NBFC Consultant in Mumbai: CA Murli Chandak’s Guide to RBI Registration, Net Owned Fund Certification and Life After the CoR

<p><strong>In short:</strong> An NBFC’s Certificate of Registration is issued by the Reserve Bank of India, but almost everything RBI actually scrutinises before issuing it — the Net Owned Fund figure, the statutory auditor’s certificate behind it, the five-year business plan, and the “fit and proper” file on every director — is financial and certification work, not a form-filling exercise. That is the part of an NBFC application a Chartered Accountant and Registered Valuer actually does, and it is where most Mumbai applications I have looked at either move cleanly through RBI’s Department of Regulation or stall on a query that a better-prepared certificate would have avoided. A standard NBFC-Investment and Credit Company today needs a minimum Net Owned Fund of ₹10 crore, filed entirely through RBI’s PRAVAAH portal, which replaced the older COSMOS system for every RBI-regulated entity from 1 May 2025. A 2026 change also matters for a specific kind of Mumbai company: RBI’s Amendment Directions, issued on 29 April 2026 and effective 1 July 2026, exempt NBFCs with no public funds, no customer interface and assets below ₹1,000 crore from registration altogether. This guide covers what actually makes a company an NBFC, the Net Owned Fund by category, where I see applications genuinely stall, the registration route, the 2026 changes, what registration costs, what RBI actually watches after the CoR is issued, and how I support a Mumbai company through the registration and certification work.</p>
<p><em>By CA Murli Chandak, FCA — Fellow Chartered Accountant and IBBI-Registered Valuer (Securities or Financial Assets), registration IBBI/RV/07/2021/14408, with 8+ years in valuation, audit and advisory practice. Regulatory citations verified against RBI’s own notifications and press releases as at September 2026.</em></p>
<h2>Contents</h2>
<ol>
<li><a href=”#fit”>1. Where a Chartered Accountant Fits in an NBFC’s Relationship With RBI</a></li>
<li><a href=”#what-is-nbfc”>2. What Actually Makes a Company an NBFC</a></li>
<li><a href=”#categories”>3. NBFC Categories and Net Owned Fund at a Glance</a></li>
<li><a href=”#stall-points”>4. Where I See NBFC Applications Actually Stall</a></li>
<li><a href=”#process”>5. The PRAVAAH Registration Route, Step by Step</a></li>
<li><a href=”#2026-changes”>6. The 2026 Change Every Mumbai NBFC — or Would-Be NBFC — Should Track</a></li>
<li><a href=”#costs”>7. What Registration Actually Costs</a></li>
<li><a href=”#after-cor”>8. After the CoR: What RBI Actually Watches, and What It Doesn’t</a></li>
<li><a href=”#services”>9. What I Do for a Mumbai NBFC Applicant</a></li>
<li><a href=”#faq”>10. Frequently Asked Questions</a></li>
<li><a href=”#contact”>Discuss Your NBFC Registration</a></li>
</ol>
<h2 id=”fit”>1. Where a Chartered Accountant Fits in an NBFC’s Relationship With RBI</h2>
<p>RBI’s Department of Regulation does not read an NBFC application the way it reads a company incorporation filing. Section 45-IA of the Reserve Bank of India Act, 1934 puts the burden of proof on the applicant to demonstrate, in numbers RBI can independently verify, that the Net Owned Fund is real, unencumbered and correctly computed; that the five-year business plan is specific to the company rather than a template; and that every director and significant shareholder clears the “fit and proper” test. None of that is drafting work — it is accounting, certification and financial-structuring work, sitting inside the same Chartered Accountancy practice that does the company’s statutory audit, its concurrent audit if it later needs one, and, where the company later raises capital or restructures, its business valuation.</p>
<p>That overlap is not incidental to how I approach an NBFC engagement in Mumbai. The statutory auditor’s certificate confirming Net Owned Fund, the restated financials RBI’s Department of Regulation reviews alongside the business plan, and — for an NBFC that later needs one under RBI’s concurrent audit norms — the audit itself, all draw on the same certification discipline. A promoter who brings in a generalist company-registration agent for the PRAVAAH filing and a separate CA for the NOF certificate is coordinating two parties on the one document RBI checks first; keeping that work inside one practice removes that coordination gap.</p>
<h2 id=”what-is-nbfc”>2. What Actually Makes a Company an NBFC</h2>
