh is not dealt with by the Hyderabad RO — it is the AP RO. Getting this right at the point of PRAVAAH filing is not optional.

I am CA Murli Chandak, a Chartered Accountant and IBBI Registered Valuer (Registration No. IBBI/RV/07/2021/14408) based in Ahmedabad, with a national practice in NBFC advisory, RBI registration, regulatory compliance, and financial valuation. This guide is written specifically for promoters and businesses in Hyderabad and Telangana who are evaluating the NBFC route, preparing to file, or managing compliance after registration.

1. The RBI Hyderabad Regional Office and the AP Regional Office: What Every Applicant Must Know

This section addresses a point that most NBFC advisory guides for Hyderabad overlook entirely, and it is one of the most practically consequential facts for any promoter in the region.

The RBI Hyderabad Regional Office is located at 6-1-56, Secretariat Road, Saifabad, Hyderabad 500 004 (Tel: 040-23230863; Email: rdhyderabad@rbi.org.in). Its jurisdiction is the State of Telangana only. The Regional Director as of this publication is Shri Chinmoy Kumar. Physical submissions of NBFC application packages for companies incorporated in Telangana are directed to this office.

The RBI Andhra Pradesh Regional Office has been operational since 22 August 2022, reflecting the administrative recognition of Telangana’s bifurcation from Andhra Pradesh. It is currently temporarily functioning from the same Secretariat Road address as the Hyderabad RO, with four departments active: Department of Supervision, Financial Inclusion and Development Department, Foreign Exchange Department, and Integrated Banking Department. The Regional Director is Shri A.O. Basheer. Its jurisdiction is the State of Andhra Pradesh.

The practical implication is direct. If your company is incorporated in Telangana — whether in Hyderabad, Warangal, Karimnagar, or any other city in the state — your NBFC application is handled by the Hyderabad RO. If your company is incorporated in Andhra Pradesh — Vijayawada, Visakhapatnam, Tirupati, Guntur — it is handled by the AP RO. Both offices currently share a Hyderabad address, but they are distinct regulatory units with separate correspondence channels. Directing application correspondence to the wrong unit adds unnecessary delay. This should be clarified before PRAVAAH submission is finalised.

2. Why Hyderabad Promoters Engage an NBFC Consultant

The NBFC regulatory framework administered by the RBI is comprehensive, detailed, and subject to frequent revision. The consolidated Scale Based Regulation framework, set out in the RBI (Non-Banking Financial Companies — Registration, Exemptions and Framework for Scale Based Regulation) Directions, 2025 (RBI/DOR/2025-26/339, issued 28 November 2025), runs across 35 co-ordinated Master Directions covering capital adequacy, governance, asset classification, risk management, conduct, and consumer protection. No part of this framework is static.

Hyderabad’s business ecosystem generates several categories of NBFC applicant that face above-average regulatory complexity.

2.1 The Pharma and Life Sciences Sector

Hyderabad hosts one of the largest concentrations of pharmaceutical and life sciences businesses in Asia, spanning Genome Valley, HITECH City, and the Hyderabad Pharma City project. This sector generates significant receivables — between manufacturers, distributors, and contract research organisations — and has produced a meaningful number of businesses interested in NBFC-Factor (factoring company) registration or NBFC-ICC lending structures oriented toward supply chain finance. The NBFC-Factor category requires a minimum Net Owned Fund of Rs. 5 crore and mandates that at least 75 per cent of qualifying assets consist of factoring assets, in accordance with the Factoring Regulation Act, 2011. The business case for a factoring NBFC in the pharma supply chain is commercially coherent, but the regulatory structuring is specific and must be correctly executed from the outset.

