NBFC Registration with RBI: Process, NOF & Certificate of Registration

A Non Banking Financial Company cannot lend, invest or carry on any non-banking financial business in India without first obtaining a Certificate of Registration from the Reserve Bank of India under Section 45-IA of the RBI Act, 1934. For a promoter who already has the ₹10 crore net owned fund in place, the harder part of registration is no longer the capital test, it is convincing RBI that the entity, not its technology partner, actually controls lending. RBI has cancelled over 150 Certificates of Registration in the past two years, several explicitly for outsourcing credit evaluation, interest rate determination or KYC to third-party apps. This article covers the process, the capital test, the Certificate of Registration itself, and the digital lending scrutiny that decides whether a fintech-backed application clears RBI on the first pass.

What is the minimum net owned fund required for NBFC registration with RBI?

The minimum Net Owned Fund for a new NBFC registration is ₹10 crore, effective from 1 October 2022, and this capital must be fully paid up and unencumbered at the time of filing, not promised for later. Net Owned Fund is defined under Section 45-IA(7) of the RBI Act, 1934, as paid-up equity capital plus free reserves, reduced by accumulated losses, intangible assets and specified inter-group investments. Specialised categories carry different thresholds, ranging from ₹2 crore for an NBFC-P2P to ₹300 crore for an NBFC-Infrastructure Finance Company.

Who needs NBFC registration and what does RBI actually test

An entity needs to register as an NBFC when it satisfies what RBI calls the 50-50 test: financial assets form more than 50 per cent of total assets, and income from financial assets forms more than 50 per cent of gross income. This test comes from RBI’s Press Release 1998-99/1269 dated 8 April 1999, since the RBI Act itself does not define “principal business.” A company that lends, invests in shares and securities, does hire-purchase or leasing, or takes deposits under any scheme, and clears both limbs of the 50-50 test, falls within the definition of a non-banking financial institution under Section 45-I(a) and (c) of the RBI Act, 1934.

For a fintech promoter, the 50-50 test is rarely in doubt; the business is built to lend or invest from day one. The real threshold question is narrower: does the entity, or its technology and lending service provider partners, actually make the credit decision. RBI’s registration and supervisory practice both turn on this, and treating it as settled once the entity clears the 50-50 test is the single most common misjudgement in fintech-model applications.

Certain categories are carved out of RBI registration entirely to avoid dual regulation. Alternative Investment Funds, Merchant Bankers and stock brokers registered with SEBI, insurance companies holding an IRDAI Certificate of Registration, Nidhi companies notified under the Companies Act, and chit fund companies registered under the Chit Funds Act, 1982, do not need a separate NBFC licence even if their activity would otherwise meet the 50-50 test.

Types of NBFC registration under RBI’s revised framework

RBI regulates NBFCs on two overlapping axes: what they do (Investment and Credit Company, Housing Finance Company, Infrastructure Finance Company, Core Investment Company, Micro Finance Institution, Factor, Mortgage Guarantee Company, Account Aggregator, Peer to Peer Lending Platform, Standalone Primary Dealer) and how systemically significant they are, under the Scale Based Regulation (SBR) Framework in force since 1 October 2022, which places every NBFC into the Base Layer, Middle Layer, Upper Layer or (rarely populated) Top Layer.

On 29 April 2026, RBI issued the Non-Banking Financial Companies (Registration, Exemptions and Framework for Scale Based Regulation) Amendment Directions, 2026, effective 1 July 2026, which added a further distinction on top of this structure.

A lending or fintech NBFC that faces borrowers directly will almost always be a Type II NBFC, since a customer interface is inherent to the model; the Unregistered Type I exemption matters mainly for group holding vehicles and captive finance arms, not for the customer-facing lender itself. Founders running both a lending NBFC and a separate group investment vehicle should still map the investment entity against the exemption, since it changes whether that second entity needs its own NOF and registration at all.

Net owned funds required for NBFC registration

Net Owned Fund, or NOF, is the capital gate RBI checks first, and it verifies the figure against a legal definition rather than a company’s own balance sheet presentation. Under Section 45-IA(7) of the RBI Act, 1934, read with Paragraph 5.1.25 of the Master Direction, Reserve Bank of India (Non-Banking Financial Company, Scale Based Regulation) 2023, NOF is computed as follows.

