Concurrent Audit Consultant in Ahmedabad | NBFC | Marcken

In short: Marcken Consulting LLP is a concurrent audit consultant in Ahmedabad for Gujarat NBFCs whose boards want the loan book, the prudential numbers and the regulatory filings checked continuously through the year by a Chartered Accountancy firm that is independent of the statutory auditor and is based in the same city as RBI’s Regional Office for the state. The firm is headquartered on Ashram Road, Ahmedabad, with concurrent audit, valuation and GST as its core practice, and it works with the kind of lender Gujarat produces in numbers: family-promoted NBFC-ICCs financing MSME clusters in textiles, chemicals, ceramics and pharmaceuticals, equipment and vehicle financiers, gold-loan companies and microfinance institutions. The regulatory backdrop has changed completely in the last twelve months. RBI consolidated the NBFC rulebook into thirty-five subject-wise Directions on 28 November 2025, issued its supervisory directions on statutory audit, the auditor’s report, internal audit and cybersecurity on 31 July 2026, and brought every Base Layer NBFC onto the 90-day NPA norm on 31 March 2026. One thing has not changed, and the first section of this guide says it plainly: RBI does not mandate a concurrent audit for NBFCs. It is a board decision, and the value of it depends entirely on scoping it to the Directions that actually bind the company. This guide covers that scope for an Ahmedabad lender — related-party controls in a family-promoted company, the MSME and equipment-finance fundamentals, the gold loan directions in force since 1 April 2026 and the microfinance framework — and explains how Marcken Consulting LLP runs the engagement.

1. What Does a Concurrent Audit Consultant in Ahmedabad Do?

A concurrent audit consultant in Ahmedabad sits between the NBFC’s own finance team and its statutory auditor. The finance team books the transactions; the statutory auditor opines on the year once it is over; the concurrent auditor tests the transactions and the controls while the year is running and tells the Audit Committee what needs fixing now. For a Gujarat lender that means, each cycle: recomputing special mention and NPA classification and the provision from the ledger; sampling the cycle’s disbursements against the credit policy, the KYC Directions and the Fair Practices Code and Key Facts Statement rules; testing security creation, charge registration and insurance on financed assets; reading every advance to a director, a relative or a group entity against the board’s policy and the Companies Act; and reconciling the supervisory returns and the lender covenant certificates to the books before they are filed. Marcken Consulting LLP delivers that programme on a fixed cycle and reports by exception, so that a thin finance team gets a short list of things to do rather than a long report to file.

2. Why Ahmedabad: RBI’s Regional Office for Gujarat, and a Firm on the Same Road

• RBI supervises Gujarat’s NBFCs from Ashram Road. Reserve Bank of India, Ahmedabad Regional Office, La Gajjar Chambers, Ashram Road, Near Gandhi Bridge, Ahmedabad 380 009 holds jurisdiction over every NBFC registered in Gujarat and in the Union Territory of Dadra and Nagar Haveli and Daman and Diu. Marcken Consulting LLP’s own office is on the same road, which matters less for geography than for familiarity: the firm works with the supervisory expectations of this Regional Office as a matter of routine.
• Gujarat has already proved the NBFC model at scale. MAS Financial Services Limited, incorporated in Ahmedabad in 1995 and RBI-registered since 1998, is a listed NBFC-ICC lending into micro-enterprise, SME, two-wheeler, commercial-vehicle and affordable-housing segments. The same segments make up the books of most of the state’s smaller NBFCs, and they shape the audit programme in Section 6.
• The clusters that need non-bank credit are here. Textiles and apparel in Ahmedabad, chemicals and petrochemicals, ceramics, pharmaceuticals, and gems and jewellery form Gujarat’s MSME base; the manufacturers and traders in those clusters without the documentation profile banks prefer are the borrowers Gujarat’s NBFCs serve, which is why MSME, equipment and vehicle finance dominate local books.
• Family promotion is the norm, not the exception. A large share of Gujarat’s NBFCs are promoted by business families whose other companies trade, manufacture or hold property. That makes the loans-to-directors policy, the related-party trail and the group exposure limits the single most important part of a concurrent audit here (Section 5), in a way they are not for a venture-backed lender in Bangalore or a bank-affiliated company in Mumbai.

