Introduction
The Non-Banking Financial Company sector in India operates under one of the most detailed regulatory frameworks in the financial services industry. For businesses based in Kolkata — whether a family-run lending enterprise, an MSME-focused trade financier, or a fintech startup building a digital credit product — navigating the requirements of the Reserve Bank of India and the Ministry of Corporate Affairs demands careful planning, accurate documentation and a thorough understanding of applicable law.
At CA Murli Chandak, we work with promoters and companies across India to structure NBFC applications, secure RBI registration and build robust compliance frameworks. This guide sets out everything a promoter, director or management team in Kolkata needs to understand before initiating the NBFC registration process — from threshold conditions and minimum capital requirements to the step-by-step application process, post-registration compliance and how to evaluate advisory credentials.
1. What Does an NBFC Consultant in Kolkata Do?
An NBFC consultant is a specialist advisor who guides promoters and companies through the process of obtaining a Certificate of Registration from the Reserve Bank of India and meeting the regulatory obligations that apply throughout the life of the licensed entity. At CA Murli Chandak, the scope of engagement spans three broad phases: pre-registration structuring, the formal application process and post-registration compliance support.
Category Selection and Business-Model Assessment
One of the earliest and most consequential decisions in the registration journey is determining the correct NBFC category. The RBI recognises multiple categories — Investment and Credit Companies, Microfinance Institutions, Factors, Peer-to-Peer Lending Platforms, Account Aggregators, Housing Finance Companies and Infrastructure Finance Companies, among others. CA Murli Chandak assesses the promoter’s intended business model and recommends the most appropriate category before any application is filed.
Company and Capital Structuring
Only companies incorporated under the Companies Act, 2013 are eligible to hold an NBFC licence. We assist in incorporating the entity where required, ensuring the Memorandum of Association includes a sufficiently broad financial-services object clause. Capital structuring is equally critical — we advise on meeting the minimum Net Owned Fund requirement, ensuring that capital is introduced in unencumbered form and is supported by the documentation the RBI requires, including an auditor’s certificate and a banker’s no-lien confirmation.
RBI Registration Application
CA Murli Chandak prepares and files the application on the PRAVAAH portal, assembles all supporting documents and coordinates the physical submission to the relevant Regional Office of the RBI. Following submission, we manage the query-and-response process that typically ensues before a Certificate of Registration is granted.
Ongoing RBI and MCA Compliance
Our role does not end at registration. Regulatory obligations — including periodic returns to the RBI, prudential norms, fair practices compliance, KYC/AML frameworks and MCA filings — continue throughout the operational life of the NBFC. We offer structured post-registration compliance support on both retainer and project bases.
2. Why Businesses in Kolkata Need an NBFC Consultant
Kolkata has a long and established history as a commercial and financial centre. The city’s business fabric includes a dense network of MSMEs, trading enterprises, family-run financial operations and, increasingly, fintech and digital-lending ventures. This environment creates a sustained demand for formal lending infrastructure — and therefore for NBFC registration and advisory services.
Lending, Investment and Fintech Opportunities
The credit needs of small businesses in West Bengal, particularly in manufacturing, trade and logistics, are substantial. An NBFC structure allows promoters to formally deploy capital as loans, earn interest income on a regulated basis and build a scalable lending book. For fintech entrepreneurs, the NBFC-ICC or NBFC-P2P framework provides a regulatory home for digital credit and marketplace lending models.
MSME and Trade-Finance-Oriented Business Models
A significant share of NBFC registrations in the eastern region are driven by the need to formalise MSME lending, supply-chain finance and bill-discounting activities. CA Murli Chandak helps promoters structure these models appropriately, ensuring that the business plan presented to RBI reflects the actual product intent in a manner that is both commercially coherent and regulatory compliant.
Increasing Regulatory Scrutiny
The RBI has progressively tightened its oversight of the NBFC sector. The Scale Based Regulation framework, introduced in 2022, stratified NBFCs into Base, Middle, Upper and Top Layers with differentiated compliance requirements at each level. The Digital Lending Guidelines of 2022 introduced strict rules on Lending Service Providers, Default Loss Guarantee arrangements and the conduct of digital lending operations. Any business that fails to account for these developments at the registration stage risks serious compliance gaps from the outset.