How Net Owned Fund is computed

1. Start with paid-up equity capital and free reserves as disclosed in the latest audited balance sheet.
2. Deduct accumulated losses, deferred revenue expenditure and other intangible assets.
3. Further deduct investments in shares of the company’s own subsidiaries, group companies and any other NBFC.
4. Also deduct the book value of debentures, bonds, outstanding loans, advances, hire-purchase and lease finance made to subsidiaries and group companies, but only to the extent this book value exceeds 10 per cent of the amount arrived at in step 2.

The result must sit in the company’s bank account as capital, not as a loan or a promised future infusion, and RBI expects it evidenced by an auditor’s certificate and a banker’s confirmation of no lien at the time of filing. For a promoter who has already committed the ₹10 crore, the practical task is narrower: keep it in a dedicated fixed deposit, free of any pledge or charge, from well before the filing date, since RBI’s due diligence traces the capital’s source and any recent movement in and out of the account.

Minimum NOF by category

Existing NBFCs registered before October 2022 with lower NOF were given a glide path: ₹5 crore by 31 March 2025 and the full ₹10 crore by 31 March 2027. A promoter acquiring or investing in an older, sub-scale NBFC rather than filing fresh should check where that entity sits on this glide path before closing, since a shortfall inherited at closing becomes the buyer’s compliance problem the day after signing.

Eligibility criteria RBI applies to a lending or fintech promoter

Beyond the structural checklist most guides stop at (a company under the Companies Act, an object clause covering financial activity, full NOF, a director with banking experience), RBI’s fit and proper assessment for a promoter running or planning a digital lending model tests something more specific: whether the promoters and board can demonstrate the entity, not a partner, will own the credit decision from day one.

• Company structure and object clause. The applicant must be a private or public limited company under the Companies Act, 2013, with the object clause explicitly covering the intended lending or investment activity. LLPs and partnerships cannot hold an NBFC Certificate of Registration.
• Board composition. At least one director, and increasingly a meaningful share of the board, should carry banking or financial services experience. RBI reads the board as the body accountable for underwriting policy, not a nominal oversight layer sitting above a technology team that actually runs the credit engine.
• Promoter and director due diligence. RBI checks antecedents, financial track record and source of funds for every promoter and director. A prior loan default, an unresolved CIBIL flag, or pending action with SEBI or IRDAI routinely triggers a clarification round that adds months.
• Evidence of genuine underwriting control, not outsourced control. Where the business plan describes a partnership with a technology company or lending service provider, RBI’s questions increasingly probe who sets the credit policy, who approves individual loans, and who owns the underwriting model. An application that reads as a technology platform sourcing the licence of a compliant shell will draw sustained scrutiny even if every document on the checklist is technically complete.
• FDI compliance where relevant. Where the company has foreign shareholding, it must comply with sectoral FDI norms for NBFCs under FEMA, with Form FC-GPR current before the RBI application is filed.
• No pre-commencement of business. The Board Resolution filed with the application commits the company not to accept deposits or carry on NBFC business until the Certificate of Registration is issued.

Why does RBI reject or later cancel registrations for fintech-backed NBFCs specifically?

RBI has cancelled Certificates of Registration where an NBFC outsourced credit evaluation, interest rate determination or KYC verification to a technology partner without retaining effective oversight, treating this as a breach of the outsourcing and digital lending guidelines rather than a documentation gap. Multiple such cancellations in 2024 and 2025 cited exactly this failure (RBI press releases; Master Direction on Outsourcing of Financial Services).

Step-by-step NBFC registration process with RBI

The process runs in two distinct phases: incorporating and capitalising the company, then filing with RBI through the PRAVAAH portal.