<p>Section 45-I(f) of the RBI Act, 1934 defines a non-banking financial company, but the test that actually decides whether a company needs to register is the <strong>50-50 test</strong>: a company is treated as conducting financial business as its principal business if more than 50% of its total assets are financial assets, and more than 50% of its gross income comes from those assets. A company that clears this test cannot commence or carry on non-banking financial business without a Certificate of Registration from RBI under Section 45-IA — and RBI has been explicit and consistent, in decades of press releases going back to the 1990s, that doing so anyway is a criminal offence: Section 58B(4A) of the RBI Act provides for imprisonment of one to five years and a fine of ₹1 lakh to ₹5 lakh for contravening Section 45-IA(1). I mention the exact figures because they are cited inconsistently online — some online guides quote a fine running into crores, which is not what the Act or RBI’s own press releases actually specify.</p>
<p>Two structural points matter before a promoter goes further. First, only a company incorporated under the Companies Act, 2013 (or its 1956 predecessor) can hold a Certificate of Registration — an individual, partnership or LLP cannot register directly, which is worth confirming early if the business is currently running out of a partnership or LLP structure. Second, several categories that look like financial businesses are carved out of RBI’s NBFC framework because they are already regulated elsewhere: Nidhi companies (Ministry of Corporate Affairs), chit-fund companies, and entities regulated by SEBI or IRDAI for their core activity. Housing finance companies are the one category that moved the other way — transferred from the National Housing Bank to RBI’s own regulatory umbrella in 2019, and now registered and supervised by RBI directly rather than as a separate exemption.</p>
<h2 id=”categories”>3. NBFC Categories and Net Owned Fund at a Glance</h2>
<p>The category a company registers under sets its Net Owned Fund floor, its permitted activities, and its ongoing compliance load for the life of the company — which makes this a decision worth getting right at the outset rather than revisiting after the business plan is drafted.</p>
<table style=”width: 100%; border-collapse: collapse; margin: 20px 0;”>
<thead>
<tr style=”background-color: #12284C; color: #ffffff;”>
<th style=”padding: 10px 12px; border: 1px solid #d5dbe4; text-align: left;”>Category</th>
<th style=”padding: 10px 12px; border: 1px solid #d5dbe4; text-align: left;”>What it does</th>
<th style=”padding: 10px 12px; border: 1px solid #d5dbe4; text-align: left;”>Minimum Net Owned Fund</th>
</tr>
</thead>
<tbody>
<tr>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>NBFC-ICC (Investment and Credit Company)</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>The broadest category — lending, investment in shares and securities, and related financing under one licence. Most first-time Mumbai applicants start here.</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>₹10 crore, effective 1 October 2022</td>
</tr>
<tr style=”background-color: #f7f9fc;”>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>NBFC-Factor</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>Purchases receivables from businesses at a discount; factoring must be the company’s principal business.</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>₹10 crore, effective 1 October 2022</td>
</tr>
<tr>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>NBFC-MFI</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>Micro-finance lending to low-income borrowers, subject to income-linked eligibility and lending caps.</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>₹10 crore, effective 1 October 2022 (₹10 crore also applies in the North Eastern region under the same glide path)</td>
</tr>
<tr style=”background-color: #f7f9fc;”>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>NBFC-P2P and Account Aggregator</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>A P2P platform connects individual lenders and borrowers without lending on its own book; an Account Aggregator shares a customer’s financial data across institutions with consent, without holding funds.</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>₹2 crore</td>
</tr>
<tr>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>Housing Finance Company</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>Finances housing as its principal business; registered with and regulated by RBI directly since 2019.</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>₹20 crore, under RBI’s Master Direction on Housing Finance Companies</td>
