Which returns does an NBFC file with the Reserve Bank?
An NBFC files the supervisory returns that the Reserve Bank’s 2024 filing direction assigns to its layer. A base-layer company does not file the set written for a middle-layer or upper-layer company. The annual statutory auditor’s certificate, DNBS10, is filed by 31 December. The NBS forms used in older lists are not these returns.
Why does the layer matter?
The direction sorts companies by layer and by activity. Quarterly returns of financial parameters, prudential norms, and short-term liquidity are required of an upper-layer company and a middle-layer company, and of a base-layer company only where the direction includes it, for example once assets are ₹100 crore or more for the liquidity statement. A peer-to-peer platform, a core investment company, and an asset reconstruction company have their own forms. Copying one row onto every NBFC files a return the company was not asked for. The 2020 NBS list, and why it is not used, is on the older-returns page.
Which filing is annual?
DNBS10 is the statutory auditor’s certificate that the company continues to be engaged in the business that requires the certificate of registration. It is filed by 31 December. Separately, an Investment and Credit Company that does not accept or hold public deposits files a board declaration to that effect by 30 April. That declaration is not a return of deposits. The certificate of registration itself, and the ₹10 crore Net Owned Funds a new applicant shows, are on the NBFC page.
What is not an RBI return?
Know-your-customer checks and reporting of a suspicious transaction follow the prevention-of-money-laundering rules. They are not DNBS forms. A fraud report is filed when the fraud direction requires it, on the dates that direction sets. None of these filings takes the place of Form AOC-4 or the annual return the company files as a company. Those Registrar filings are on the AOC-4 page. This page does not set a capital-adequacy percentage and does not say that every NBFC must appoint an independent director.
Frequently asked questions
Four questions cover the base layer, DNBS10, a deposit declaration, and the Registrar’s filings.
Does a base-layer NBFC file every DNBS form?
No. Several quarterly returns on financials, prudential norms, and liquidity are for the middle and upper layers, or for a base-layer company only once its asset size crosses the line the direction sets. A smaller base-layer company is outside those forms.
Is the auditor’s certificate due on 31 December?
Yes. DNBS10, the statutory auditor’s certificate of continued compliance, is filed by 31 December.
Is a board declaration the same as a deposit return?
No. An Investment and Credit Company that does not accept public deposits files a yearly declaration to that effect, by 30 April. That declaration is not a return of deposits accepted.
Do these returns replace the Companies Act filings?
No. An NBFC is still a company. It still files its financial statements and its annual return with the Registrar. The Reserve Bank’s returns are additional.
Sources
Supervisory returns are filed under the Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024. The certificate of registration is section 45-IA of the Reserve Bank of India Act, 1934.