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Home / NBFC & Fintech / NBFC Registration (RBI COR)
A rejected or queried NBFC application can cost you 6–12 months and lakhs in abortive work. CS Chetna Shoor personally reviews your Net Owned Fund structuring, business plan, and promoter documentation before it reaches RBI’s desk.
RBI evaluates NBFC applications more closely than almost any other business license in India, because Section 45-IA of the RBI Act, 1934 puts the regulator in the position of deciding who gets to lend or invest with public trust behind them. There’s no fast-track: every application is checked against capital adequacy, promoter background, and business-plan credibility before a Certificate of Registration is even considered.
This page is for founders and promoters who already know they need an NBFC — the question is who structures the filing so it survives that scrutiny. We work with promoters at the eligibility stage, not after a rejection letter, and Chetna signs off on the Net Owned Fund composition and business plan personally before either goes to RBI.
Minimum Net Owned Fund for new NBFC registration (since Oct 2022)
Must be a Pvt Ltd or Public Ltd company — LLPs & partnerships not eligible
Principal Business Criteria: financial assets & income each above half of total
Promoters and directors must clear RBI's credit and background checks
Typical RBI approval timeline via the COSMOS portal
Legal basis under the RBI Act, 1934 mandating registration
RBI rejects over 40% of NBFC applications on the first attempt. Here’s what actually causes it.
The ₹10 crore threshold isn't just a number to clear — RBI checks where that capital sits. Funds routed through related-party loans, parked in fixed assets, or lacking a clean audit trail back to genuine promoter contribution get flagged, even when the balance sheet technically shows ₹10 crore.
RBI expects projections, risk policy, and a Fair Practices Code specific to your NBFC type. A plan adapted from a different category's template — or one that reads generic — is one of the fastest ways an application comes back with queries instead of an approval.
RBI runs credit and background checks on every promoter and director. An undisclosed default, an unclear source-of-funds trail for the NOF, or a prior regulatory issue can stall an otherwise complete filing for months if it surfaces after submission instead of before it.
Most founders come to us assuming they need a generic “NBFC license” — but RBI’s framework splits into distinct categories with different capital and compliance requirements, and filing under the wrong one is a common reason applications stall mid-review. We confirm the right category during the eligibility assessment, before any document goes to RBI.
The default route for most lending and investment businesses; covers the broadest range of financial activity under one license.
A lower NOF threshold of ₹5 crore (₹2 crore in the Northeast), often the better fit for early-stage microfinance promoters. See our NBFC-MFI Registration service.
For group structures that primarily hold shares in other group entities rather than lend externally.
A separate license category for peer-to-peer platforms, governed by its own fund-transfer and exposure-limit rules.
We confirm your NBFC category, current NOF position, and whether your promoter profile is likely to clear RBI's fit-and-proper checks.
A full review of what you have against what RBI will expect, so gaps surface now rather than after submission.
Chetna reviews the business plan and financial projections directly before either is finalized.
Submission through the COSMOS portal, followed by physical document submission to the RBI regional office.
We respond to every RBI query directly as it comes in, so you're not left interpreting regulatory language under time pressure.
Once your Certificate of Registration is issued, we set up your statutory registers and RBI returns calendar. Typical timeline: 3–6 months end to end.
Compliance obligations start the day the Certificate of Registration is issued — for many NBFCs, this is where the real workload begins.
NBS returns and an annual statutory auditor's certificate. See NBFC Annual RBI Compliance.
Companies Act filings continue in parallel with RBI obligations.
Ongoing customer due diligence and Central KYC registry obligations.
Governance and prudential requirements scale with your NBFC's regulatory layer as it grows.
CS Chetna Shoor’s team replies within 4 hours on WhatsApp.
Most Certificate of Registration applications take 3–6 months from filing to approval, provided the documentation and business plan are complete on first submission. That timeline extends, often well past a year, when RBI raises queries on NOF composition, promoter background, or the business plan — which is the most common source of delay in NBFC licensing.
As per RBI norms effective October 2022, new NBFC applicants need a minimum NOF of ₹10 crore, up from the earlier ₹2 crore threshold, under Section 45-IA of the RBI Act, 1934. The capital must be unencumbered and verifiable through audited financials — not parked in fixed assets or group-company investments beyond RBI’s permissible limits. NBFC-MFIs carry a lower ₹5 crore threshold (₹2 crore in the Northeast); our NBFC-MFI Registration service may be the more direct route if that fits your business.
The core set includes your Certificate of Incorporation, MOA/AOA with financial activity stated as a company object, audited financials evidencing the NOF, a three-year business plan, KYC and net-worth certificates for all directors and promoters, and a banker’s certificate confirming the NOF deposit. We provide a complete checklist at the start of the process so gaps surface before submission, not after.
Yes — acquiring an NBFC that already holds a valid Certificate of Registration can be faster than fresh registration, since it skips the 3–6 month filing cycle, but it brings its own due diligence burden around the entity’s compliance history and any contingent liabilities. See our NBFC Takeover & Acquisition Advisory service for that route.
Once registered, an NBFC must file periodic RBI returns, maintain Scale Based Regulation compliance appropriate to its layer, follow KYC/AML and Fair Practices Code norms, and continue meeting the NOF and Principal Business Criteria on an ongoing basis. See our NBFC Annual RBI Compliance service for ongoing filing support.
Qualified Company Secretary · ICSI Member · Founder, Expertvuw Management Pvt Ltd
Chetna has guided NBFC promoters through RBI’s COR process end to end, with particular focus on structuring the Net Owned Fund and business plan so the application survives first-round RBI scrutiny rather than coming back with a query.