</tr>
<tr style=”background-color: #f7f9fc;”>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>Infrastructure Finance Company / Infrastructure Debt Fund-NBFC</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>Long-tenor financing for infrastructure projects — the highest Net Owned Fund floor of any category, alongside a dedicated capital-adequacy norm.</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>₹300 crore, with a minimum CRAR of 15% (Tier-I capital at least 10%)</td>
</tr>
<tr>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>Core Investment Company (CIC)</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>Holds investments in group companies’ shares and debt for group-structuring purposes rather than public-facing lending.</td>
<td style=”padding: 10px 12px; border: 1px solid #d5dbe4;”>Exempt from registration below ₹100 crore in asset size; registration and a separate capital framework apply above that threshold</td>
</tr>
</tbody>
</table>
<p>Net Owned Fund itself is computed under Section 45-IA — broadly, paid-up equity capital and free reserves, reduced by accumulated losses, deferred revenue expenditure and other intangible assets, and adjusted for certain investments in and loans to group companies. It has to be unencumbered and evidenced by a statutory auditor’s certificate; RBI does not accept a Net Owned Fund figure that cannot be traced to an actual, lien-free deposit, which is the certification step described in Section 1 above and the first thing I check before a filing goes anywhere near PRAVAAH.</p>
<h2 id=”stall-points”>4. Where I See NBFC Applications Actually Stall</h2>
<p>RBI does not give partial credit for an application that is mostly right, and a query or a rejection costs a promoter months rather than weeks before a refiling is realistic. In the applications I have reviewed or worked on, the same handful of issues account for most of that delay:</p>
<ul>
<li><strong>A Net Owned Fund certificate the bank confirmation doesn’t quite match.</strong> The statutory auditor’s certificate has to reconcile exactly to a bank confirmation that the fixed deposit carries no lien — a mismatch here, even a small one, is one of the fastest ways to draw a clarification round.</li>
<li><strong>A business plan that reads as templated.</strong> RBI’s Department of Regulation reviews the five-year business plan closely for whether the target market, financial projections and risk-management approach are specific to that company. A plan that could describe any NBFC-ICC in the country is a common reason applications stall, and it is not a drafting problem — it needs financial projections that are actually defensible against the promoter’s own numbers.</li>
<li><strong>Incomplete “fit and proper” documentation.</strong> Every director and every shareholder above the relevant threshold needs KYC, a credit report, and RBI expects at least one full-time director with genuine banking or financial-services experience. Gaps here surface late, often after the first round of RBI queries, if they are not checked before filing.</li>
<li><strong>Digital lending, LSP and DLG arrangements treated as an afterthought.</strong> For any Mumbai company with a fintech or digital-lending model, RBI’s clarification rounds now routinely examine Lending Service Provider and Default Loss Guarantee arrangements in detail. Treating these as core filing material from day one, rather than something to explain if RBI asks, materially shortens the process.</li>
<li><strong>An objects clause or shareholding structure that needs to be unwound later.</strong> Getting the company’s objects clause, shareholding pattern and director selection right before incorporation is measurably cheaper than restructuring a company after RBI has already started reviewing it.</li>
</ul>
<h2 id=”process”>5. The PRAVAAH Registration Route, Step by Step</h2>
<p>Every RBI-regulated entity, including a new NBFC Certificate of Registration application, has filed exclusively through RBI’s <a href=”https://pravaah.rbi.org.in” target=”_blank” rel=”nofollow noopener”>PRAVAAH portal</a> (Platform for Regulatory Application, Validation and Authorisation) since it became mandatory on 1 May 2025, replacing the older COSMOS system. The route, in outline:</p>
<ol>
<li><strong>Incorporate the company</strong> under the Companies Act, 2013, with an objects clause that clearly covers financial or NBFC activity, and obtain DIN and DSC for every proposed director.</li>