Avoiding Common and Costly Mistakes
Registration applications submitted with incorrect NOF calculations, encumbered capital, weak business plans or improperly described outsourcing arrangements frequently face extended scrutiny or rejection. CA Murli Chandak’s advisory process substantially reduces these risks by ensuring the application package is complete, accurate and consistent with current RBI expectations before it is filed.
3. Who Needs NBFC Registration? Understanding the RBI 50-50 Test
Not every entity that lends money or makes investments is required to register as an NBFC. The RBI applies a principal-business test to determine whether registration is mandatory.
The Principal-Business Test
Under the framework established by the RBI, a company is required to register under Section 45-IA of the Reserve Bank of India Act, 1934 if both of the following conditions are satisfied:
- Financial assets constitute more than 50 percent of the company’s total assets.
- Income from financial assets constitutes more than 50 percent of the company’s gross income.
Both conditions must be satisfied simultaneously. A company that derives more than 50 percent of its income from financial activities but whose balance sheet is dominated by non-financial assets may not meet the threshold — though the position warrants careful analysis before any conclusion is reached.
Exemptions and Specific Cases
Certain categories of entities are exempt from the RBI registration requirement even if they otherwise meet the principal-business test — including insurance companies regulated by IRDAI, stock exchanges registered with SEBI, and certain Nidhi companies. We assess whether any such exemption applies before initiating a registration process.
Important: Starting NBFC activities — particularly the business of lending or investment — without the required Certificate of Registration is a serious regulatory offence under the RBI Act, 1934. Contact CA Murli Chandak for a definitive assessment before commencing any activity that may trigger the registration requirement.
4. Minimum Net Owned Fund (NOF) Requirements for NBFCs
Net Owned Fund is the primary capital threshold that an applicant must satisfy before the RBI will consider an NBFC registration application. The requirement varies by category.
What is Net Owned Fund?
Net Owned Fund is broadly defined as the aggregate of paid-up equity capital, free reserves, share premium and capital reserves representing surplus on sale of assets — net of accumulated losses, deferred revenue expenditure and intangible assets — further reduced by investments in subsidiaries and group companies, and the book value of loans and advances made to subsidiaries and group companies.
| NBFC Category | Minimum Net Owned Fund |
|---|---|
| NBFC-ICC (Investment and Credit Company) | Rs. 10 crore |
| NBFC-MFI (Microfinance Institution) | Rs. 10 crore (Rs. 5 crore in North East) |
| NBFC-Factor | Rs. 10 crore |
| NBFC-P2P (Peer-to-Peer Lending Platform) | Rs. 2 crore |
| NBFC-AA (Account Aggregator) | Rs. 2 crore |
| Housing Finance Company (HFC) | Rs. 20 crore |
| Infrastructure Finance Company (IFC) | Rs. 300 crore |
| Infrastructure Debt Fund NBFC (IDF-NBFC) | Rs. 300 crore |
| Mortgage Guarantee Company | Rs. 100 crore |
Documentation Supporting NOF
The RBI requires a certificate from a practising Chartered Accountant confirming the applicant company’s NOF meets the applicable threshold as of a recent date, along with a banker’s no-lien certificate confirming the capital is unencumbered. CA Murli Chandak coordinates the preparation and review of both documents as part of the pre-filing process.
5. Types of NBFCs Relevant for Businesses in Kolkata
The RBI has defined multiple NBFC categories, each designed to accommodate a specific type of financial activity. Category selection is one of the most consequential early decisions in the registration process.
NBFC-ICC: Investment and Credit Company
This is the most common and broadly applicable category. An NBFC-ICC is permitted to engage in lending, investing in financial assets and providing hire-purchase and leasing finance. Businesses looking to establish a general-purpose lending platform will typically apply in this category. The minimum NOF requirement is Rs. 10 crore.
NBFC-MFI: Microfinance Institution
An NBFC-MFI lends primarily to low-income households, with at least 85 percent of its net assets in qualifying collateral-free loans. This category is particularly relevant for social-finance and rural-lending models in West Bengal.