2.2 The Fintech and Digital Lending Ecosystem

Hyderabad’s technology and startup ecosystem has produced a significant number of digital lending businesses. The RBI (Digital Lending) Directions, 2025 (issued 8 May 2025), which consolidated and replaced the earlier 2022 Digital Lending Guidelines and the 2023 Default Loss Guarantee Guidelines, now govern all digital lending activity by regulated entities. The 2025 Directions introduced material new obligations: all Digital Lending Apps operated by an NBFC or its Lending Service Providers must be reported through RBI’s CIMS portal; enhanced due diligence requirements apply to Default Loss Guarantee providers; and specific provisions now govern LSPs that partner with multiple regulated entities, requiring transparent disclosure of all lenders and unbiased presentation of loan offers. A fintech platform preparing an NBFC application must design its LSP structure, DLG arrangements, and digital interface compliance against the 2025 Directions, not the superseded 2022 framework.

2.3 The NBFC-MFI Context in Telangana

The microfinance sector in Telangana and Andhra Pradesh carries a specific regulatory history that applicants for NBFC-MFI registration must understand. The Andhra Pradesh Micro-Finance Institutions (Regulation of Money-Lending) Act, 2010 was enacted following a period of serious distress in the microfinance sector, and the RBI has since affirmed before courts that NBFC-MFIs registered with it are subject to central regulation exclusively, not to state-level frameworks of this nature. However, the episode shaped the RBI’s approach to NBFC-MFI applications from the region, and applicants can expect careful scrutiny of business plans, borrower protection frameworks, and credit assessment methodologies. The minimum Net Owned Fund for NBFC-MFIs is Rs. 10 crore, except for those operating in the northeastern states. The business plan for an NBFC-MFI applicant from Telangana must specifically address how the proposed credit policies and grievance redressal framework are aligned with RBI’s current Master Directions on microfinance.

3. Does Your Business Require NBFC Registration?

The foundational question for any business considering NBFC registration is whether registration is legally required. The answer is not self-evident for many fintech platforms operating in Hyderabad’s technology sector.

Under Section 45-IA of the Reserve Bank of India Act, 1934, a company whose principal business is financial activity — lending, investment in financial instruments, or acceptance of deposits — is required to register as an NBFC before commencing such activity. The RBI has historically applied a principal-business test: where a company’s financial assets exceed 50 per cent of its total assets, and income from financial assets exceeds 50 per cent of its total income, registration is required.

The challenge for technology-driven businesses is that this line is not always obvious. A platform that facilitates lending between parties without itself deploying funds may be operating as an NBFC-P2P and requires registration under that category. A business that provides Default Loss Guarantees on a portfolio of loans originated by an NBFC partner may have incidental exposures that need careful regulatory assessment. An embedded finance product that routes consumer credit through an NBFC partner using an app as the interface may, depending on its contractual structure, qualify as a Lending Service Provider rather than an NBFC — but that distinction requires analysis of the specific contractual arrangements.

Commencing NBFC activity without registration is an offence under Section 58B of the RBI Act. The RBI regularly cancels the registrations of NBFCs and takes enforcement action against unregistered entities. Before proceeding with product development or capital-raising on the assumption that registration is not required, businesses in Hyderabad’s fintech sector should obtain a specific regulatory opinion on their proposed model.

4. NBFC Categories and Minimum Capital Requirements

The RBI defines multiple categories of NBFC, each designed for a specific type of financial activity. Selecting the correct category is one of the most consequential decisions in the registration process — and one that must be driven entirely by the proposed business model, not by the minimum capital threshold.

Category	Principal Activity	Minimum NOF
NBFC-ICC	Lending, investment in securities, hire purchase	Rs. 10 crore
NBFC-MFI	Collateral-free credit to low-income borrowers	Rs. 10 crore
NBFC-Factor	Purchase of trade receivables (factoring)	Rs. 5 crore
NBFC-P2P	Peer-to-peer lending platform intermediary	Rs. 2 crore
NBFC-AA	Financial data aggregation with customer consent	Rs. 2 crore
NBFC-IFC	Long-term infrastructure financing	Rs. 300 crore
HFC	Loans for residential property (regulated by NHB)	Rs. 25 crore

The capital requirements above reflect the current regulatory framework. They should be confirmed against the applicable Master Directions at the time of application — the RBI has revised these thresholds in the past and retains the authority to do so again.

