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Is Your NBFC Actually Registered with FIU-IND? Many Aren't — And RBI Now Knows It

FIU-IND published a list of NBFCs that hadn’t fulfilled their PMLA registration obligations as of June 2026 — and a formal FIU-IND–RBI information-sharing arrangement means gaps here no longer stay siloed from your RBI standing. CS Chetna Shoor handles the FINnet Gateway registration and ongoing reporting so your NBFC isn’t on that list.

Overview

Why FIU-IND Registration Isn't a One-Time Filing

Every RBI-registered NBFC is a “reporting entity” under the Prevention of Money Laundering Act, 2002, obligated to register itself and its Principal Officer with FIU-IND through the FINnet Gateway (FINGate 2.0) portal, and to intimate a Designated Director as well. Registration is only the starting point — NBFCs must then file Suspicious Transaction Reports, Cash Transaction Reports, and other prescribed reports on an ongoing basis, against statutory deadlines as tight as seven working days for suspicious activity.

This obligation is actively enforced, not a formality: FIU-IND’s own published list of non-compliant NBFCs, most recently updated as of June 30, 2026, is used by banks to apply enhanced scrutiny to those entities’ transactions. This page is for NBFCs setting up FIU-IND registration for the first time, or discovering — often during an acquisition or compliance audit — that registration was never completed or has lapsed. Chetna manages the entity and Principal Officer registration and sets up the ongoing reporting discipline both RBI and FIU-IND expect.

Talk to an NBFC Compliance Specialist →
Service Covers

What This Service Covers

1

Entity and Principal Officer registration on the FINnet Gateway (FINGate 2.0) portal.

2

Designated Director appointment and intimation to FIU-IND, alongside the Principal Officer.

3

AML/CFT policy drafting aligned to PMLA and RBI's KYC/AML Master Direction.

4

STR, CTR, and NTR reporting setup, with the internal escalation and record-keeping processes RBI's tight deadlines require.

5

Remediation support if your NBFC's registration lapsed or was never completed.

6

Ongoing reporting management, so filings happen within statutory deadlines rather than being tracked manually.

Eligibility & key criteria

Every RBI NBFC

Is a "reporting entity" under PMLA, regardless of size or category

FINnet Gateway

The mandatory online portal (FINGate 2.0) for entity and Principal Officer registration

7 working days

Deadline to file a Suspicious Transaction Report from when suspicion is formed

₹10 lakh+

Cash transaction threshold triggering a Cash Transaction Report, due by the 15th of the following month

5 years

Minimum record-retention period under PMLA

PMLA, 2002 + FIU-IND–RBI MoU

Legal basis, with active information-sharing between the two regulators

Why It's Complex

Three Reasons FIU-IND Compliance Gets Missed

RBI rejects over 40% of NBFC applications on the first attempt. Here’s what actually causes it.

Registration and reporting are two different disciplines

Completing entity and Principal Officer registration on FINnet is only step one. The ongoing STR/CTR/NTR filing cadence — with deadlines as tight as seven working days for suspicious activity and monthly deadlines for cash transaction reports — is where most compliance failures actually occur, well after registration itself is done.

Non-compliance no longer stays siloed from RBI

FIU-IND now shares information with RBI under a formal coordination arrangement, and FIU-IND's own published non-compliant NBFC list is used by banks to apply enhanced due diligence to those entities. A gap here has consequences that reach beyond FIU-IND itself.

Personnel changes get missed

A Principal Officer or Designated Director change needs to be promptly updated with FIU-IND. NBFCs that update internal records but forget the FIU-IND intimation end up with a registration that's technically inaccurate — which surfaces exactly when a reporting deadline is missed and FIU-IND asks who was responsible.

WHERE YOU STAND

FIU-IND compliance sits on a spectrum, and it's worth being honest about where your NBFC actually falls.

Most founders default to assuming they need a generic “NBFC license” — but RBI’s framework has distinct categories, and applying under the wrong one is a common reason applications stall. We confirm the right category before filing, not after a rejection.