1. Incorporate the company. Obtain DSC and DIN for proposed directors, reserve a name that reflects financial activity where practical, and file SPICe+ with the object clause drafted to cover the intended NBFC business. Obtain the Certificate of Incorporation from the Registrar of Companies.
2. Capitalise the entity to the applicable NOF. Open a corporate bank account, remit the full NOF as paid-up equity, and place it in a fixed deposit. Obtain the statutory auditor’s certificate and the banker’s no-lien confirmation, both dated close to the filing date.
3. Constitute a fit and proper board and finalise partner contracts. Appoint directors with the relevant sectoral experience, adopt a Fair Practices Code by board resolution, finalise LSP and DLG contracts if the model uses them, and pass the Board Resolution authorising the RBI application and committing the company not to commence business before registration.
4. Prepare the business plan. Draft a business plan spanning at least the first five years, covering products, target markets, projected financials, risk management policy, capital planning, and, for a digital lender, the LSP oversight structure and DLG mechanics. RBI reads this closely and raises queries where the plan reads as generic or disconnected from the promoters’ actual capability.
5. File online through the PRAVAAH portal. Since 1 May 2025, all RBI registration applications, including NBFC applications, move through PRAVAAH (Platform for Regulatory Application, Validation and Authorisation) at pravaah.rbi.org.in, which replaced the earlier COSMOS system. Create an applicant login, select the relevant Certificate of Registration application, and complete the digital form with supporting documents uploaded against the prescribed checklist.
6. Receive the Company Application Reference Number (CARN) on submission, and track status through the PRAVAAH dashboard.
7. Submit the physical copy of the application, in two separately paginated sets, to the Regional Office of RBI’s Department of Regulation exercising jurisdiction over the company’s registered office, along with the CARN acknowledgement.
8. Respond to RBI’s queries. RBI’s Department of Regulation typically raises one or more rounds of clarification, and for a digital lending model these questions now routinely probe LSP contracts, DLG structuring and who owns the underwriting decision, not only the standard financial and director checklist.
9. Receive the Certificate of Registration. Once RBI is satisfied on all fronts, it issues the CoR under Section 45-IA(1), specifying the category (Type I or Type II under the 2026 framework) and any conditions attached.

The only official online filing link is the PRAVAAH portal itself: https://pravaah.rbi.org.in. COSMOS is discontinued for this purpose.

What RBI expects in the business plan of a digital lending NBFC

This is the section most registration guides skip entirely, and it is where a fintech promoter’s application succeeds or stalls. RBI’s Digital Lending Directions, 2025, dated 8 May 2025, consolidated the earlier 2022 digital lending guidelines, the outsourcing and recovery agent circulars, and the 2023 Default Loss Guarantee framework into one code, and RBI now reads a digital lender’s business plan against these standards at the registration stage itself, not only after the CoR is issued.

• Lending Service Provider due diligence must be built into the plan, not added later. Where the model involves an LSP for customer acquisition, underwriting support or servicing, the business plan should show a contractual arrangement with clearly defined roles, and evidence that the applicant, as the Regulated Entity, retains liability and oversight for every act of the LSP. RBI’s Directions are explicit that outsourcing a lending function does not transfer the regulatory responsibility.
• The Default Loss Guarantee, if the model uses one, is capped at 5 per cent. Any DLG or FLDG arrangement between the NBFC and an LSP cannot exceed 5 per cent of the relevant loan portfolio, must be invoked within 120 days of default, must be structured as cash, fixed deposit or bank guarantee rather than an implicit risk transfer, and is prohibited outright for credit cards or revolving credit facilities.
• Digital Lending App reporting to RBI’s CIMS portal is mandatory for every app used by the applicant or its LSPs, with ownership, grievance officer contact and compliance certification details kept current.
• Key Facts Statement and cooling-off period compliance must be reflected in the loan documentation design described in the business plan: a standardised KFS aligned to the APR methodology, and a minimum one-day cooling-off period during which a borrower can exit without penalty beyond a disclosed processing fee.
• Co-lending partnerships, if planned, follow a separate regime. Where the business plan involves sourcing loans jointly with a bank, the Co-Lending Arrangements Directions, 2025, effective 1 January 2026, require each partner to retain a minimum 10 per cent share of every loan on its own books, apply borrower-level asset classification, and route funds through an escrow structure, replacing the discretionary 2020 co-lending circular.
• SRO membership is becoming a practical expectation, not yet a mandate. RBI has approved the Fintech Association for Consumer Empowerment as the self-regulatory organisation for digital lending, and while membership is not a registration precondition today, an application that shows an existing or planned SRO relationship reads as a more mature governance posture.

What does RBI check most closely in an NBFC application from a fintech-backed lender?

RBI checks whether the applicant, not its technology or lending service provider partner, genuinely controls the credit decision, evidenced by who sets underwriting policy, who approves individual loans, and how liability for the partner’s conduct is retained on the applicant’s books. Applications that read as a compliant shell wrapped around a technology platform draw sustained clarification rounds even when every document on the standard checklist is complete (RBI Digital Lending Directions, 2025; Master Direction on Outsourcing of Financial Services).

Step-by-step NBFC registration process with RBI

The process runs in two distinct phases: incorporating and capitalising the company, then filing with RBI through the PRAVAAH portal.

