NBFC Policy Framework

THE NEW POLICY FRAMEWORK FOR NBFCS: A ROADMAP FOR 2025

In a landmark move to streamline regulations, the Reserve Bank of India (RBI) on November
28, 2025, consolidated over 9,000 circulars into a cohesive set of 35 Master Directions on
Non-Banking Financial Companies. This reorganisation is not just a clerical update; it
represents a paradigm shift toward transparency, governance, and the mitigation of systemic
risks.
For Non-Banking Financial Companies (NBFCs), “policy-driven governance” is no longer
optional – it is the bedrock of business operations. These RBI mandated policies ensure that
NBFCs operate with the same level of discipline as banks, reducing fraud and protecting the
end consumer.

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Below is an overview of the critical policy frameworks every modern NBFC must now maintain.

1. Responsible Business Conduct

At the heart of the 2025 Directions is the Responsible Business Conduct framework. This ensures that the interaction between the lender and the borrower is ethical and transparent.

  • Fair Practices Code (FPC): A public commitment to transparency in loan agreements, terms, and conditions.
  • Grievance Redressal Mechanism (GRM): A mandatory system to resolve customer complaints within set timelines, often including a dedicated Officer.
  • Responsible Lending Conduct Policy: Focuses on assessing the borrower’s repayment capacity to prevent “debt traps.”
  • Interest Rate Policy: Standardizes how interest rates are calculated, ensuring they are not excessive or discriminatory.
  • Lending Against Gold and Silver Collateral Policy: Specific rules for the valuation, storage, and auctioning of gold and silver collateral.
  • Staff and Recovery Agent Training: Ensures that those on the front lines, especially recovery agents, act within the law and treat borrowers with dignity.

2. Know Your Customer (KYC) and Employee (KYE)

Security starts with knowing who you are dealing with, both outside and inside the organization.

  • KYC Policy: Standardized procedures for verifying customer identity to prevent money laundering and terror financing.
  • KYE Policy: Extends due diligence to the NBFC’s own staff, ensuring that employees with access to sensitive data or funds are properly vetted.

3. Management of Defaults and Stressed Assets

The RBI has tightened the rules on how NBFCs handle “bad loans” to ensure consistency and fairness.

  • Wilful Defaulters Policy: A strict framework to identify and report borrowers who have the capacity to pay but choose not to.
  • Resolution Plan & Recovery Policy: Pre-defined strategies for restructuring loans before they become Non-Performing Assets (NPAs).
  • Compromise Settlements & Technical Write-offs: Standardizes how an NBFC can settle a debt for less than the full amount, ensuring these decisions are not arbitrary.

4. Financial Stability and Operational Resilience

NBFCs must ensure they do not run out of cash or take excessive risks with their own portfolios.

  • Asset Liability Management (ALM) Policy: Monitors the “gap” between when an NBFC owes money (liabilities) and when it expects to receive money (assets).
  • Liquidity Risk Management Framework: Ensures the NBFC keeps enough “liquid” cash to meet emergency withdrawals or obligations.
  • Investment Policy: Governs how the NBFC invests its surplus funds, focusing on safety and valuation rather than high-risk speculation.
  • Risk Management Policy: The master framework for identifying and mitigating Credit, Market, and Operational risks.

5. Technology, Outsourcing and Digital Governance

As NBFCs become digital-first, the risks shift toward the cloud and third-party vendors.

  • IT and Cloud Adoption Policy: Governs how data is stored on remote servers and ensures cybersecurity.
  • Outsourcing of Financial Services: Even if a task is outsourced (like lead generation or loan grating), the NBFC remains responsible for any failures.
  • Business Continuity & Disaster Recovery: A plan to keep the business running in case of a massive tech failure or natural disaster.
  • Website Policy: Ensures all mandatory disclosures (FPC, Interest Rates) are accessible to the public online.
  • Third-Party Risk Management Policy: A dedicated framework to manage risks arising from vendors, fintech partners, and securitisation managers.
  • “Fit and Proper” Criteria for Directors: The RBI views leadership as the “soul” of an NBFC. Under the Fit and Proper Policy, every director undergoes rigorous due diligence regarding their expertise and integrity. 

 

6. CSR and Compliance

  • Under the Companies Act, 2013, eligible NBFCs must implement a Corporate Social Responsibility (CSR) Policy, allocating 2% of average net profits to social development projects like healthcare and education. 
  • Complementing this, larger NBFCs are required to maintain a Compliance Policy overseen by a Chief Compliance Officer (CCO). This framework ensures the organization prioritizes legal and ethical standards, with the CCO acting as the “conscience” of the company to mitigate regulatory risks.

7. The New Frontier: Climate Finance

Reflecting global trends, the 2025 directions introduce a framework for “Green Finance.”

  • Green Deposits Policy: For deposit-taking NBFCs, this governs how “Green Deposits” are raised and ensures they are only used for environmentally friendly projects (like renewable energy).
  • Financing Framework: A board-approved plan to identify and fund projects that mitigate climate change risks.

Conclusion

The 2025 Policy Framework marks the “coming of age” for NBFCs. By mandating these policies, the RBI is ensuring that NBFCs are not just “shadow banks” but robust, transparent institutions. Following these policies is not just about compliance. It is about building trust with stakeholders, from the smallest borrower to the largest investor.

Frequently Asked Questions (FAQ)

To make rules simpler, clearer, and more consistent for all NBFCs.

To improve trust, stability, and responsible behaviour in the NBFC sector.

The FPC ensures that NBFCs treat customers fairly and provide clear information.

It is a system that allows customers to file complaints and get them resolved on time.

It helps NBFCs identify and manage risks so they can operate safely and smoothly.

It means lending money carefully after checking whether the borrower can repay.

To contribute a portion of their profits to social and community development.

KYC verifies customer identity to prevent fraud and illegal activities.

Yes. Your data can only be shared after you approve a consent artefact that clearly states what data is needed, why, and for how long.

They guide NBFCs to support environmentally friendly and sustainable projects.

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