5. Company Structuring Before Incorporation

NBFC registration is available only to a company incorporated under the Companies Act, 2013 or its predecessor. Limited Liability Partnerships, partnership firms, trusts, and sole proprietorships are not eligible regardless of how they are structured or capitalised. This is an absolute statutory requirement.

The structuring decisions taken before or at incorporation have lasting consequences for the registration process. The three most important are:

5.1 The Objects Clause. The Memorandum of Association must contain a principal objects clause that precisely and specifically authorises the financial activities the company intends to undertake as an NBFC. A general or generic objects clause — or one that characterises the company as a technology or services business without clear financial activity language — will be flagged at the PRAVAAH stage and will attract an RBI query. The exact wording of the objects clause should be reviewed and confirmed before incorporation is completed. Amending the MoA after incorporation to correct an inadequate clause adds cost and delay — both the MoA amendment process and the knock-on effect on the RBI application timeline.

5.2 Board Composition and Fit-and-Proper Compliance. The RBI evaluates the board of every NBFC applicant against its fit-and-proper criteria. The board must collectively demonstrate relevant experience in banking, finance, or the specific sector in which the NBFC proposes to operate. Directors with adverse credit history, regulatory sanctions, or pending proceedings before financial regulators are likely to prejudice the application. The CIBIL score and credit history of each director are reviewed. For Hyderabad applicants with multi-jurisdictional business backgrounds, this check must cover all relevant jurisdictions in which directors have been active.

5.3 Foreign Direct Investment and Beneficial Ownership. Where a proposed NBFC has foreign shareholders, the Foreign Direct Investment framework becomes relevant from the point of company incorporation. The sectoral cap for NBFCs under the automatic route, the reporting requirements under FEMA, and the RBI’s own scrutiny of foreign ownership during the registration review must all be factored into the ownership structure before the company is incorporated. In addition, significant beneficial owners must be identified and disclosed in accordance with the beneficial ownership provisions of the Companies Act, 2013.

6. Net Owned Fund: What the RBI Actually Checks

The Net Owned Fund requirement is, in practice, one of the most frequently misunderstood aspects of the NBFC registration process. The regulatory minimum — Rs. 10 crore for NBFC-ICCs — is well-known. What is less well-understood is the evidentiary standard the RBI applies to demonstrate compliance.

Net Owned Fund is computed as paid-up equity capital plus free reserves, less accumulated losses, deferred revenue expenditure, and certain intangible assets, with a further deduction for investments in group companies or subsidiaries that exceed a specified proportion of owned funds. The computation follows the definitional framework in the applicable Master Directions and cannot be approximated by the company’s net worth as reported in its financial statements — the two figures will often differ.

The RBI requires three categories of evidence at the time of application:

1. A Statutory Auditor’s certificate — not a Chartered Accountant’s certificate — certifying the NOF computed in accordance with the RBI’s definition as of a recent date. This is one of the most common errors in applications: submitting a CA certificate rather than a Statutory Auditor’s certificate. The RBI is explicit about which it requires.
2. A banker’s no-lien certificate confirming that the share capital is unencumbered and not subject to any charge, pledge, or lien.
3. Source-of-funds documentation covering the origin of the promoters’ capital contribution — bank statements, income tax returns, investment records, or other evidence tracing the funds to legitimate, documented sources over a reasonable historical period.

The RBI’s source-of-funds scrutiny has intensified in recent years, consistent with broader anti-money laundering considerations. For promoters in Hyderabad’s pharma, technology, and real estate sectors — where capital structures often involve family investment companies, HUF-partition proceeds, or cross-border distributions — the documentation requirement needs careful advance planning. Capital that cannot be clearly traced to legitimate documented sources will not satisfy the regulator.

