Lending without a licence is not a business model — it's a regulatory event waiting to happen. NBFC registration with the RBI is a rigorous process: capital, fit-and-proper, business plan, systems. We take you from application to Certificate of Registration, then keep you compliant as a regulated entity.
A Non-Banking Financial Company conducting financial business (lending, investment, hire-purchase, etc.) as its principal business needs registration with the RBI under Section 45-IA of the RBI Act — a Certificate of Registration (CoR). The RBI examines capital adequacy (minimum Net Owned Funds, currently ₹10 crore for most categories with glide paths), promoter fit-and-proper, business plan viability, and systems and controls.
Registration is the beginning, not the end. Licensed NBFCs face ongoing RBI regulation: prudential norms, reporting (multiple returns), governance requirements, and supervision. The application should be built by people who understand what regulated life requires — because the RBI assesses whether you're ready for it.
Fintechs and lenders whose business model requires an NBFC licence — digital lending, MSME credit, consumer finance, vehicle finance. Operating the model without the licence is the fastest route to regulatory action.
Groups adding a financing arm — captive finance for equipment, dealer financing, consumer credit supporting the core business. And investors acquiring or investing in NBFCs, where the licence's standing and the target's compliance history need diligence.
NBFC category selection (investment, loan, microfinance, housing finance via NHB, etc.), capital planning for NOF requirements, and the honest assessment of whether the licence route or a partnership/BC model suits your stage. Not everyone needs their own licence immediately.
The full RBI application: business plan, financial projections, promoter profiles and fit-and-proper documentation, systems and controls framework, policies (credit, ALM, KYC/AML, grievance). Drafted to survive RBI scrutiny — because it will face it.
Query responses, clarifications, and the follow-through the application process demands. RBI applications are conversations, not submissions; we manage the dialogue.
The governance, systems, and compliance framework that must be operational — board composition, committees, reporting systems, audit framework. Ready for regulated life on day one.
Post-licence: RBI returns, prudential norm compliance, governance calendar, inspection readiness. The regulated-entity discipline, run as a service.
Registration engagements are fixed-fee projects, scoped to category and complexity — a standard loan-company application vs a complex multi-activity one differ significantly. Ongoing compliance is an annual retainer.
RBI timelines: 6–12 months from complete application to CoR, driven by the RBI's scrutiny cycles. Well-prepared applications move faster; incomplete ones stall.
Filing with thin capital, vague business plans, or unprepared promoters. The RBI's questions will find every weakness; a rejected application poisons the next attempt. Ready means ready.
Treating the licence as the finish line. Post-CoR life — returns, inspections, prudential norms, governance — is where NBFCs actually live. Budget and staff for it from the start.
Operating a lending business through "partnerships" that are really unlicensed lending. The RBI looks at substance; structures designed to avoid the licence requirement are the first thing supervision examines.
Licence vs partnership decision, category, capital plan. The honest strategy.
Application, business plan, policies, promoter documentation. Built to scrutiny standard.
Filing, RBI queries, clarifications — managed through to CoR.
Regulated-entity compliance: returns, governance, inspection readiness. Ongoing.
Minimum Net Owned Funds of ₹10 crore for most NBFC categories (with glide paths for existing smaller ones). The business plan must also show viability beyond the minimum.
6–12 months from a complete application. Preparation quality is the biggest variable you control.
Yes, subject to FDI policy for financial services — minimum capitalisation norms apply for foreign-owned NBFCs. We structure this.
Activity-based: loan companies, investment companies, microfinance, asset finance, etc. Category determines applicable regulations. We recommend on your business model.
If you're doing the lending (balance-sheet risk), yes. Pure tech/marketplace models have different considerations — but the RBI examines substance, not labels.
Regulated life: returns, prudential norms, governance, inspections. We run the ongoing compliance — it's a standing engagement, not a project.
No — lending without registration is the very violation the process exists to prevent. The RBI checks this.
Viability, governance, systems, and fit-and-proper management — not just capital. Most rejections are on business-model credibility, not funds.
A fit-and-proper assessment applies — the RBI examines director backgrounds. Problematic histories surface here.
Yes, if financial activity crosses the 50-50 test (financial assets and income each exceeding 50%). Many companies trip into NBFC status accidentally — we assess first.
Talk to a partner about your situation — no pitch, no obligation. If we're not the right firm for it, we'll tell you that too.
Request a consultation