Never registered

The highest-risk position — your NBFC is on record as failing a mandatory PMLA obligation the moment FIU-IND or RBI checks.

Registered but not actively reporting

A common gap — entity registration was completed once, but STR/CTR filings have lapsed or were never properly operationalized day to day.

Registered and reporting, but personnel records outdated

Lower risk, but still needs correcting — a Principal Officer or Designated Director change that was never intimated to FIU-IND.

NBFC P2P Lending

For peer-to-peer lending platforms — a separate license category with its own fund-transfer and exposure-limit rules under RBI's P2P lending directions.

Documents Required

What you'll need to hand us

Company Documents

Personnel Documents

Our Process

From Health Check to Ongoing Reporting

1

FIU-IND compliance health check

We confirm your current registration status, personnel records, and reporting history against what FIU-IND actually has on file.

2

Entity & Principal Officer registration

Registration or correction completed on the FINnet Gateway portal.

3

AML/CFT policy drafting or review

Policy aligned to PMLA and RBI's KYC/AML Master Direction, drafted fresh or updated as needed.

4

Designated Director & workflow setup

Designated Director intimated to FIU-IND, and an internal reporting workflow established.

5

STR/CTR/NTR filing management

Reports filed within statutory deadlines, rather than tracked manually and at risk of slipping.

6

FIU-IND query handling

Direct handling of any FIU-IND queries or notices as they arise.

STAYING COMPLIANT

Staying Off FIU-IND's Non-Compliant List

FIU-IND compliance is an ongoing discipline, not a registration you complete once and file away.

Ongoing STR/CTR/NTR filing discipline against statutory deadlines, not a one-time registration event.

Prompt intimation of any Principal Officer or Designated Director change.

Periodic internal review of AML/CFT policy against updated PMLA rules and RBI directions.

Coordination with your broader RBI compliance program, since RBI now has visibility into FIU-IND standing. See NBFC Annual RBI Compliance.

Eligibility & key criteria

CS Chetna Shoor’s team replies within 4 hours on WhatsApp.






    FAQs

    Frequently Asked Questions

    Do all NBFCs need to register with FIU-IND?

    Yes. Every NBFC registered with RBI is a “reporting entity” under the Prevention of Money Laundering Act, 2002, and must register itself and its Principal Officer with FIU-IND through the FINnet Gateway portal, regardless of size or category. This applies equally to deposit-taking and non-deposit-taking NBFCs.

    The Principal Officer is a senior management employee responsible for AML/CFT compliance, filing reports with FIU-IND, and acting as the primary point of contact for FIU-IND communications. The Designated Director is a separate, senior board-level appointment that NBFCs must also intimate to FIU-IND, adding an additional layer of accountability beyond the Principal Officer.

    NBFCs file Suspicious Transaction Reports (STRs) within seven working days of forming suspicion, Cash Transaction Reports (CTRs) for cash transactions of ₹10 lakh or more by the 15th of the following month, and Non-Profit Organization Transaction Reports (NTRs) where applicable. Records supporting these reports must be retained for a minimum of five years.

    Unregistered NBFCs are published on FIU-IND’s list of non-compliant entities, which banks use to apply enhanced due diligence to their transactions — creating operational friction well before any formal penalty is imposed. Non-compliance also risks direct enforcement action under PMLA and can affect the NBFC’s standing with RBI given the information-sharing arrangement between the two regulators.

    Yes. FIU-IND and RBI have a formal information-sharing arrangement, and repeated or serious violations of FIU-IND reporting obligations can attract RBI scrutiny in its own right, separate from any FIU-IND enforcement action. Treating FIU-IND compliance as unrelated to your RBI standing is no longer a safe assumption.

    Who Handles This

    CS Chetna Shoor — you'll be working directly with her

    CS Chetna Shoor

    CS Chetna Shoor

    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.

    — Chetna