7. The NBFC Registration Process: Step by Step

The NBFC registration process in Hyderabad follows the national sequence, with the jurisdiction-specific considerations noted above applying at the point of physical submission.

1. Pre-Incorporation Structuring: Confirm eligibility, select the appropriate NBFC category, draft the objects clause, structure the board to satisfy fit-and-proper requirements, and address any FDI or beneficial ownership considerations. Engaging an advisor at this stage — before incorporation is complete — prevents the most common and most costly errors.
2. Capital Arrangement: Infuse the minimum paid-up capital in compliance with the applicable NOF threshold. Ensure all capital is unencumbered, sourced from documented funds, and capable of satisfying the RBI’s source-of-funds review. Obtain the Statutory Auditor’s NOF certificate and banker’s no-lien confirmation.
3. Governance and Policy Preparation: Constitute the board, pass the necessary resolutions authorising the NBFC application, and prepare all board-approved policies — Fair Practices Code, credit policy, KYC/AML policy, risk management framework, and (for digital lenders) IT and cybersecurity policy and DLA reporting framework compliant with the RBI (Digital Lending) Directions, 2025.
4. Business Plan Preparation: Prepare a detailed, RBI-ready business plan incorporating five-year financial projections with clearly stated assumptions, capital adequacy projections, funding strategy, target market analysis, and underwriting framework. For NBFC-Factor applications, the plan must address the composition of the qualifying asset base. For NBFC-MFI applications, it must address borrower protection and grievance redressal in detail.
5. PRAVAAH Filing: Complete the NBFC registration application on the PRAVAAH portal (pravaah.rbi.org.in). All documents must be uploaded in the prescribed formats and within the portal’s file size limits. Upon successful submission, the system generates a CARN (Company Application Reference Number) for all subsequent correspondence.
6. Physical Submission: Submit physical copies of the application and supporting documents to the relevant RBI Regional Office — for Telangana-incorporated companies, the RBI Hyderabad Regional Office at Secretariat Road, Saifabad, Hyderabad 500 004; for Andhra Pradesh-incorporated companies, the AP Regional Office at the same address. Confirm physical submission requirements directly with the relevant office at the time of filing.
7. RBI Review and Query Management: The RBI reviews the application and raises queries or seeks additional information as required. Query responses must be filed promptly, accurately, and in complete compliance with the RBI’s specific requests. Each query round that is handled poorly extends the timeline.
8. Certificate of Registration: Upon satisfaction that the applicant meets all eligibility requirements, the RBI issues the Certificate of Registration. The NBFC may then commence the activities authorised by its registration.

8. The PRAVAAH Portal: What Applicants Need to Know

The PRAVAAH portal (Platform for Regulatory Application, VAlidation And AutHorisation) is the mandatory channel for all NBFC registration applications. Applications prepared on templates from earlier systems — including the COSMOS portal — are not appropriate for current submissions and may not align with the current documentation requirements.

Common PRAVAAH filing errors that delay applications include: uploading documents in incorrect file formats or exceeding file size limits; submitting an incomplete online application form; using outdated document templates; and failing to cross-reference documents correctly within the application. A correctly filed first submission substantially reduces the likelihood of avoidable queries. An incomplete submission does not halt the process — it invites a query round that adds months to the timeline.

The CARN generated on submission is the reference number for all subsequent RBI correspondence, including during query rounds and at receipt of the Certificate of Registration. All correspondence should be filed and tracked against this reference.

9. Digital Lending and the RBI (Digital Lending) Directions, 2025

For NBFC applicants in Hyderabad’s fintech sector, the most important current regulatory reference point for business plan preparation, policy drafting, and LSP structuring is the RBI (Digital Lending) Directions, 2025, issued on 8 May 2025. These Directions consolidated and replaced the Guidelines on Digital Lending dated 2 September 2022, the Guidelines on Default Loss Guarantee in Digital Lending dated 8 June 2023, and the earlier circular on digital lending outsourcing dated June 2020. Any NBFC application prepared against the superseded 2022 framework is working with outdated regulatory guidance.