3. Is Concurrent Audit Mandatory for an NBFC? The Straight Answer

No. This is the first question most Gujarat promoters ask, and a surprising number of pages answer it wrongly. RBI prescribes a concurrent audit system for commercial banks, through its revised guidelines of 18 September 2019, and from 2026 for urban co-operative banks. It has never prescribed one for NBFCs. The thirty-five NBFC Directions of 28 November 2025 and the supervisory directions of 31 July 2026 mention concurrent auditors in a single provision, and that provision is a restriction rather than a mandate: the Reserve Bank of India (Non-Banking Financial Companies — Statutory Audit) Directions, 2026 (RBI/DoS/2026-27/465) state that “concurrent auditors of the NBFC should not be considered for appointment as SCAs / SAs of the same NBFC”, and require a gap of at least one year between any non-audit work for the NBFC or its group and appointment as statutory auditor. Non-deposit-taking NBFCs with assets below ₹1,000 crore may continue their existing appointment procedure, but the principle that the two roles need two firms is now written down.

What RBI does require is an assurance structure that a concurrent audit serves. Its risk-based internal audit framework of 3 February 2021, now consolidated in the Internal Audit Function Directions, 2026, binds deposit-taking NBFCs and non-deposit-taking NBFCs of ₹5,000 crore and above, with a proposal on the table to extend it to every Middle Layer NBFC from 1 January 2027. The Companies Act, 2013 requires an internal auditor under Section 138 once a private company’s bank borrowings reach ₹100 crore or its turnover ₹200 crore. And every lender to an NBFC, every rating agency and, increasingly, every family office investing in one asks for independent assurance on the book. For most Gujarat NBFCs below the RBI thresholds, the concurrent audit is the only independent, continuous assurance the board has, and the board decides its scope.

4. The Rulebook a Gujarat NBFC Is Audited Against

Since 28 November 2025, each subject sits in its own Direction. The table maps the subjects a concurrent audit covers to the instrument and to what is actually tested:

Subject	Instrument	What the concurrent audit tests
Layer and registration	Registration, Exemptions and Framework for Scale Based Regulation Directions, 2025 (amended from 1 July 2026)	Which layer the company is in, and therefore which thresholds and norms apply; whether a group vehicle falls within the 2026 Unregistered Type I framework
Asset classification and provisioning	Income Recognition, Asset Classification and Provisioning Directions, 2025	Day-end SMA/NPA classification, the 90-day norm, upgrade only on full clearance, provisioning at the prescribed rates
Lending rules	Credit Facilities Directions, 2025 (digital lending, gold loan and microfinance chapters), Governance Directions, 2025	Loans to directors and relatives against the board policy; gold loan LTV and assaying; microfinance eligibility and pricing
Conduct and customer protection	Responsible Business Conduct Directions, 2025; KYC Directions, 2025	Fair Practices Code, Key Facts Statement and charges disclosure, KYC completeness on a file sample
Capital and reserves	Prudential Norms on Capital Adequacy Directions, 2025; Section 45-IC, RBI Act, 1934	The 15% minimum CRAR recomputed; the transfer of at least 20% of net profit to the reserve fund
Audit and assurance	Statutory Audit, Auditor’s Report, Internal Audit Function and Cybersecurity Directions, 2026	Independence of the concurrent auditor; alignment with the statutory auditor’s certificate; IT controls in the chapter that applies to the company’s size

5. Family-Promoted NBFCs: Loans to Directors, Related Parties and Group Companies

In a family-promoted Gujarat NBFC, the finding that most often turns a routine audit into a problem is not a bad loan to an outsider; it is an advance to a promoter, a relative or a group company that was booked as an ordinary loan and never tested as what it was. Four controls are tested every cycle:

• The board-approved policy. RBI’s NBFC Directions require a board-approved policy on loans to directors, senior officers and relatives of directors, and to entities in which directors or their relatives hold a major shareholding, with the aggregate disclosed in the annual financial statements. The audit traces every such advance to the policy, the approving minute and the disclosure schedule.
• Section 185 of the Companies Act, 2013. Loans, guarantees and security to directors and to persons in whom a director is interested are restricted, with narrow exceptions; the audit checks that any such facility sits within an exception that applies to the company.
• Section 188 and the related-party register. Transactions with related parties need board approval, and above the prescribed thresholds shareholder approval, with disclosure in the board’s report; the audit reconciles the loan book to the related-party register and to the auditor’s related-party schedule.
• Group exposure and the CIC question. Where the promoter group holds its investments through a Core Investment Company, the Core Investment Companies Directions, 2025 govern it, and the 2026 amendment to the Registration and SBR Directions may have changed whether the vehicle needs to be registered at all; the audit flags both. This firm’s NBFC license consultant in Ahmedabad guide explains the Type I and Unregistered Type I categories in full.