<li><strong>Infuse and certify the Net Owned Fund</strong> for the chosen category, deposited as an unencumbered fixed deposit in a scheduled commercial bank, supported by the statutory auditor’s certificate described above.</li>
<li><strong>Build the five-year business plan</strong> and assemble the “fit and proper” documentation for every relevant director and shareholder.</li>
<li><strong>File on PRAVAAH</strong>, creating an applicant login and completing the Certificate of Registration application with the full document set, receiving a Company Application Reference Number (CARN) on submission.</li>
<li><strong>Submit the physical application</strong> — a paginated hard copy with the CARN acknowledgement — to the Regional Office of RBI’s Department of Regulation with jurisdiction over the company’s registered office. For a Mumbai-registered company, this is the same Regional Office that sits alongside RBI’s Central Office in Fort, which administers the Scale-Based Regulation framework nationally.</li>
<li><strong>Respond to RBI’s queries</strong>, typically across one or more rounds, and receive the Certificate of Registration once RBI is satisfied on eligibility, Net Owned Fund, business plan and promoter background.</li>
</ol>
<p>Timelines vary with how complete the filing is at the outset: a well-prepared, straightforward NBFC-ICC application commonly clears in roughly 3 to 6 months from the PRAVAAH filing date, while a digital-lending, LSP or DLG structure, or an application that draws several rounds of RBI clarification, can run 9 to 14 months. Section 45-IA sets no statutory deadline for RBI to decide, so there is no fixed backstop to plan against — which is exactly why the certification work in Sections 1 and 4 carries more weight than the filing mechanics themselves.</p>
<h2 id=”2026-changes”>6. The 2026 Change Every Mumbai NBFC — or Would-Be NBFC — Should Track</h2>
<p>RBI’s <a href=”https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13407&Mode=0″ target=”_blank” rel=”nofollow noopener”>Reserve Bank of India (Non-Banking Financial Companies – Registration, Exemptions and Framework for Scale Based Regulation) Amendment Directions, 2026</a>, issued on 29 April 2026 and in force from 1 July 2026, is directly relevant to a certain kind of Mumbai company — typically a group holding, treasury or investment vehicle rather than a customer-facing lender:</p>
<ul>
<li><strong>Exempt entirely:</strong> a company that neither avails public funds (including indirect public funds) nor has any customer interface, and whose asset size stays below ₹1,000 crore on its latest audited balance sheet, is now exempt from registration under Section 45-IA and from the reserve-fund requirement under Section 45-IC.</li>
<li><strong>Registers as “Type I NBFC”:</strong> a company with the same profile — no public funds, no customer interface — but an asset size of ₹1,000 crore or more must still register, specifically as a Type I NBFC, through PRAVAAH.</li>
<li><strong>Registers as “Type II NBFC”:</strong> any NBFC that does access public funds or does have a customer interface registers under the standard framework this guide otherwise describes.</li>
</ul>
<p>Existing NBFCs, including those already holding a CoR as a Type I NBFC, have a one-time window to apply for deregistration through PRAVAAH, by 31 December 2026, supported by three years of audited financials, a statutory auditor’s certificate confirming the absence of public funds and customer interface, and a board resolution undertaking not to access either in future. RBI has been explicit that a deregistration application it is not satisfied is genuine will be refused, so this is not a simple administrative filing for a group looking to shed its compliance burden — it is, again, a certification exercise, and the auditor’s certificate is the document RBI will actually test.</p>
<h2 id=”costs”>7. What Registration Actually Costs</h2>
<p>Three cost layers apply, and only the first is capital rather than expense:</p>
<ul>
<li><strong>The Net Owned Fund itself</strong> — ₹10 crore for a standard NBFC-ICC — held as an unencumbered deposit, not spent; it is capital deployed into the business.</li>
<li><strong>RBI’s own application fee</strong> — published guidance on the current figure is genuinely inconsistent following the move to PRAVAAH, with some sources still quoting the older COSMOS-era figure and others describing the fee as not separately prescribed under the current framework. Rather than repeat a number that risks being wrong, I confirm the exact current fee against RBI’s own published schedule immediately before filing, and would rather tell a client that directly than guess.</li>