NBFC-Factor
Factoring involves the acquisition of receivables at a discount. At least 75 percent of the NBFC-Factor’s assets and income must derive from factoring activity. This category suits Kolkata’s trading and manufacturing sectors seeking to monetise receivables.
NBFC-P2P: Peer-to-Peer Lending Platform
An NBFC-P2P operates as a marketplace connecting individual lenders with borrowers. It does not lend itself; it facilitates and earns a fee. The minimum NOF of Rs. 2 crore is lower than other categories, but the regulatory framework is detailed and evolving.
NBFC-AA: Account Aggregator
An Account Aggregator consolidates and shares a customer’s financial information across institutions with their consent. It does not lend or invest. This is a highly specialised category relevant primarily to data infrastructure companies.
Scale Based Regulation: Layers
The RBI’s Scale Based Regulation framework, effective October 2022, categorises all NBFCs into four layers — Base, Middle, Upper and Top — based on asset size and systemic risk. New applicants typically enter the Base Layer and must plan for escalating obligations as they grow.
6. Eligibility and Company Structure for NBFC Registration
Eligibility for an NBFC licence is confined to companies incorporated under the Companies Act, 2013. Understanding the structural requirements before incorporation is essential to avoiding delays.
Type of Entity
Only a private limited company or a public limited company can apply for and hold an NBFC Certificate of Registration. LLPs, sole proprietorships, partnership firms and trusts are not eligible. Promoters operating through such structures will need to incorporate a separate company.
Object Clause in the MOA
The Memorandum of Association must contain an appropriate financial services object clause. If the company has been incorporated with a narrow or non-financial clause, it will need to be amended before an NBFC application can be filed.
Fit and Proper Criteria for Directors
Directors and major shareholders must satisfy the RBI’s fit-and-proper criteria — covering financial integrity, professional background, educational qualifications, absence of criminal convictions and disqualifications under the Companies Act, 2013.
Governance Structure
The applicant company must have a board of directors with relevant experience in financial services, risk management or business operations. The RBI expects applicants to demonstrate that the board has the collective competence to oversee the proposed NBFC operations.
7. Documents Required for NBFC Registration
The documentation package required for NBFC registration is extensive. Incomplete or inconsistent documentation is one of the primary reasons for delays.
Company Incorporation Documents
- Certificate of Incorporation issued by the Registrar of Companies
- Memorandum of Association, with appropriate financial services object clause
- Articles of Association
- PAN card of the company
- Latest shareholding pattern of the company
Financial Documents
- Audited financial statements for the last three financial years (if the company is not newly incorporated)
- Latest management accounts or interim financials, where applicable
- Auditor’s certificate confirming the Net Owned Fund position
- Banker’s no-lien certificate confirming that the NOF capital is unencumbered
Director and Shareholder Documents
- KYC documents for all directors (PAN, Aadhaar, passport-size photographs)
- KYC documents for all shareholders, including corporate shareholders
- CIBIL or credit report for each director
- Fit-and-proper declarations signed by each director
- Educational and professional qualification certificates of directors
Business Plan and Policy Documents
- Detailed business plan covering proposed products, target markets, distribution strategy and risk management approach
- Five-year financial projections including projected P&L, Balance Sheet and Cash Flow Statement
- Board-approved credit policy and risk management framework
- Board resolution authorising the application
Digital-Lending Specific Documents (Where Applicable)
- Details of Lending Service Providers — nature of arrangement, scope and compensation
- LSP contracts, where executed
- Details of any Default Loss Guarantee arrangement
- Confirmation of compliance with the RBI’s Digital Lending Guidelines
8. NBFC Registration Process in Kolkata – Step by Step
CA Murli Chandak manages this end-to-end process on behalf of applicants, coordinating documentation, filing, submission and query responses. The nine stages below must be completed sequentially.
- Company Incorporation: A private or public limited company must be incorporated under the Companies Act, 2013, with an appropriate financial services object clause. This stage includes name reservation, drafting of the MOA and AOA, and filing with the Registrar of Companies.
