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Home / NBFC & Fintech / NBFC-ICC (Investment & Credit Company)
If your business doesn’t fit a specialized RBI category — microfinance, infrastructure, factoring — NBFC-ICC is almost certainly the license you need. CS Chetna Shoor personally structures the Net Owned Fund, business plan, and category positioning before your application reaches RBI.
RBI merged the erstwhile Asset Finance, Loan, and Investment Company categories into a single Investment and Credit Company (NBFC-ICC) classification in 2019, creating one license that now covers most lending and investment activity that doesn’t fall under a specialized category. That breadth is an advantage for founders who don’t want to be boxed into a narrow product line — but it also means RBI checks your business plan closely for coherence, since “broad” isn’t the same as “undefined.”
This page is for promoters building a lending, investment, or leasing business that doesn’t specifically need an MFI, CIC, factoring, or infrastructure-finance license. Chetna reviews the Net Owned Fund structuring and the business plan’s lending-line definitions personally, and confirms ICC is genuinely the right category before the application goes to RBI — not after a query comes back asking why it isn’t.
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 above 50% of total
Most new NBFC-ICCs start in the SBR Base Layer (assets under ₹1,000 crore)
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.
Because NBFC-ICC covers such a wide range of lending and investment activity, RBI scrutinizes whether your business plan describes one coherent model — or a mix of unrelated products bundled together, sometimes to sidestep a specialized category's stricter conditions. A plan that reads as several different businesses stitched into one filing is a common source of queries.
Crossing ₹1,000 crore in assets automatically moves an NBFC-ICC from the SBR Base Layer into the Middle Layer, pulling in additional governance, provisioning, and disclosure requirements from the date the balance sheet crosses that line. Promoters who aren't tracking this proactively often find out only when their auditor flags it at year-end.
Some lending models sit close to a specialized category's definition — factoring receivables, infrastructure lending, group-holding structures — and filing as ICC by default rather than checking the alternative can mean carrying conditions that don't match how the business actually operates, or missing a lighter-touch regime a specialized license would have offered.
Most founders default to NBFC-ICC because it’s the broadest category — and for most lending and investment businesses, that default is correct. But it’s worth ruling out the alternatives before filing, not after.
The default category for most lending and investment businesses — covers a broad range of financial activity under one license. Most new applicants fall here.
For microfinance-focused lenders. Carries a lower NOF threshold of ₹5 crore instead of ₹10 crore — often the better fit for early-stage microfinance promoters.
For groups that primarily hold shares and investments in other group companies rather than lend to the public — a distinct, lighter-touch regulatory category.
Specialized categories for receivables factoring and infrastructure lending respectively — each with its own asset-mix test and, for IFC, a substantially higher ₹300 crore NOF requirement. Worth ruling out before defaulting to ICC if your lending is concentrated in either area.
We confirm NBFC-ICC is the right fit against your lending model, your current NOF position, and whether a specialized category would serve you better.
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, making sure your lending and investment lines are clearly defined for RBI's review.
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 the Certificate of Registration is issued, we set up statutory registers, the RBI returns calendar, and a Base-to-Middle-Layer asset tracker.
Compliance obligations start the day the Certificate of Registration is issued, and they scale up automatically if your asset base grows into the Middle Layer.
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.
Tracking your asset size against the ₹1,000 crore Middle Layer threshold so the transition doesn't catch you unprepared.
CS Chetna Shoor’s team replies within 4 hours on WhatsApp.
NBFC-ICC (Investment and Credit Company) is the default RBI category for lending and investment businesses that don’t meet a specialized category’s requirements, formed in 2019 when RBI merged the earlier Asset Finance, Loan, and Investment Company classifications. Specialized categories like NBFC-MFI, Core Investment Companies, and NBFC-IFC each carry their own asset-mix or activity tests; NBFC-ICC applies when your business doesn’t fit those narrower definitions.
NBFC-ICC applicants need a minimum Net Owned Fund of ₹10 crore, effective since October 2022, under Section 45-IA of the RBI Act, 1934 — the same threshold that applies to standard NBFC registration generally. This is higher than the ₹5 crore threshold for NBFC-MFI, which is one reason some early-stage microfinance-focused promoters choose that category instead.
No. Unlike NBFC-MFI, which requires a minimum 60% of assets in qualifying microfinance loans, NBFC-ICC has no fixed asset-mix test beyond the general Principal Business Criteria — financial assets and financial income each above 50% of the total. This gives ICC-registered NBFCs more flexibility in their lending and investment mix, provided the business plan presents a coherent model.
Once a non-deposit-taking NBFC-ICC’s asset size reaches ₹1,000 crore, it moves from the Scale Based Regulation Base Layer into the Middle Layer, which brings additional governance, provisioning, and disclosure requirements. We recommend tracking this threshold proactively as part of ongoing compliance, since the obligations apply from the point the balance sheet crosses the line, not from a later filing date.
Once registered, an NBFC-ICC must file periodic RBI returns, follow KYC/AML and Fair Practices Code norms, continue meeting the NOF and Principal Business Criteria, and monitor its asset size against the Middle Layer threshold under Scale Based Regulation. 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.