NBFC Registration in India
Company · Capital · Fit-and-proper · RBI application follow-up
A Non-Banking Financial Company is not a 7-day SPICe+ product. Comtax helps promoters plan the company, Net Owned Funds, director profile and RBI Certificate of Registration file — online across India, with a CS desk in Paschim Vihar, West Delhi.
Typical planning horizon 3–6 months after the file is actually ready · No fake “guaranteed CoR”
What NBFC registration in India actually is
An NBFC is a company whose principal business is financial — lending, investing or a notified financial activity — and which must hold a Certificate of Registration from the Reserve Bank of India before it operates as an NBFC.
This is a different product from Private Limited Company registration, GST or a money-lending shop licence. Incorporation creates the company. RBI CoR is what lets that company run an NBFC business. Mixing the two is how promoters waste a year and a large capital block.
Comtax Business Consultants (Comtax) is a Corporate Secretarial firm. We coordinate company law, documentation, capital evidence and application follow-up. We do not publish a click-by-click RBI portal manual, and we do not promise approval. RBI decides on the facts of the file.
Who this is for — and who it is not
If you want a small consultancy GSTIN, this is the wrong page. If you want to build a regulated lending or investment book, start here.
Usually a fit
- Promoters planning a lending or investment company as the main business
- Groups that can place the current notified Net Owned Funds — not a token ₹2 crore story
- Directors who can pass fit-and-proper / CIBIL / experience scrutiny
- A 3–5 year business plan that matches the licence being sought
- Founders in Delhi NCR, Mumbai, Bengaluru or elsewhere who want CS-led file coordination
Usually not a fit (yet)
- A trading or services company that only wants to “give a few loans on the side”
- Capital that exists only as a verbal commitment
- Directors with unresolved defaults or a thin financial-services profile
- A plan copied from another NBFC’s website
- Anyone expecting CoR in two weeks like SPICe+
NBFC types we see in real files
RBI’s scale-based world uses activity labels. Pick the model before you draft MoA objects and the business plan.
Investment and Credit Company (ICC)
The common umbrella for lending and investment NBFCs after older AFC / loan / investment splits were merged for many applicants.
NBFC-MFI
Microfinance with specialised borrower, ticket-size and conduct rules. Not a generic loan company with a new name.
Infrastructure finance
Project and infra exposure needs a plan and capital story RBI can test. Not a brochure activity list.
Factors / other specialised NBFCs
Factoring and certain specialised registrations have their own tests. Category errors waste the first RBI round.
Housing finance
HFC is a specialised pathway — do not treat it as a standard NBFC CoR with “housing” added in the objects.
Core Investment Company (CIC)
Group holding / investment patterns may fall under CIC conditions. Wrong label here is expensive.
Eligibility you should plan for
- A company incorporated in India with objects that actually match financial business
- Financial activity as principal business — not a trading company with a lending clause
- Net Owned Funds at the current RBI-notified level (older ₹2 crore is not a safe planning number for new applicants)
- Funds that are real, traceable and sitting in the company — not a future promise
- Directors who meet fit-and-proper: integrity, CIBIL, experience, time commitment
- A business plan, policies and systems proportionate to the licence you want
- No “accept deposits like a bank” story unless you are in a permitted deposit-taking category — most new files are non-deposit
Capital note: RBI raised NOF from the historic ₹2 crore floor, with a glide path towards ₹10 crore for many NBFCs. We confirm the figure that applies to your category and application date in consultation — we will not print a stale number as if it were still law.
Documents typically assembled
- Certificate of Incorporation, PAN, MoA / AoA
- Director and shareholder KYC, DIN, CIBIL / fit-and-proper declarations
- Board resolutions and authorised-signatory papers
- Net worth / NOF certificate and bank evidence of funds
- Shareholding pattern and source-of-funds trail
- 3–5 year business plan and financial projections
- Draft policies (credit, KYC/AML, IT, fair practice — as applicable)
- Registered office proof and company statutory records
- Auditor details and other annexures RBI’s current checklist asks for
What the NBFC journey involves
High-level stages only. This is not an RBI portal click-guide. Incomplete capital or director papers are what stall files — not “not knowing the website.”