- NOF Arrangement and Documentation: The required minimum Net Owned Fund must be introduced into the company as paid-up equity capital in unencumbered form. The supporting documents — auditor’s certificate and banker’s no-lien letter — must be obtained before filing.
- Fit-and-Proper Board Preparation: All directors must satisfy the RBI’s fit-and-proper criteria. Declarations, KYC documents, credit reports and professional credentials must be collated. Board restructuring, if required, should be completed at this stage.
- Business Plan and Policy Preparation: A detailed business plan, five-year financial projections and all required policy documents — including a credit policy and risk management framework — must be prepared and approved by the board.
- PRAVAAH Portal Filing: The application is submitted through the RBI’s PRAVAAH portal. The online form must be completed in full and all supporting documents uploaded in the prescribed format in the name of the applicant company.
- CARN Generation: Upon successful submission, the PRAVAAH portal generates a Company Application Reference Number (CARN). This reference number is required for all future communication with the RBI.
- Physical Document Submission to the RBI Regional Office: A physical set of documents must be submitted to the relevant Regional Office of the RBI. For West Bengal-based applicants, this is the RBI’s Kolkata Regional Office. The physical submission must include the CARN.
- Responding to RBI Queries: The RBI will typically raise queries seeking clarification on specific aspects of the application. Timely, accurate and consistent responses are critical. Our team manages this correspondence on behalf of clients.
- Receipt of the Certificate of Registration: The RBI grants the Certificate of Registration under Section 45-IA(1) of the RBI Act, 1934 upon satisfaction with the application. The entity may not commence NBFC operations prior to receiving the CoR.
9. PRAVAAH Portal and the RBI Application for NBFC Registration
The PRAVAAH portal — Platform for Regulatory Application, Validation and Authorisation — is the RBI’s centralised digital platform for receiving applications relating to authorisation, licensing and registration. NBFC registration applications are submitted exclusively through this portal.
The portal requires the applicant to create an account using the company’s CIN, PAN and other identifying information before the application form can be accessed. The application covers company information, director details, capital and fund information, business plan summary and document uploads.
Key Features of the PRAVAAH Process
- All documents must be uploaded in PDF format, accurately labelled in accordance with the portal’s requirements.
- The portal validates certain fields before allowing submission, reducing the risk of typographical errors in key data points.
- Upon successful submission, the CARN serves as the unique identifier throughout the review process.
- Communications from the RBI regarding queries and decisions are routed through the portal.
Important: Even after the online application is submitted through PRAVAAH, the physical set of supporting documents must be submitted to the relevant RBI Regional Office. Both the online and physical submissions are mandatory. CA Murli Chandak coordinates both components of the filing process for all clients.
10. Business Plan, Financial Projections and RBI Policies
The business plan is the most scrutinised narrative component of the NBFC registration application. The RBI uses it to assess whether the proposed entity has a coherent, viable and regulatory-compliant model. CA Murli Chandak prepares all business plan documentation as part of its full-service registration engagement.
Content of the Business Plan
- Executive summary — the nature of the proposed NBFC, its target market and product offerings.
- Product description — loan tenors, ticket sizes, target borrower profiles and pricing.
- Distribution strategy — direct origination or through a Lending Service Provider.
- Risk management framework — credit, operational, liquidity and concentration risk policies.
- Governance structure — board composition, committee structure and reporting lines.
- Regulatory compliance framework — how the NBFC will meet its ongoing RBI and MCA obligations.
Financial Projections
Financial projections cover a five-year horizon and include a projected P&L, Balance Sheet and Cash Flow Statement. Projections must be internally consistent and commercially defensible. Unrealistic growth assumptions or inconsistencies with the stated business model will attract adverse comment from the RBI.
Digital Lending and LSP-Specific Considerations
For NBFCs that intend to operate a digital lending model or engage Lending Service Providers, the business plan must address the RBI’s Digital Lending Guidelines in detail — covering the LSP structure, underwriting control, the Key Fact Statement framework and the cooling-off period provisions.
11. NBFC Registration Timeline and Consultancy Costs in Kolkata
Both timeline and cost are subject to variability depending on the complexity of the proposed business model and the completeness of the application at submission.