<li><strong>Professional and incidental costs</strong> — company incorporation, notarisation and stamp costs for declarations and affidavits, the statutory auditor’s Net Owned Fund certificate, and my own fee for the business plan, the certification work and managing RBI’s queries through to the CoR, quoted separately from the outset so a promoter can see what is capital, what is a regulatory cost, and what is advisory fee before filing begins.</li>
</ul>
<h2 id=”after-cor”>8. After the CoR: What RBI Actually Watches, and What It Doesn’t</h2>
<p>The Certificate of Registration is the start of an ongoing compliance relationship with RBI, not the end of one. A registered NBFC is expected to maintain a minimum Capital to Risk-Weighted Assets Ratio (CRAR) of 15%, file periodic regulatory returns whose frequency depends on the company’s Scale-Based Regulation layer, operate under a board-approved Fair Practices Code, and run KYC and anti-money-laundering procedures consistent with RBI’s Master Directions.</p>
<p>It is worth being precise here, because a claim I have seen repeated in other guides overstates what is actually happening. RBI does cancel or accept the surrender of NBFC Certificates of Registration in large batches, almost every month — <a href=”https://website.rbi.org.in/web/rbi/-/press-releases/rbi-cancels-certificate-of-registration-of-35-nbfcs” target=”_blank” rel=”nofollow noopener”>RBI’s own press releases dated 7 January 2026</a> record the cancellation of 35 NBFCs and the accepted surrender of another 16 in a single week, on top of similar batches through 2025 and into 2026. But the reasons RBI publishes alongside these batches are overwhelmingly administrative: voluntary exit from the business, ceasing to exist as a legal entity through amalgamation, merger, dissolution or voluntary strike-off, or reclassification as an exempt, unregistered Core Investment Company — not, in most cases, a supervisory finding against the company. Where RBI does penalise an operating NBFC for a genuine compliance failure, such as a breach of the Fair Practices Code, that action typically takes the form of a monetary penalty under Section 58G(1)(b) read with Section 58B(5)(aa) of the RBI Act — a different legal mechanism from cancellation of the CoR under Section 45-IA(6), and one that leaves the company registered and operating while it corrects the failure. The practical point for a promoter is the same either way: the compliance calendar — CRAR, returns, the Fair Practices Code, KYC/AML — is not a formality to revisit if RBI writes, and I build it into the engagement from day one rather than treating it as a separate, later conversation.</p>
<h2 id=”services”>9. What I Do for a Mumbai NBFC Applicant</h2>
<p>NBFC work in this practice sits squarely inside the certification and financial-structuring work described above, alongside the coordination needed to take an application through to the CoR:</p>
<ul>
<li><strong>Eligibility and category assessment</strong>, including whether the 2026 Type I NBFC exemption removes the need to register at all.</li>
<li><strong>Net Owned Fund computation and the statutory auditor’s certificate</strong> RBI’s Department of Regulation actually accepts on first submission, reconciled to the bank’s lien confirmation before it goes anywhere near PRAVAAH.</li>
<li><strong>The five-year business plan and financial projections</strong>, built from the company’s actual model rather than a template, and the “fit and proper” documentation for directors and significant shareholders.</li>
<li><strong>PRAVAAH filing and the physical application set</strong> for RBI’s Mumbai Regional Office, and responses to RBI’s rounds of clarification through to the Certificate of Registration.</li>
<li><strong>Post-registration compliance</strong>, including the CRAR, returns, Fair Practices Code and KYC/AML calendar, and — where the company’s scale calls for it — the concurrent audit work this practice already carries out for financial-sector clients.</li>
<li><strong>Valuation continuity beyond registration day</strong>, where an NBFC registration sits alongside a fundraise, an ESOP grant, or a later change of control, drawing on the same <a href=”https://murlichandak.com/registered-valuer-in-mumbai/”>Registered Valuer</a> work already in place for Mumbai clients.</li>
</ul>
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<p style=”margin-top: 0;”><strong>Weighing an NBFC registration, or checking where your Mumbai application actually stands?</strong></p>