The practical output is a related-party trail the statutory auditor can rely on and the board can defend, rather than a schedule assembled from memory at year-end.

6. MSME, Equipment and Vehicle Finance: The Fundamentals the Audit Never Skips

For the lending that makes up most Gujarat books, the concurrent audit returns to the same fundamentals every cycle, each anchored to a Direction:

• Classification at day-end, not month-end. The IRAC Directions, 2025 require that “classification of borrower accounts as SMA as well as NPA shall be done as part of day-end process for the relevant date”, and an NPA may be upgraded only once “entire arrears of interest and principal are paid by the borrower”. A branch-and-field lender whose collections arrive in cash, cheque and UPI through the day is exactly the lender for whom the audit tests the day-end engine, the receipts cut-off and the unapplied-collections account.
• The 90-day norm, now for every layer. Base Layer NBFCs completed the glide path from 180 days to 90 on 31 March 2026. Any Gujarat NBFC still running a 120-day or 150-day setting in its loan system is misclassifying its book today.
• Provisioning recomputed. Standard assets at 0.25% for the Base Layer and 0.40% for the Middle Layer; sub-standard at 10% of outstanding; the secured portion of doubtful assets at 20%, 30% and 50% by age and the unsecured portion at 100%; loss assets at 100%. The audit rebuilds the figure from the ageing report and reports the difference from the books as an exception.
• Security creation, charge registration and insurance. Hypothecation of equipment and vehicles, mortgage of property, registration of charges with the Registrar of Companies where the borrower is a company and, where applicable, with the Central Registry (CERSAI), and insurance on financed assets with the NBFC’s interest noted — each tested on a sample, because a security that was never perfected is an unsecured loan for provisioning purposes.
• Field collections to general ledger. Collections recorded by field staff reconciled to bank deposits and to the loan ledger, with the gaps and the delays reported; this is where a lean back office is most exposed.
• KYC, Fair Practices Code and Key Facts Statement. A file sample tested under the KYC Directions, 2025 and the Responsible Business Conduct Directions, 2025 for identity and address verification, the disclosure of interest rate and all charges in the Key Facts Statement, and the recovery practices the Fair Practices Code requires.
• Returns and certificates. The figures in supervisory returns and in the certificates given to banks under their sanction terms reconciled to the ledger before submission.

7. Gold Loans Under the 2025 Directions

Gold-backed lending is an established line for Gujarat NBFCs, and the rules governing it changed on 1 April 2026, when the Reserve Bank of India (Lending Against Gold and Silver Collateral) Directions, 2025, issued on 6 June 2025 and now carried into the Credit Facilities Directions, 2025 for NBFCs, took effect for all regulated entities including NBFCs and housing finance companies. The concurrent audit of a gold-loan book tests:

• Loan-to-value by loan size. For consumption loans, LTV ceilings of 85% for loans up to ₹2.5 lakh, 80% for loans above ₹2.5 lakh and up to ₹5 lakh, and 75% for loans above ₹5 lakh; income-generating loans follow the NBFC’s own board-approved credit policy. The audit re-marks the collateral at each cycle date and tests the LTV at sanction and on an ongoing basis.
• Assaying in the borrower’s presence. The Directions require that the borrower is present when the collateral is assayed and that the purity and weight are documented in a standard form; the audit samples the assay records against the loan files.
• Collateral caps per borrower. Gold ornaments up to 1 kilogram, silver ornaments up to 10 kilograms, gold coins up to 50 grams and silver coins up to 500 grams per borrower; the audit tests aggregate pledges across a borrower’s accounts.
• Release on repayment. Collateral must be returned within seven days of full repayment or settlement, with compensation to the borrower of ₹5,000 for each day of delay beyond that; the audit tests the release register and any compensation paid.
• Auction discipline. Notice to the borrower before any sale of collateral and refund of any surplus; the audit tests each auction in the cycle against the Directions and the board-approved auction policy.