Indicative Timeline
| Stage | Indicative Duration |
|---|---|
| Company incorporation (if not yet done) | 2 to 4 weeks |
| Capital arrangement and NOF documentation | 2 to 6 weeks |
| Business plan, projections and policy preparation | 3 to 6 weeks |
| PRAVAAH filing and physical submission | 1 to 2 weeks |
| RBI processing and query resolution | 3 to 6 months (longer for complex models) |
Consultancy Costs
Professional fees vary considerably based on scope. A full-service engagement with CA Murli Chandak covers company incorporation, capital structuring, business plan preparation, RBI application management and post-registration compliance support. Promoters are encouraged to assess scope and track record rather than fee alone. Book an initial consultation at calendly.com/murlichandak/30min.
12. Post-Registration NBFC Compliance Requirements
The grant of the Certificate of Registration marks the beginning, not the end, of the regulatory compliance journey. An NBFC is subject to a comprehensive and ongoing set of obligations throughout its operational life.
Prudential Norms
The RBI prescribes prudential norms covering income recognition, asset classification and provisioning. These norms determine how an NBFC categorises its loan assets based on repayment performance and how much provision it must maintain against potential credit losses.
Capital Adequacy and Exposure Norms
NBFCs must maintain a minimum Capital to Risk-weighted Assets Ratio (CRAR). Exposure norms limit the concentration of lending to any single borrower or group of connected borrowers as a proportion of the NBFC’s owned funds.
Periodic RBI Returns and Reporting
NBFCs must file a range of returns with the RBI — monthly, quarterly, half-yearly and annually. Missing return deadlines or filing inaccurate returns attracts regulatory action.
KYC, AML and Customer Protection
Every NBFC must implement a KYC policy and an Anti-Money Laundering framework in accordance with the Prevention of Money Laundering Act, 2002 and the RBI’s Master Direction on KYC.
Fair Practices Code and Grievance Redressal
The RBI’s Fair Practices Code prescribes how an NBFC must communicate with borrowers and handle complaints. Every NBFC must have a designated Nodal Officer and must display its grievance redressal mechanism on its website and at its offices.
MCA Annual Filings
In addition to RBI obligations, an NBFC must discharge its annual filing requirements under the Companies Act, 2013 — including Form MGT-7 and Form AOC-4 with the Registrar of Companies.
13. How CA Murli Chandak Supports Ongoing NBFC Compliance
Ongoing compliance support is a significant component of the value that CA Murli Chandak delivers after the Certificate of Registration has been granted. The regulatory calendar for an NBFC is demanding, and the consequences of missed filings or procedural lapses are material.
Compliance Calendar Management
CA Murli Chandak maintains a category-specific compliance calendar for each client NBFC, tracking all filing deadlines, board meeting requirements and regulatory submission dates. This ensures no obligation is inadvertently missed.
RBI Return Preparation and Filing
Our team prepares periodic RBI returns, maps financial data to regulatory definitions and files returns accurately and on time — substantially reducing the internal burden on the NBFC’s management.
Policy Updates and Regulatory Monitoring
The RBI issues Master Directions, Circulars and Guidelines on an ongoing basis. We monitor these communications and advise clients on the implications of new regulations for their operations, policies and documentation.
Inspection and Query Support
When an RBI inspection is notified or a regulatory query is raised, our team assists in assembling the required information and preparing responses that are accurate, complete and appropriately framed.
14. Digital Lending, LSP and DLG Considerations for Kolkata Fintechs
The RBI’s Digital Lending Guidelines, issued in 2022, introduced a significant regulatory overlay for NBFCs that operate digital credit models or engage third-party service providers. Fintech-oriented promoters in Kolkata must understand these requirements before structuring their business models.
Lending Service Providers
A Lending Service Provider is an entity engaged by an NBFC to carry out one or more lending functions — sourcing, loan servicing, recovery or customer interaction. LSP engagements must be documented through a formal agreement, LSPs must be listed on the NBFC’s website, and the LSP is prohibited from making any independent credit decision. All loan disbursements and repayments must be routed directly between the borrower and the NBFC.
