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When Did You Last Get an Independent Read on Your NBFC's Actual Compliance Position?

Ongoing compliance management tells you filings are happening; a compliance audit tells you whether they’re actually correct — across RBI, MCA, PMLA, and SBR at once. CS Chetna Shoor runs the audit and hands you a findings report, not just an assumed clean bill of health.

Overview

Why Filings Being Submitted Isn't the Same as Being Compliant

Most NBFCs have someone filing NBS returns, ROC forms, and FIU-IND reports on an ongoing basis — what’s rarer is an independent, structured review confirming those filings are substantively correct, not just submitted on time. An NBFC compliance audit checks your actual position against RBI’s NBFC framework, Companies Act ROC obligations, PMLA/FIU-IND reporting, and Scale Based Regulation requirements together, producing a single findings report rather than leaving each compliance domain to assume the others are fine.

This page is for NBFC boards commissioning a periodic health check, promoters preparing for an RBI inspection, fundraise, or acquisition, and anyone who wants an audit-quality answer to “are we actually compliant” rather than an assumption based on filings being submitted. Chetna reviews all four domains together and delivers a prioritized findings report, not a binary pass/fail.

Talk to an NBFC Compliance Specialist →
Service Covers

What This Service Covers

1

RBI compliance review — NOF, Principal Business Criteria, NBS returns, and SBR layer fit, checked against your actual financial position.

2

ROC compliance review — Companies Act filings, charge registration, and director KYC status.

3

PMLA/FIU-IND compliance review — registration status, Principal Officer and Designated Director records, and STR/CTR filing history.

4

Governance review — board composition, committee structure, and policy documentation against what your NBFC's size and layer actually require.

5

Findings report with a prioritized remediation plan, not just a pass/fail summary.

6

Follow-up support to close out identified gaps.

Eligibility & key criteria

RBI + MCA + PMLA + SBR

Reviewed together, not as separate, siloed checks

NOF & PBC verified

Checked against actual financials, not assumed from the last filing

STR/CTR history

Checked for both completeness and timeliness, not just existence

Governance fit

Board and committee structure checked against your NBFC's actual SBR layer

Prioritized findings

Not a binary pass/fail, but a ranked remediation plan

Independent review

A structured audit, distinct from the ongoing filing management most NBFCs already have

Why It's Complex

Three Reasons a Standalone Audit Catches What Ongoing Filing Doesn't

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

Filings being submitted isn't the same as filings being correct

An NBS return filed on time can still understate a NOF shortfall or misclassify the SBR layer. A compliance audit checks substance — recalculating NOF and Principal Business Criteria against actual financials, not just confirming the return was filed.

Four compliance domains, four different blind spots

A team focused on RBI returns may not know FIU-IND's Principal Officer record is outdated, and a general MCA-focused firm may not check whether board composition actually matches SBR governance requirements. No single default provider naturally covers all four domains together.

The value shows up exactly when you need it most

Compliance gaps get expensive to discover right before an RBI inspection, a fundraise, or an acquisition — and by then there's often no time left to remediate them properly. This is why the audit is more useful done periodically, rather than reactively once a deadline is already looming.

WHEN TO COMMISSION THIS

When to Commission a Compliance Audit

A compliance audit earns its cost at specific moments — it’s worth knowing which one applies to you.

Periodic health check

An annual or biennial independent review, even with clean ongoing filings, to catch what routine management might miss.

Ahead of an RBI inspection

To identify and remediate gaps before RBI does, rather than discovering them in an inspection finding.

Ahead of a fundraise or acquisition

Since buyer-side diligence will surface these gaps anyway. See our NBFC Due Diligence (Buyer Side) service for the diligence framework itself.

After a personnel or ownership change

When the people who built your original compliance setup are no longer the ones running it day to day.

Documents Required

What you'll need to hand us

Company Documents

Compliance Documents

Our Process

From Scoping to Findings Report

1

Audit scoping

We confirm which domains — RBI, MCA, PMLA, or SBR — need the deepest review based on your NBFC's history and current risk profile.

2

Document collection & initial review

Documents gathered and reviewed across all four compliance domains in parallel.

3

Detailed verification

NOF and Principal Business Criteria recalculation, ROC filing cross-check, FIU-IND reporting history review, and governance-to-layer fit assessment.

4

Findings report delivered

Issues ranked by regulatory risk and urgency, not presented as an undifferentiated list.

5

Remediation support

Support to close out identified gaps, coordinated with our other compliance services as needed.

AFTER THE AUDIT

What Happens After the Findings Report

The audit itself is the diagnostic — what happens next determines whether it actually improves your compliance position.

A prioritized remediation plan, addressed in order of regulatory risk rather than convenience.

Ongoing compliance management handoff, if gaps require restructuring your filing processes. See NBFC Annual RBI Compliance, NBFC ROC Compliance, or FIU-IND Registration for NBFCs.

A board-level findings summary, suitable for governance reporting.

A clean audit report that can serve as useful evidence if a fundraise or acquisition diligence process follows.

Eligibility & key criteria

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






    FAQs

    Frequently Asked Questions

    How is a compliance audit different from ongoing RBI compliance management?

    Ongoing compliance management handles the recurring filing calendar — NBS returns, ROC forms, FIU-IND reports — submitted on time each cycle. A compliance audit is a separate, independent review of whether those filings and the underlying compliance position are actually correct, covering RBI, MCA, PMLA, and SBR obligations together in a single structured assessment.

    It verifies NOF and Principal Business Criteria against actual financials, reviews ROC filing history and charge registrations, checks FIU-IND registration and STR/CTR filing completeness, and assesses whether board and governance structure actually matches your NBFC’s Scale Based Regulation layer — delivered as a single findings report rather than four disconnected reviews.

    An annual or biennial audit is a reasonable baseline for most NBFCs, though it’s worth commissioning one specifically ahead of an RBI inspection, a fundraise, an acquisition, or after a change in the personnel managing your compliance function — moments when an undiscovered gap becomes materially more costly.

    Yes — buyer-side or investor due diligence will surface compliance gaps regardless, and an independent audit beforehand lets you remediate what you can and frame the rest honestly, rather than being caught off guard mid-negotiation. See our NBFC Due Diligence (Buyer Side) service for the diligence process itself if you’re on the buying end of a transaction.

    Findings are delivered as a prioritized remediation plan ranked by regulatory risk, not a flat list. From there, remediation typically hands off into our ongoing compliance services — RBI returns management, ROC filing support, or FIU-IND registration correction — depending on which domain the gap sits in.

    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