<p>If you would like an independent view on eligibility, the Net Owned Fund certificate, or where a stalled application is likely to be stuck, I can walk through it on a short call.</p>
<p style=”margin-bottom: 0; display: flex; flex-wrap: wrap; gap: 14px; align-items: center;”><a style=”display: inline-block; background: #12284C; color: #ffffff; padding: 12px 26px; border-radius: 4px; text-decoration: none; font-weight: 600; white-space: nowrap;” href=”https://murlichandak.com/contact/”>Book a Free Consultation</a><a style=”display: inline-block; background: #25D366; color: #ffffff; padding: 12px 26px; border-radius: 4px; text-decoration: none; font-weight: 600; white-space: nowrap;” href=”https://wa.me/919998539902″>Chat on WhatsApp</a></p>
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<p style=”margin-top: 0;”><strong>Why Choose CA Murli Chandak</strong></p>
<p>I am a Fellow Chartered Accountant with over 8 years in practice, including a partnership at a Chartered Accountancy firm, and an IBBI-Registered Valuer for Securities or Financial Assets, registration number IBBI/RV/07/2021/14408. My practice’s core work — DCF and FCFE equity valuations, Net Asset Value workings, ESOP valuations, impairment testing and concurrent audit — already produces the exact category of certificate RBI’s Department of Regulation checks first in an NBFC application: restated financials, a statutory auditor’s certificate that reconciles to the bank, and a business plan built from real projections rather than a template.</p>
<p style=”margin-bottom: 0;”>I work with Mumbai companies from an Ahmedabad-based practice on a video-first model, with in-person availability where an engagement calls for it — the same remote-delivery approach already in place for Mumbai clients on <a href=”https://murlichandak.com/registered-valuer-in-mumbai/”>Registered Valuer</a>, <a href=”https://murlichandak.com/virtual-cfo-in-mumbai/”>Virtual CFO</a>, <a href=”https://murlichandak.com/transfer-pricing-consultant-in-mumbai/”>Transfer Pricing</a> and <a href=”https://murlichandak.com/gst-consultant-in-mumbai/”>GST</a> matters.</p>
</div>
<h2 id=”faq”>10. Frequently Asked Questions</h2>
<h3>Q1. What does an NBFC consultant actually do that a company-registration agent doesn’t?</h3>
<p><strong>A:</strong> A registration agent typically handles the PRAVAAH filing mechanics. The work that actually decides whether RBI approves the application — the Net Owned Fund certificate, the business plan’s financial projections, and the “fit and proper” documentation — is accounting and certification work, which is why I run it inside the same practice that does the company’s audit and valuation work rather than handing it to a separate filing agent.</p>
<h3>Q2. Is the RBI application fee still ₹50,000?</h3>
<p><strong>A:</strong> That figure is repeated widely online, but it dates to the older COSMOS-era process. Guidance on the current fee under PRAVAAH is inconsistent across published sources, so I confirm the exact figure against RBI’s own schedule immediately before filing rather than quote a number that may no longer be accurate.</p>
<h3>Q3. Can a CA’s certificate really be the reason an application stalls?</h3>
<p><strong>A:</strong> Yes — the Net Owned Fund certificate has to reconcile exactly to the bank’s confirmation that the deposit carries no lien, and a mismatch here is one of the fastest ways to draw an RBI clarification round. It is a small document with an outsized effect on the timeline.</p>
<h3>Q4. What is Net Owned Fund, and how is it different from paid-up capital?</h3>
<p><strong>A:</strong> Net Owned Fund is paid-up equity capital plus free reserves, reduced by accumulated losses, deferred revenue expenditure and intangible assets, and adjusted for certain investments in and loans to group companies, under Section 45-IA of the RBI Act. It is usually lower than headline paid-up capital once these deductions are applied, which is why it needs to be computed, not assumed.</p>
<h3>Q5. Do I need the full ₹10 crore even if I plan to start small?</h3>
<p><strong>A:</strong> For a new NBFC-ICC, NBFC-Factor or NBFC-MFI application, yes — ₹10 crore has applied to new applicants since 1 October 2022. The lower categories (NBFC-P2P and Account Aggregator, at ₹2 crore) exist precisely for business models that don’t need the ICC’s broader lending and investment scope.</p>
<h3>Q6. My company doesn’t take public funds or deal with customers directly — do I need to register from July 2026?</h3>