Model & category mapping
Company + objects + capital plan
NOF, directors, policies pack
RBI application & query cycle
CoR — then ongoing compliance
Where applications usually break
- Planning capital at the old ₹2 crore story
- MoA objects that do not match the activity sought
- NOF not actually in the company or not cleanly evidenced
- Directors who fail fit-and-proper / time-commitment tests
- A generic business plan copied from the internet
- Deposit-taking language on a non-deposit file
- Slow or inconsistent replies to RBI queries
- Starting lending before CoR “because SPICe+ is done”
What Comtax handles
- Whether NBFC is the right vehicle vs operating company + other licences
- Company incorporation / object alignment if the entity is not ready
- Document and NOF evidence checklist against current RBI expectations
- Director fit-and-proper pack coordination
- Business-plan and annexure consistency review
- Application coordination and query-response support
- Post-CoR secretarial / ROC calendar if you want a retainer
Typical horizon after a complete pack: about 3–6 months. Queries and inspection change that.
After Certificate of Registration
CoR is not a trophy. Scale-based regulation, returns, conduct rules and activity-within-licence are the real operating system.
- Stay inside the activity you were registered for
- Board, policies and fair-practice discipline
- KYC / AML and customer-conduct standards
- RBI returns and supervisory information on time
- Auditor, statutory registers and Companies Act filings still apply
- GST, income-tax and labour licences as the book grows
- Change-in-management / shareholding intimations when required
Related company-law work
Most NBFC files start with a clean Private Limited (or public) company. If you do not have the entity yet, we start there — then capital and RBI, not the other way around.
Pan-India promoter support
Capital, directors and RBI process are national. We work with promoter groups in Mumbai, Bengaluru, Hyderabad, Pune, Jaipur and other cities on digital document collection and file coordination.
Delhi NCR desk
Walk-in review in Paschim Vihar, West Delhi for promoter KYC, board papers and plan consistency before anything goes to RBI.
Frequently asked questions
NBFC registration in India — capital, timeline, company type and what Comtax will and will not promise.
What is an NBFC?
A Non-Banking Financial Company is a company registered under the Companies Act that carries on financial business — typically lending, investing or similar activities — as its principal business, under RBI regulation. It is not a bank and cannot accept demand deposits like a bank.
Do I need RBI registration to start lending in India?
If financial activity is your principal business and you meet the NBFC tests, you generally need a Certificate of Registration (CoR) from RBI before commencing that business. Running lending as a side activity inside an operating company is a different legal analysis — do not assume either path without review.
Is the minimum capital still ₹2 crore?
No. Treat ₹2 crore as the old benchmark, not the current plan for a new NBFC. RBI has raised Net Owned Funds (NOF) substantially, with a glide path towards ₹10 crore for many NBFCs. New applicants should budget for the notified NOF applicable on the date of application — we confirm this in consultation because the figure is regulatory, not marketing.
How long does NBFC registration take?
A realistic planning range is often about 3–6 months after the company, capital, business plan and director papers are actually ready. RBI queries, inspection and incomplete NOF evidence extend this. It is not a 7–10 day SPICe+ product.
Can I register an NBFC as a Private Limited Company?
Many NBFCs are companies under the Companies Act (private or public, depending on the model and investor plan). The company must exist, meet principal-business conditions and satisfy RBI fit-and-proper and capital norms. Structure is decided before the RBI file, not after.
What is the difference between an NBFC and a bank?
Banks can accept demand deposits and are licensed as banks. NBFCs cannot accept demand deposits in the bank sense, face different CRR/SLR treatment, and operate under the RBI NBFC framework. Marketing “like a bank” is a compliance risk.
Can Comtax guarantee RBI approval?
No. RBI approval is discretionary and fact-specific. We prepare the company, documents, plan and application coordination so the file is complete and consistent. We do not sell guaranteed CoR.
Do you help after the Certificate of Registration?
Yes. CoR is the start of scale-based compliance: returns, fair-practice, KYC/AML, auditor, board process and activity-within-licence discipline. We can scope post-registration secretarial support separately.
Is Housing Finance or microfinance the same application?
No. Housing finance and NBFC-MFI have specialised conditions. Do not file a generic loan-company story if your model is HFC or MFI. Category mapping is the first serious step.
Can founders outside Delhi apply?
Yes. Company and RBI processes are national. We support files across India online, with a CS desk in Paschim Vihar, West Delhi for Delhi NCR promoters who want in-person review.
Plan the NBFC file before you lock capital
Book a consultation. We tell you whether an NBFC is the right vehicle, what NOF and director profile you should assume, and what the RBI pack must contain — without a fake two-week promise.
Paschim Vihar, West Delhi · Serving promoter groups across India