Default Loss Guarantee Arrangements
The RBI’s framework permits First Loss Default Guarantee arrangements under specified conditions — including a cap on the aggregate DLG as a proportion of the underlying loan portfolio. DLG arrangements must be fully documented and must not alter the fundamental lender-borrower relationship.
Key Fact Statement and Cooling-Off Period
Every digital borrower must receive a Key Fact Statement before the loan agreement is executed, setting out the all-in cost of the loan in a standardised format. Borrowers must also be provided a cooling-off period during which they may exit the loan agreement without penalty.
Advisory Note: NBFC registration applications contemplating a digital-lending model or LSP arrangement must address these requirements comprehensively in the business plan. CA Murli Chandak has experience in structuring and documenting digital-lending operations in a manner consistent with the RBI’s Digital Lending Guidelines.
15. How to Choose the Right NBFC Consultant in Kolkata
The selection of an NBFC consultant is a consequential decision. The quality of advisory support directly influences the efficiency of registration, the quality of the post-registration compliance framework and the NBFC’s long-term regulatory standing.
1. RBI-Specific Experience
CA Murli Chandak brings focused expertise in the RBI’s regulatory framework — including the Scale Based Regulation framework, the principal-business test, NOF requirements by category and the Digital Lending Guidelines. General corporate law or accounting experience, while useful, does not substitute for this specialised knowledge.
2. Track Record of Completed Registrations
The number and diversity of NBFC registrations successfully completed is a material indicator of practical capability. Promoters should seek consultants who have handled registrations across multiple categories, not merely one.
3. Understanding of Digital Lending Requirements
For fintech-oriented applicants, the consultant’s familiarity with Digital Lending Guidelines, LSP structuring and DLG conditions is essential. This is a fast-evolving regulatory area that demands current, applied knowledge.
4. Transparent Scope and Engagement Structure
CA Murli Chandak provides a clear scope of engagement, a defined list of deliverables and a transparent fee structure. Engagements are documented through formal engagement letters that specify exactly what is and is not within scope.
5. Post-Registration Compliance Capability
The registration process is a one-time event. Compliance is an ongoing obligation. A consultant who can provide year-round compliance support — return filing, policy updates, regulatory monitoring and inspection support — delivers greater long-term value.
6. References and Case Credentials
Promoters are welcome to request references from existing CA Murli Chandak clients who have been through the registration process and are now in the compliance phase. Feedback from operational NBFCs is the most reliable indicator of advisory quality.
16. Why Local Kolkata Expertise Can Matter
The RBI’s regulatory framework is a nationwide one, and the substantive requirements for NBFC registration and compliance are identical across India. However, local expertise provides tangible practical advantages in specific areas.
Understanding the Local Business Ecosystem
A consultant familiar with Kolkata’s MSME sector, trade-finance dynamics and lending models can design a business plan that is not only regulatory compliant but also commercially credible in the context of the local market.
Family-Office and Investment-Oriented Businesses
Kolkata has a long tradition of family-office and investment-oriented business structures. CA Murli Chandak has experience advising family groups seeking to formalise investment operations through an NBFC structure, including structuring the entity, managing related-party considerations and satisfying the RBI’s fit-and-proper requirements.
Coordination with Local Institutions
The physical submission of documents to the RBI’s Kolkata Regional Office and coordination with local banks for the no-lien certificate are more efficiently managed with established local relationships and familiarity with the regional office’s procedures.
17. Common Mistakes to Avoid During NBFC Registration
Experience across multiple NBFC registration engagements reveals a consistent set of errors that delay applications or, in more serious cases, lead to rejection.
- Incorrect NOF calculation. Investments in group companies, encumbered assets and deferred expenses must be properly accounted for. An incorrect NOF certificate will attract immediate scrutiny from the RBI.
- Encumbered capital. Introducing capital from borrowed funds and presenting it as equity capital is a serious error. The RBI requires confirmation that capital is genuinely unencumbered.
- Weak or unrealistic business plans. Vague, internally inconsistent or commercially implausible plans will not withstand RBI review.
- Inadequate financial object clause in the MOA. A narrowly drafted or non-financial object clause must be amended before the application can be filed.