The material additions and changes in the 2025 Directions that affect NBFC applicants include:

9.1 DLA Reporting on CIMS. All Digital Lending Apps operated by the NBFC or by any Lending Service Provider engaged by it must be reported through the CIMS portal. The NBFC’s Chief Compliance Officer or an authorised official must certify compliance. This is a pre-commencement obligation for new registrants, not a post-launch requirement.

9.2 Multi-Lender LSP Arrangements. Where an LSP partners with multiple regulated entities, the 2025 Directions mandate transparent disclosure of all potential lenders to borrowers and prohibit any bias in the presentation of loan offers. This provision, which was not in the 2022 framework, must be reflected in LSP agreements entered into by new NBFC registrants.

9.3 Enhanced DLG Due Diligence. The Default Loss Guarantee framework, which governs first-loss credit protection arrangements between NBFCs and their LSP or co-lending partners, now requires enhanced due diligence on DLG providers, with additional restrictions on DLG arrangements for revolving credit facilities, credit-guarantee-scheme-covered loans, and loans facilitated by NBFC-P2P platforms. The contractual DLG framework must be designed to comply with the 2025 Directions from the outset.

9.4 No Pass-Through Accounts. The prohibition on pass-through accounts — that is, routing loan disbursals or repayments through LSP or third-party accounts rather than directly between the borrower and the NBFC — is reaffirmed in the 2025 Directions. This is an absolute requirement that cannot be contracted around. An application whose business plan describes a fund-flow architecture that relies on pass-through accounts will not succeed.

10. Post-Registration Compliance for Hyderabad NBFCs

The Certificate of Registration marks the beginning of a sustained regulatory relationship with the RBI, not the conclusion of the advisory engagement. The compliance obligations that arise after registration are comprehensive and continuing.

Statutory Audit: Annual statutory audit by a Statutory Auditor, with a separate auditor’s certificate submitted to the RBI confirming compliance with specified regulatory ratios.

CIMS Returns: Periodic returns through the CIMS platform covering asset quality, capital adequacy, and other regulatory metrics. Late filing attracts penalties. For digital lenders, the CIMS obligation extends to ongoing DLA reporting.

NOF Maintenance: The minimum Net Owned Fund must be maintained at all times after registration, not merely at the point of application. Where an NBFC’s NOF falls below the minimum, the shortfall must be reported to the RBI and corrective action taken promptly.

Change-in-Control Approvals: Any transfer of ownership that results in a change of management control requires prior RBI approval under the RBI (Non-Banking Financial Companies — Acquisition of Shareholding or Control) Directions, 2025 (RBI Id 12964, issued 28 November 2025). This requirement applies to mergers, acquisitions, and significant share transfers. NBFC promoters planning exit transactions must factor RBI approval timelines into their transaction structure.

Scale Based Regulation Classification: Under the SBR framework, as an NBFC grows in asset size and systemic relevance, it may transition from the Base Layer to the Middle or Upper Layer. Each layer carries progressively more intensive regulatory requirements. Post-registration compliance planning must account for this growth trajectory.

11. Where Hyderabad NBFC Applications Stall: Four Common Failure Points

Based on the pattern of NBFC registration applications and the RBI’s query responses, the following are the most consistently encountered failure points for applicants from the Hyderabad and Telangana region.

11.1 The Jurisdiction Mismatch. As discussed in Section 1, applicants who direct their physical submissions or post-PRAVAAH correspondence to the wrong RBI office — Hyderabad RO when the company is incorporated in Andhra Pradesh, or vice versa — create administrative delays. This is particularly relevant given that both offices currently share a building. Confirming the precise correspondence protocol with the relevant office before submission avoids this avoidable complication.