1. Incorporate the company. Obtain DSC and DIN for proposed directors, reserve a name that reflects financial activity where practical, and file SPICe+ with the object clause drafted to cover the intended NBFC business. Obtain the Certificate of Incorporation from the Registrar of Companies.
2. Capitalise the entity to the applicable NOF. Open a corporate bank account, remit the full NOF as paid-up equity, and place it in a fixed deposit. Obtain the statutory auditor’s certificate and the banker’s no-lien confirmation, both dated close to the filing date.
3. Constitute a fit and proper board and finalise partner contracts. Appoint directors with the relevant sectoral experience, adopt a Fair Practices Code by board resolution, finalise LSP and DLG contracts if the model uses them, and pass the Board Resolution authorising the RBI application and committing the company not to commence business before registration.
4. Prepare the business plan. Draft a business plan spanning at least the first five years, covering products, target markets, projected financials, risk management policy, capital planning, and, for a digital lender, the LSP oversight structure and DLG mechanics described above. RBI reads this closely and raises queries where the plan reads as generic or disconnected from the promoters’ actual capability.
5. File online through the PRAVAAH portal. Since 1 May 2025, all RBI registration applications, including NBFC applications, move through PRAVAAH (Platform for Regulatory Application, Validation and Authorisation) at pravaah.rbi.org.in, which replaced the earlier COSMOS system. Create an applicant login, select the relevant Certificate of Registration application, and complete the digital form with supporting documents uploaded against the prescribed checklist.
6. Receive the Company Application Reference Number (CARN) on submission, and track status through the PRAVAAH dashboard.
7. Submit the physical copy of the application, in two separately paginated sets, to the Regional Office of RBI’s Department of Regulation exercising jurisdiction over the company’s registered office, along with the CARN acknowledgement.
8. Respond to RBI’s queries. RBI’s Department of Regulation typically raises one or more rounds of clarification, and for a digital lending model these questions now routinely probe LSP contracts, DLG structuring and who owns the underwriting decision, not only the standard financial and director checklist.
9. Receive the Certificate of Registration. Once RBI is satisfied on all fronts, it issues the CoR under Section 45-IA(1), specifying the category (Type I or Type II under the 2026 framework) and any conditions attached.

Does NBFC registration still go through the COSMOS portal?

No. COSMOS has been discontinued for NBFC registration. All applications for a Certificate of Registration, along with every other RBI regulatory approval, have been filed exclusively through the PRAVAAH portal since it became mandatory for all RBI-regulated entities on 1 May 2025.

Documents required for NBFC registration

RBI’s indicative checklist covers identification, financials, management and undertakings. A digital lending applicant should treat the LSP and DLG documentation as core filing material, not a later addition.

• Certified copies of the Certificate of Incorporation, and Certificate of Commencement of Business where applicable
• Updated Memorandum and Articles of Association, with the financial activity clauses highlighted
• Audited financial statements for the last three years, or since incorporation if younger
• Fixed deposit receipt and banker’s certificate of no lien evidencing the NOF
• Statutory auditor’s certificate certifying the NOF computation as per Section 45-IA(7)
• Detailed profiles of directors and key managerial personnel, including qualifications, experience and other directorships
• Board Resolution authorising the application and undertaking not to commence NBFC business before registration
• Five-year business plan with financial projections and a risk management policy
• LSP contracts and due diligence records, where the model relies on outsourced customer acquisition, underwriting support or servicing
• DLG or FLDG contractual documentation, if any, specifying the cap, invocation mechanics and instrument (cash, fixed deposit or bank guarantee)
• Details of group companies, including whether any are regulated by SEBI, IRDAI or another regulator, and the status of any pending regulatory action against them
• KYC documents (PAN, address proof) of directors and major shareholders
• Declaration on source of funds for the NOF and for the promoters’ capital contribution generally

Certificate of Registration: what it is and what triggers cancellation

The Certificate of Registration, commonly abbreviated CoR, is the operative licence issued under Section 45-IA(1) of the RBI Act, 1934, and no company may commence or carry on non-banking financial business without holding one. The CoR specifies the category of NBFC (now including Type I or Type II under the 2026 framework), whether the company is authorised to accept public deposits, and the Regional Office of RBI under whose supervisory jurisdiction the company sits.