<p><strong>A:</strong> Only if your asset size reaches ₹1,000 crore or more, in which case you register as a Type I NBFC. Below that threshold, RBI’s Amendment Directions effective 1 July 2026 exempt such a company from registration and from the Section 45-IC reserve-fund requirement entirely — worth checking before assuming registration is required.</p>
<h3>Q7. How long does registration actually take?</h3>
<p><strong>A:</strong> A well-prepared, straightforward NBFC-ICC application typically clears in 3 to 6 months from the PRAVAAH filing date. Digital-lending, LSP or DLG structures, or applications needing several rounds of RBI clarification, commonly run 9 to 14 months. RBI has no statutory deadline to decide.</p>
<h3>Q8. If RBI cancels an NBFC’s registration, is that always because of a compliance failure?</h3>
<p><strong>A:</strong> Usually not. Most cancellation batches RBI publishes cite voluntary exit, mergers, dissolution or reclassification as an exempt Core Investment Company — administrative reasons, not supervisory findings. Genuine compliance failures, such as Fair Practices Code breaches, more often draw a monetary penalty under Section 58G while the company stays registered.</p>
<h3>Q9. Can my regular auditor issue the Net Owned Fund certificate, or does it need to be someone specific?</h3>
<p><strong>A:</strong> It needs to be the company’s statutory auditor, and the certificate needs to say precisely what RBI expects — the computation method and the unencumbered, lien-free status of the deposit, reconciled to the bank’s own confirmation. A generic net-worth certificate is not the same document.</p>
<h3>Q10. What’s the single most common reason a Mumbai NBFC application takes longer than expected?</h3>
<p><strong>A:</strong> A business plan that reads as generic rather than built from the company’s actual numbers. RBI’s Department of Regulation reviews this document closely, and a plan assembled from a template is one of the more common reasons for a clarification round or an outright stall.</p>
<h3>Q11. Can I bring you in only for post-registration compliance, if the registration itself was handled elsewhere?</h3>
<p><strong>A:</strong> Yes — the CRAR, returns, Fair Practices Code and KYC/AML calendar, and any later valuation work tied to a fundraise, ESOP grant or change of control, can be taken on independently of who handled the original PRAVAAH filing.</p>
<h2 id=”contact”>Discuss Your NBFC Registration</h2>
<p>If your Mumbai company is weighing an NBFC registration, checking where a stalled application actually stands, or setting up post-CoR compliance, tell me where things are today and I can map out what’s still needed.</p>
<p><strong>CA Murli Chandak – FCA | IBBI-Registered Valuer (Securities or Financial Assets) | IBBI/RV/07/2021/14408</strong><br />
Website: <a href=”https://murlichandak.com/”>murlichandak.com</a><br />
Phone: +91 99985 39902<br />
Email: <a href=”mailto:murlichandak@murlichandak.com”>murlichandak@murlichandak.com</a><br />
LinkedIn: <a href=”https://www.linkedin.com/in/ca-murli-chandak-69b68080/” target=”_blank” rel=”noopener”>Connect with CA Murli Chandak</a></p>
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<p><em>This article is intended for general guidance only and does not constitute legal, financial or regulatory advice. Regulatory positions are stated as at September 2026 and were verified against the Reserve Bank of India Act, 1934, RBI’s Reserve Bank of India (Non-Banking Financial Companies – Registration, Exemptions and Framework for Scale Based Regulation) Amendment Directions, 2026 (notified 29 April 2026, effective 1 July 2026), RBI’s Master Direction on Housing Finance Companies, RBI’s PRAVAAH portal documentation, and RBI press releases on NBFC registration cancellations. Thresholds, fees and timelines under the RBI framework are revised from time to time and should be confirmed against RBI’s current notifications on the date of filing.</em></p>
<p><strong>Related reading:</strong> <a href=”https://murlichandak.com/registered-valuer-in-mumbai/”>Registered Valuer in Mumbai</a> | <a href=”https://murlichandak.com/virtual-cfo-in-mumbai/”>Virtual CFO in Mumbai</a> | <a href=”https://murlichandak.com/gst-consultant-in-mumbai/”>GST Consultant in Mumbai</a> | <a href=”https://murlichandak.com/transfer-pricing-consultant-in-mumbai/”>Transfer Pricing Consultant in Mumbai</a> | <a href=”https://murlichandak.com/ipo-consultant-in-mumbai/”>IPO Consultant in Mumbai</a></p>
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