8. Microfinance Lending: The 2022 Framework and the NBFC-MFI Directions, 2025

Microfinance lending in Gujarat is governed by the Reserve Bank of India (Regulatory Framework for Microfinance Loans) Directions, 2022, issued on 14 March 2022, whose substance now also sits in the microfinance chapter of the Credit Facilities Directions, 2025 and in the Microfinance Institution Directions, 2025 for NBFC-MFIs. The 2022 framework removed the interest rate ceiling that older guidance still quotes, and replaced it with obligations that a concurrent audit can test directly:

• Household income eligibility. A microfinance loan is a collateral-free loan to a household with an annual income of up to ₹3 lakh; the audit samples the household income assessment on file against the board-approved methodology.
• Repayment capacity. Monthly loan repayment obligations of the household are capped at 50% of monthly household income across all its lenders; the audit tests the credit bureau pull and the computation.
• Pricing. There is no rate cap; the NBFC must price under a board-approved policy, disclose the minimum, maximum and average rates, and not charge usurious rates. The audit tests the rate on each sampled loan against the policy and the disclosure.
• Collateral-free and no prepayment penalty. The audit confirms that no security or lien has been taken and that no prepayment penalty has been charged on the sampled loans.

For an NBFC-MFI, the category direction adds the qualifying-asset test and the category-specific prudential norms, which the audit tracks at each cycle date alongside the standard NBFC programme.

9. How the Engagement Runs with Marcken Consulting LLP

1. Conflict and independence confirmation — Marcken Consulting LLP confirms that it does not hold, and is outside the one-year window around, the statutory audit of the NBFC or its group, as the 2026 Statutory Audit Directions require.
2. Audit Committee appointment — an engagement letter approved by the Audit Committee fixes the cycle, the sampling basis, the Directions in scope and the exception-report format.
3. Policy baseline — the credit policy, the loans-to-directors policy, the KYC policy, the Fair Practices Code and, where relevant, the gold-loan and microfinance policies are read against the 2025 and 2026 Directions, so that the cycle work tests compliance with policies that are themselves current.
4. Cycle testing — the recomputations and samples in Sections 5 to 8, run monthly or quarterly with data taken from the loan system and reconciled to the ledger and the bank.
5. Pre-filing review — supervisory returns and lender certificates reconciled before they go out.
6. Exception reporting and follow-up — a short, risk-ranked report to the Audit Committee with an owner and a date against each item, re-tested at the next cycle until closed, and an annual close-out shared with the statutory auditor.

Deliverable
Independence confirmation and Audit Committee engagement letter
Policy baseline against the 2025 and 2026 Directions
Recomputed SMA/NPA classification and provisioning each cycle
Related-party and loans-to-directors trail reconciled to the register and the policy
Security, charge registration, insurance and field-collection test results
Gold loan and microfinance compliance samples, where applicable
Pre-filing reconciliations, cycle exception reports and the annual close-out

10. What It Costs

No RBI direction fixes a fee for a concurrent audit, and any figure quoted on a website without seeing the book is a guess. For a Gujarat NBFC the fee turns on the cycle, the number of branches and field locations to be visited, whether gold-loan or microfinance testing is in scope, the size of the related-party universe in a family group, and the number of returns and certificates reviewed before filing. Marcken Consulting LLP scopes first and quotes a fixed annual fee against the scope, so that the promoter and the Audit Committee know what is tested, how often and at what cost before the engagement letter is signed.

11. Quick Reference Checklist for Gujarat NBFCs

• Promoters, relatives or group companies have borrowed from the NBFC, and the related-party register has not been reconciled to the loan book this year
• The loan system still classifies NPAs at 120 or 150 days, or at month-end rather than day-end
• Bank borrowings have reached ₹100 crore or turnover ₹200 crore, bringing the company within Section 138 of the Companies Act, 2013
• The company lends against gold and has not re-set its LTV, assaying, release and auction processes to the Directions in force since 1 April 2026
• The company makes microfinance loans and still prices or documents them under the pre-2022 framework
• A bank, rating agency or investor has asked for independent assurance on the portfolio, or the company is preparing for an equity raise or an IPO
• The current concurrent auditor is also the statutory auditor, which the 2026 Statutory Audit Directions do not permit

12. Why Marcken Consulting LLP Is the Right Concurrent Audit Consultant in Ahmedabad

Marcken Consulting LLP is led by CA Murli Chandak, an IBBI-Registered Valuer for Securities or Financial Assets, and is headquartered in Ahmedabad, where its NBFC practice has been built around the structures Gujarat’s business families actually use:

• Based where RBI’s Regional Office for Gujarat is based: the firm’s office and RBI’s Ahmedabad Regional Office are both on Ashram Road, and the firm works with the Regional Office’s supervisory expectations as a matter of routine rather than as an occasional event.
• An NBFC practice across the lifecycle: standalone NBFC registration, NBFC due diligence, NBFC takeover and business plan for NBFC service lines, with the NBFC license consultant in Ahmedabad guide covering the registration side of the same Directions.
• Built for family-promoted companies: related-party trails, loans-to-directors policies, group CIC questions and the Companies Act approvals that go with them are the firm’s daily work for Gujarat groups, not an add-on to a bank-style checklist.
• Independence structured correctly: the firm takes a concurrent audit only where the statutory audit sits with another firm, and documents the separation the 2026 Directions require in the engagement letter.
• Valuation depth for collateral and transactions: the same firm’s business valuation and IBBI-Registered Valuer practice means pledged-share, property and business valuations in the book are reviewed by valuers, and a later fundraise or ESOP exercise draws on the same record.
• The whole compliance stack in one office: GST, virtual CFO and CA services for Gujarat businesses sit alongside the audit, so a finding with a tax or reporting consequence is closed by the same team.

This guide is one of three in a series: the concurrent audit consultant in Mumbai guide covers the 2026 statutory audit directions in depth, capital-market-linked lending, group structures and housing finance companies, and the concurrent audit consultant in Bangalore guide covers digital lending, the 2026 cybersecurity directions and venture-backed lenders.

13. Frequently Asked Questions

Q1. Does RBI require an NBFC in Ahmedabad to appoint a concurrent auditor?
No. RBI’s concurrent audit instruments apply to commercial banks and, from 2026, urban co-operative banks. No NBFC direction prescribes a concurrent audit. It is a board decision, usually driven by lenders, rating agencies and investors, within RBI’s wider assurance framework of risk-based internal audit for larger NBFCs and the Companies Act internal audit thresholds.

Q2. Can the same CA firm be our statutory auditor and our concurrent auditor?
No. The Statutory Audit Directions, 2026 state that concurrent auditors of an NBFC should not be considered for appointment as its statutory auditors, and require a one-year gap between non-audit work and a statutory appointment.

Q3. Our NBFC is a Base Layer company. Is the NPA norm 90 days for us?
Yes, since 31 March 2026, when the glide path from 180 days ended. Classification runs as a day-end process and an NPA is upgraded only when all arrears of interest and principal are cleared.

Q4. How does the audit treat a loan to a promoter’s other company?
It is tested against the board-approved policy on loans to directors, senior officers and relatives and to entities in which they hold a major shareholding, against Section 185 of the Companies Act, 2013, and against the Section 188 related-party approval and disclosure requirements, and reconciled to the related-party register.

Q5. What changed for gold loans in 2026?
From 1 April 2026 the Lending Against Gold and Silver Collateral Directions, 2025 apply: loan-size-linked LTV ceilings of 85%, 80% and 75% for consumption loans, assaying in the borrower’s presence, per-borrower collateral caps, release of collateral within seven days of repayment with ₹5,000 per day of delay as compensation, and notice-and-surplus rules for auctions.

Q6. Is there still a 26% interest cap on microfinance loans?
No. The 2022 microfinance framework removed the rate ceiling and replaced it with a board-approved pricing policy, disclosure of minimum, maximum and average rates, a bar on usurious pricing, the ₹3 lakh household income limit and the 50% cap on monthly repayment obligations relative to household income.

Q7. What does the audit report look like?
A short exception report to the Audit Committee: each finding risk-ranked, with the control owner, the remediation date and the status at the next cycle. It is not filed with RBI, though RBI’s supervisory team may ask to see it during an inspection.

Q8. Does Marcken Consulting LLP only work with Ahmedabad NBFCs?
No. The firm’s concurrent audit practice covers NBFCs across India; this guide focuses on Ahmedabad and Gujarat because that is where the firm is based, where RBI’s Regional Office for the state sits, and where family-promoted MSME, gold-loan and microfinance lenders are concentrated.

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Marcken Consulting LLP offers a no-charge 30-minute consultation to discuss your NBFC’s concurrent audit scope, independence position and reporting cycle.

Marcken Consulting LLP | CA Murli Chandak, IBBI-Registered Valuer (Securities or Financial Assets)
Website: marckenconsulting.com
Phone: +91 99980 59923 / +91 99985 39902
Email: crm@marckenconsulting.com

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Regulatory positions in this guide are as published by the Reserve Bank of India as at October 2026 and are confirmed at the start of each engagement. This guide is general information, not legal, regulatory or investment advice.