• Display and verification. The CoR must be prominently displayed at the company’s place of business, and any counterparty can verify registration status against the List of Registered NBFCs on the RBI website.
• No deposit taking by default. Since 1997, RBI has not issued fresh Certificates of Registration authorising new NBFCs to accept public deposits. Nearly all new registrations are non-deposit taking.
• Registration is not a one-time event. RBI’s own recent enforcement pattern, cancelling over 150 Certificates of Registration in the past two years, reflects a shift from a registration-based model to continuous supervision: RBI can cancel a CoR if the company fails to commence business within six months, ceases operations for six months, breaches a condition attached to the certificate, falls short of NOF, or violates outsourcing and digital lending norms after registration, as it has done in multiple recent cases involving unsupervised technology tie-ups. Cancellation follows a show cause process, with a right of appeal to the Central Government within thirty days under Section 45-IA(7).
• Surrender requires prior approval. An NBFC that wants to exit the business or restructure cannot simply stop; it must apply to RBI through the PRAVAAH portal, submitting the original certificate, audited financials and a statutory auditor’s certificate, and obtain approval before the exit is treated as complete.
• Change of control needs prior approval. Any acquisition or transfer of 26 per cent or more of an NBFC’s paid-up equity, or a merger or amalgamation changing control, shareholding by 26 per cent or more, or more than 30 per cent of directors, requires RBI’s prior written approval.

How long does NBFC registration take

RBI Act, 1934 does not prescribe a statutory clock within which RBI must decide an application. In practice, timelines vary with how cleanly the promoter’s control and outsourcing story holds together, not only with documentation completeness.

The single largest lever a founder controls is response speed to RBI’s clarification queries, and for a digital lender, having the LSP contract and DLG structuring finalised and internally consistent before filing removes an entire round of correspondence that otherwise adds a full quarter to the calendar.

What is the realistic timeline from incorporation to holding an NBFC Certificate of Registration?

Most well-prepared applications take four to six months from PRAVAAH filing to receiving the Certificate of Registration, on top of the time needed to incorporate and capitalise the company. Fintech-backed applications involving LSP or DLG structures commonly extend to nine to twelve months, since RBI now probes underwriting control as closely as it checks the standard document set (RBI Act, 1934, Section 45-IA; RBI Digital Lending Directions, 2025).

Common mistakes that cost founders time and money

Filing before the NOF is genuinely unencumbered. Applicants sometimes show the fixed deposit but have pledged part of it, or routed it through a promoter loan that RBI later traces. RBI treats this as a NOF that does not qualify at all, and the application effectively restarts.

Letting the technology partner design the credit policy. The most consequential mistake for a fintech-backed applicant is building a business plan and operating model where the LSP or technology partner, not the NBFC’s own board and credit team, actually sets underwriting rules and approves loans. RBI’s cancellation record shows this is treated as a substantive violation, not a documentation defect, and it can surface both at registration and years into supervision.

Treating the DLG structure as a commercial side letter. A DLG arrangement drafted as a generic indemnity rather than a contract compliant with the 5 per cent cap, the 120-day invocation window and the permitted instruments invites RBI to unwind the arrangement or treat it as an impermissible risk transfer.

Ignoring promoter-level history. A director or major shareholder with a prior loan default, a pending SEBI or IRDAI proceeding, or an unresolved CIBIL flag can stall an otherwise clean application for months.

Missing the Unregistered Type I exemption analysis for a separate group entity. Groups running a customer-facing lender alongside a group holding or investment vehicle sometimes register the second entity as a full NBFC when it would have qualified as an Unregistered Type I NBFC and avoided registration entirely.

Assuming COSMOS still applies. Filing through the wrong channel, or using outdated forms, causes the application to bounce back at intake stage (PRAVAAH has been mandatory since 1 May 2025).

Frequently asked questions

Q: Can an LLP or a partnership firm obtain NBFC registration with RBI?
A: No. Only a company incorporated under the Companies Act, 2013, or the corresponding provision of the 1956 Act, can hold a Certificate of Registration under Section 45-IA. An LLP undertaking financial activity that meets the 50-50 test needs to convert to a company structure before applying.

Q: What is the maximum Default Loss Guarantee a lending NBFC can accept from an LSP?
A: The DLG or FLDG cover on any loan portfolio cannot exceed 5 per cent of that portfolio, must be invoked within 120 days of default, and must be structured as cash, a fixed deposit or a bank guarantee rather than an implicit risk transfer; it is prohibited for credit cards and revolving credit facilities (RBI Digital Lending Directions, 2025, Chapter VI).

Q: Can RBI cancel a Certificate of Registration for outsourcing violations even after it has been granted? A: Yes. RBI has cancelled CoRs where an NBFC outsourced credit evaluation, interest rate determination or KYC verification to a technology partner without retaining effective oversight, treating this as a breach of the Master Direction on Outsourcing of Financial Services and the Digital Lending Directions, 2025, not merely a documentation lapse.