11.2 Fintech Business Plans Prepared Against the Superseded 2022 Framework. The RBI (Digital Lending) Directions, 2025 represent a material update to the regulatory framework for digital lenders. Applications whose business plans, LSP agreements, and DLG frameworks are designed against the old framework will attract queries. A consultant or legal advisor who has not updated their templates to reflect the 2025 Directions is a risk factor for the application.

11.3 Pharma and Technology Sector Source-of-Funds Complexity. Hyderabad’s promoter community often draws capital from family groups with diversified business interests across pharma, real estate, and technology. Capital that moves through multiple entities, family trusts, or HUF structures before arriving as paid-up capital in the NBFC applicant company creates source-of-funds documentation challenges. The RBI traces capital flows back through each intermediate entity. Preparing this documentation chain in advance of filing — not in response to a query — is the more efficient approach.

11.4 NBFC-MFI Applicants Underestimating the Business Plan Standard. The Telangana and Andhra Pradesh MFI sector carries regulatory history. NBFC-MFI applicants from the region should anticipate careful scrutiny of their borrower protection frameworks, credit assessment methodologies, and grievance redressal systems. A generic business plan borrowed from a template will not carry the weight of the RBI’s review. The plan must specifically address how the proposed MFI will operate in a market where the regulator has direct experience of prior sector failures.

12. Why Choose CA Murli Chandak as Your NBFC Consultant in Hyderabad

I am a Chartered Accountant and IBBI Registered Valuer (Registration No. IBBI/RV/07/2021/14408), practicing from Ahmedabad with a national NBFC advisory and financial valuation practice. My work with promoters across Telangana, Andhra Pradesh, and the wider country is built on direct engagement with the regulatory framework — not on standardised templates produced at scale.

The advisory I provide covers the full lifecycle of the NBFC registration process: pre-incorporation structuring, objects clause drafting, board composition review, Net Owned Fund documentation, business plan preparation compliant with current RBI requirements, PRAVAAH filing management, RBI query responses, and post-registration compliance support. For digital lenders in Hyderabad’s fintech sector, this includes specific advisory on LSP structuring, DLG framework design, and DLA reporting compliance under the RBI (Digital Lending) Directions, 2025.

I do not oversell timelines, I do not represent that I have any special access to or influence over the RBI’s internal decision-making, and I do not deliver generic documentation at the quality level that invites queries and delays. The value of the engagement lies in the quality of the preparation — and in the avoidance of the recoverable errors that most applicants would otherwise make.

13. Frequently Asked Questions

Q1. Which RBI office handles NBFC applications for Hyderabad-based companies?
If your company is incorporated in Telangana, your application is handled by the RBI Hyderabad Regional Office (rdhyderabad@rbi.org.in). If incorporated in Andhra Pradesh, it is handled by the RBI Andhra Pradesh Regional Office. Both offices are currently at the same Secretariat Road, Saifabad address, but they are separate regulatory units.

Q2. What is the minimum capital required for NBFC registration in Hyderabad?
The minimum Net Owned Fund depends on the NBFC category. NBFC-ICCs and NBFC-MFIs require Rs. 10 crore. NBFC-Factors require Rs. 5 crore. NBFC-P2P and NBFC-AA platforms require Rs. 2 crore. NBFC-IFCs require Rs. 300 crore. HFCs require Rs. 25 crore. These figures should be confirmed against the applicable Master Directions at the time of your application.

Q3. Can an LLP or partnership firm register as an NBFC?
No. Only a company incorporated under the Companies Act, 2013 or its predecessor is eligible. Limited Liability Partnerships, partnership firms, trusts, and sole proprietorships are not eligible, regardless of their size or capital.

Q4. Is the RBI’s 2022 Digital Lending Circular still in force?
No. The RBI (Digital Lending) Directions, 2025, issued on 8 May 2025, consolidated and replaced the 2022 Digital Lending Guidelines and the 2023 DLG Guidelines. Applications and LSP frameworks designed against the 2022 circular are based on superseded guidance.