- Poorly structured LSP or DLG arrangements. Applicants who describe a digital lending model without adequately addressing the RBI’s Digital Lending Guidelines invite detailed and repeated queries.
- Commencing NBFC activities before the CoR is granted. Beginning lending, investment or deposit-taking activity before the Certificate of Registration is issued is a serious regulatory offence under Section 45-IA of the RBI Act.
- Inconsistent documentation. Discrepancies between figures in the auditor’s certificate and the financial statements will invariably attract queries and delay processing.
- Inadequate responses to RBI queries. Responses must be substantive, accurate and supported by documentation. Vague or incomplete responses significantly extend the timeline.
18. Frequently Asked Questions About NBFC Consultants in Kolkata
Is NBFC registration mandatory for a company that lends money in Kolkata?
Whether registration is mandatory depends on whether the company satisfies the principal-business test. If financial assets exceed 50 percent of total assets and income from financial assets exceeds 50 percent of gross income, registration under Section 45-IA of the RBI Act, 1934 is mandatory. Operating an NBFC business without the required Certificate of Registration is a criminal offence.
What is the minimum Net Owned Fund required to register an NBFC?
The minimum NOF depends on the category. For NBFC-ICC, the minimum is Rs. 10 crore. For NBFC-P2P and NBFC-AA, the minimum is Rs. 2 crore. For an HFC, the minimum is Rs. 20 crore. Applicants should verify current requirements at the time of filing.
Can an LLP or a partnership firm register as an NBFC?
No. Only companies incorporated under the Companies Act, 2013 — whether private or public limited — are eligible. Promoters operating through LLPs, partnerships or other structures will need to incorporate a separate limited company.
How long does the NBFC registration process typically take?
For a well-prepared application, the RBI’s processing period is typically three to six months from the date of physical submission. Pre-filing preparation may take an additional two to four months.
Is the PRAVAAH portal mandatory for NBFC registration?
Yes. The online application must be submitted through the PRAVAAH portal, followed by a physical submission to the relevant RBI Regional Office. Both submissions are mandatory.
Do all NBFCs accept public deposits?
No. The vast majority of NBFCs are deposit-restricted. Only NBFCs specifically authorised by the RBI to accept public deposits may do so.
Can CA Murli Chandak assist after the Certificate of Registration has been granted?
Yes. CA Murli Chandak offers structured post-registration compliance retainers covering periodic RBI returns, prudential compliance, KYC/AML implementation, policy maintenance and MCA filings.
What are LSP and DLG requirements for digital lenders?
Under the RBI’s Digital Lending Guidelines of 2022, an NBFC engaging a Lending Service Provider must document the arrangement formally, retain all credit decision-making authority and ensure loan disbursements and repayments are routed directly between the NBFC and the borrower. Default Loss Guarantee arrangements are permitted under specified conditions, including aggregate caps.
Does the RBI’s regulatory framework differ for NBFCs in Kolkata compared to other cities?
No. The RBI’s regulatory framework is a nationwide one and the substantive requirements are identical regardless of where the NBFC is based.
19. Conclusion – How CA Murli Chandak Can Help
Establishing and operating a Non-Banking Financial Company in India is a substantive regulatory undertaking. The registration process demands careful preparation — from structuring the entity and arranging adequate capital, to preparing a credible business plan and managing the RBI’s application and query process.
CA Murli Chandak provides end-to-end NBFC advisory services — from initial feasibility assessment and category selection, through RBI registration, to sustained post-registration compliance support. Our team brings focused RBI regulatory expertise, a track record across multiple NBFC categories and a commitment to delivering structured, high-quality advisory outcomes.
Selecting an advisor based on a thorough assessment of credentials, track record and the breadth of continuing support capability — rather than on fee alone — is the single most important investment a promoter can make in the success of their NBFC journey.
Ready to begin? Book a consultation with CA Murli Chandak at calendly.com/murlichandak/30min or write to us at camurli@outlook.com.
Disclaimer: This article has been prepared by CA Murli Chandak for informational purposes only and does not constitute legal or regulatory advice. Regulatory requirements are subject to change; applicants should verify current requirements with the Reserve Bank of India or a qualified advisor at the time of filing.