Q: Does RBI’s Co-Lending Arrangements Directions, 2025 apply to a newly registered NBFC seeking bank partnerships?
A: Yes, from 1 January 2026 (or earlier if adopted internally), any new co-lending arrangement between the NBFC and a bank must retain a minimum 10 per cent share of each loan on the NBFC’s own books, apply borrower-level asset classification, and route funds through an escrow structure, replacing the discretionary 2020 co-lending circular.

Q: How long does the entire process take, from filing to receiving the CoR?
A: Well-prepared applications typically clear in three to six months from the PRAVAAH filing date; fintech-backed applications involving LSP or DLG structures commonly run six to twelve months, since Section 45-IA does not prescribe a statutory decision deadline for RBI.

Q: What documents does RBI verify most closely for a digital lending applicant?
A: The NOF evidencing, director profiles and antecedents, and, distinctively for a fintech-backed model, the LSP contract’s allocation of underwriting authority and the DLG arrangement’s compliance with the 5 per cent cap and permitted structures.

Q: Does NBFC registration have any FEMA or cross-border angle?
A: Yes. Where the applicant has foreign shareholding, the FDI must comply with sectoral norms for NBFCs under FEMA, and related filings such as Form FC-GPR should be current before the RBI application is filed.

Q: Can two co-founders each hold NBFC-related directorships in separate group entities?
A: Yes, but RBI aggregates the asset size of multiple NBFCs under common promoters or group control for classification into the Middle Layer, and for determining whether the Unregistered Type I exemption still applies at the group level.

Q: Is DPIIT startup recognition relevant to NBFC registration?
A: DPIIT recognition does not exempt an entity from Section 45-IA registration or the NOF requirement; NBFC regulation is sector-specific and overrides the general startup framework for financial businesses.

Q: Can the NBFC’s core credit decision legally sit with its technology or LSP partner?
A: No. The Digital Lending Directions, 2025, make clear that outsourcing a lending function does not transfer regulatory responsibility, and RBI’s enforcement record shows it treats a technology partner effectively making the credit decision as grounds for cancellation, not a permissible delegation.

Q: Can an NRI or foreign investor be a promoter in an Indian NBFC?
A: Yes, subject to FEMA’s sectoral cap and conditions for NBFC activities, and RBI’s fit and proper due diligence extends to foreign promoters and directors in the same manner as resident ones.

Q: What happens if the deal or fundraise underlying the NOF falls through after filing?
A: If the capital shown as NOF is withdrawn, pledged, or otherwise ceases to be unencumbered before the CoR is issued, the application no longer satisfies Section 45-IA(7), and RBI will require fresh evidencing or may reject the application.

Q: Are payment aggregators regulated as NBFCs?
A: No. Payment aggregators are authorised separately under the Payment and Settlement Systems Act, 2007, and a single fintech group commonly needs both an NBFC Certificate of Registration for its lending arm and a distinct payment aggregator authorisation for its collection arm.

Q: Can an existing NBFC apply to become an Unregistered Type I NBFC?
A: Yes, provided it meets the profile (no public funds, no customer interface, asset size below ₹1,000 crore), by applying for deregistration through the PRAVAAH portal within six months of the Amendment Directions taking effect, that is, by 31 December 2026.

Q: How can a lender or investor verify that a company’s NBFC registration is genuine?
A: Check the company name against the List of Registered NBFCs published on the RBI website, and confirm that the displayed Certificate of Registration specifically authorises the activity in question.

Founders structuring a digital lending NBFC around an LSP or DLG partnership should have the underwriting control narrative and partner contracts reviewed before the PRAVAAH filing, not after RBI’s first query.

Regulatory references:

• Section 45-IA, Reserve Bank of India Act, 1934 (requirement of registration and net owned fund)
• Section 45-IA(7), Reserve Bank of India Act, 1934 (definition of Net Owned Fund)
• Reserve Bank of India (Non-Banking Financial Company, Scale Based Regulation) Directions, 2023 (as amended), Paragraph 5.1.25
• Reserve Bank of India (Non-Banking Financial Companies, Registration, Exemptions and Framework for Scale Based Regulation) Directions, 2025, dated 28 November 2025
• Reserve Bank of India (Non-Banking Financial Companies, Registration, Exemptions and Framework for Scale Based Regulation) Amendment Directions, 2026, dated 29 April 2026, effective 1 July 2026

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