Q5. How long does NBFC registration take?
For well-prepared, complete applications involving straightforward business models, the process has historically taken six to twelve months from PRAVAAH submission to receipt of the Certificate of Registration. Complex fintech applications, or those involving multi-entity structures, have taken twelve to twenty-four months. No consultant can guarantee a specific timeline. The RBI’s internal processing capacity and the quality of the initial application are the primary variables.

Q6. What is the PRAVAAH portal and is the COSMOS system still used?
PRAVAAH — Platform for Regulatory Application, VAlidation And AutHorisation — is the RBI’s mandatory digital channel for NBFC registration applications. The COSMOS system has been replaced. Applications prepared on COSMOS-era templates are not appropriate for current submissions.

Q7. What ongoing compliances apply after registration?
Annual statutory audit with auditor certification to the RBI, periodic CIMS regulatory returns, NOF maintenance at all times, board governance in accordance with applicable Master Directions, prior RBI approval for any change in management control, and (for digital lenders) ongoing CIMS-based DLA reporting and compliance with the RBI (Digital Lending) Directions, 2025.

Q8. I am a pharma-sector company in Hyderabad considering a factoring NBFC. What are the key requirements?
NBFC-Factor registration requires a minimum Net Owned Fund of Rs. 5 crore. The company must be registered under the Factoring Regulation Act, 2011. At least 75 per cent of qualifying assets must consist of factoring assets — trade receivables purchased from third-party businesses. The business plan must address the receivables pipeline, underwriting framework, and credit quality of the receivable obligors. For pharma supply chain applications, the plan should specifically address the characteristics of the receivable base — invoice tenors, counterparty quality, and sector concentration risk.

Q9. What is the Scale Based Regulation framework and does it affect new NBFCs?
The SBR framework, set out in the RBI (Non-Banking Financial Companies — Registration, Exemptions and Framework for Scale Based Regulation) Directions, 2025 (issued 28 November 2025), classifies NBFCs into four layers — Base, Middle, Upper, and Top — based on asset size, complexity, and systemic importance. New registrants typically enter at the Base Layer, which carries the least intensive compliance requirements. However, the compliance plan for a fast-growing NBFC should account for the more intensive obligations that attach as it moves into the Middle or Upper Layer.

Q10. Can credit decisions be outsourced to a technology partner in a digital lending model?
No. The RBI is explicit, in both the 2022 Guidelines and the 2025 Directions, that credit decisions must be made by or under the direction of the regulated entity. Technology partners may provide credit assessment inputs, but the ultimate credit decision authority cannot be contractually transferred to an LSP or any other third party. An application whose business plan describes outsourced underwriting without adequate NBFC-level oversight will not be approved.

14. Conclusion

NBFC registration in Hyderabad is a structured, demanding regulatory process — and the current framework is materially more detailed than it was even twelve months ago. The consolidated Scale Based Regulation Master Directions of November 2025, the RBI (Digital Lending) Directions of May 2025, and the clear separation of the Hyderabad and Andhra Pradesh Regional Offices are all developments that affect applications filed from the region today. Working with an advisor who is current on all three of these points — not one working from prior-year templates — is the foundation of a well-prepared application.

Whether you are assessing whether your business model requires registration, preparing to begin the PRAVAAH filing process, structuring an LSP arrangement for a digital lending operation, or managing ongoing post-CoR compliance, I am available to provide specific, current advisory drawn from direct engagement with the RBI’s framework.

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All information in this article is for general informational purposes and does not constitute legal, regulatory, or financial advice. Regulatory requirements are subject to change. Readers should verify current requirements with the Reserve Bank of India or engage qualified professional advisors before taking any decisions. CA Murli Chandak is an IBBI Registered Valuer (IBBI/RV/07/2021/14408) and Chartered Accountant. The views expressed are personal and professional.