RBI regulatory compliance for banks, NBFCs and fintechs
NBFC registration, payment aggregator licensing, digital lending guidelines, priority sector reporting, RBI inspection readiness and enforcement defence.
NBFC and payment system licensing
- NBFC registration under RBI Master Direction, 2016: NBFC ICC, NBFC MFI, NBFC P2P and NBFC AA categories.
- Payment aggregator licence under RBI Directions on Payment Aggregators, 2020 (amended 2024): net worth, escrow, settlement and fraud management.
- Prepaid payment instrument (PPI) licence and cross border payment guidelines.
- Account aggregator framework: NBFC AA registration and consent architecture compliance.
Digital lending and fintech compliance
- RBI Guidelines on Digital Lending (September 2022): LSP disclosure, FLDG limits (5%), KFS and loan disbursement requirements.
- First Loss Default Guarantee (FLDG) structuring within RBI 5% cap and tenure limits.
- Co lending model (CLM) compliance under RBI Master Direction on co lending, 2020.
- UPI, BBPS, NACH and payment system participant obligations.
Regulatory reporting and governance
- Statutory returns: ALM statements, NPA classification, CRILC reporting and priority sector returns.
- KYC master direction compliance and video KYC implementation.
- Board level governance: fit and proper criteria, risk management committee and compliance officer appointment.
- RBI inspection preparation, observation response and corrective action plan.
How AMLEGALS assists
- NBFC and PA licence application management.
- Digital lending compliance framework design.
- RBI inspection readiness and enforcement defence.
- Fintech regulatory strategy and product compliance review.
What clients ask before they commit.
Short, direct, on the record.
01What is the minimum net worth for a payment aggregator licence?
Under the RBI Master Direction on Regulation of Payment Aggregators (15 September 2025), a non-bank PA needs a net worth of INR 15 crore at the time of application and INR 25 crore by the end of the third financial year after authorisation, maintained on an ongoing basis. The Directions cover online (PA-O), physical (PA-P) and cross-border (PA-CB) payment aggregation.
02What are the digital lending guidelines for fintech companies?
The RBI September 2022 guidelines require all lending to be between the borrower and the regulated entity (RE). Loan Service Providers (LSPs) must disclose their role, disbursement and repayment must flow directly between RE and borrower, a Key Fact Statement must be provided, and FLDG arrangements are capped at 5% of the loan portfolio.
03Can a foreign company operate as an NBFC in India?
A foreign owned or controlled NBFC can register with the RBI subject to FDI policy compliance (100% FDI permitted under automatic route for regulated NBFCs). The entity must be incorporated in India, meet minimum net owned fund requirements and satisfy the fit and proper criteria for directors and shareholders.
04What happens if an NBFC fails to comply with RBI directions?
The RBI can impose monetary penalties under Section 58B of the RBI Act, issue directions under Section 45L, restrict or cancel the Certificate of Registration, and initiate winding up proceedings. For payment system operators, the Payment and Settlement Systems Act, 2007 provides separate penalty provisions.
Related resources
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