Concurrent Audit Consultant in Delhi | NBFC | Marcken

In short: Marcken Consulting LLP is a concurrent audit consultant in Delhi for NBFCs whose boards, lenders and investors want an independent check on the loan book, the KYC and anti-money-laundering controls and the regulatory filings while the financial year is still running. Three facts make the Delhi scope different from a generic template. First, the Reserve Bank of India’s New Delhi Regional Office at 6, Sansad Marg supervises NBFCs registered not only in Delhi but also in Gurgaon, Faridabad and Sonepat in Haryana and in Noida, so a lender registered anywhere in that belt deals with the same supervisory office. Second, the Financial Intelligence Unit – India (FIU-IND), to which every NBFC files its cash and suspicious transaction reports, is headquartered in New Delhi, and the Reserve Bank of India (Non-Banking Financial Companies – Know Your Customer) Directions, 2025 require every NBFC’s KYC policy to provide for a “concurrent / internal audit system to verify compliance with KYC / AML policies and procedures”, one of the few places in RBI’s NBFC rulebook where a concurrent audit is expressly contemplated. Third, the National Capital Region’s NBFC population is weighted towards promoter-group holding companies, Base Layer investment and credit companies working towards the ₹10 crore Net Owned Fund requirement of 31 March 2027, co-lending partners of banks and peer-to-peer platforms, each of which carries its own set of RBI directions. This guide is built around those three facts. It does not repeat the digital lending, cybersecurity, housing finance, gold loan or microfinance material covered in the firm’s Bangalore, Mumbai and Ahmedabad guides, which are linked where they apply.

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

A concurrent audit consultant in Delhi tests an NBFC’s transactions, controls and filings in the month or quarter in which they occur, so that an error in asset classification, a missed FIU-IND report or an intra-group loan outside policy is corrected before it reaches an RBI return, a lender’s covenant certificate or the statutory audit. The statutory auditor gives an annual opinion on the financial statements; the concurrent auditor gives the Audit Committee a running view of whether the company is operating the way its policies and RBI’s directions say it should. For a Delhi NCR NBFC, Marcken Consulting LLP’s work falls into four parts:

  • Mapping the company to its rulebook. Identifying which of the consolidated NBFC Directions of 28 November 2025 apply to the company’s products, its Scale Based Regulation layer and its structure, and whether it also falls under the Core Investment Companies, Co-Lending Arrangements or Peer to Peer Lending Platform Directions. The map becomes the audit programme.
  • Cycle testing of transactions and controls. Sampling disbursements, collections, overdue buckets, provisioning, KYC files and related-party transactions each month or quarter, with system data drawn from the loan management system and reconciled to the ledger and the bank.
  • Pre-filing review of returns and reports. Reconciling RBI returns, FIU-IND reports, lender certificates and rating-agency data to the books before they are submitted.
  • Audit Committee reporting with owners and dates. An exception report ranked by risk, with the control owner and remediation date against each item and a re-test at the next cycle until it is closed.

2. Why Delhi NCR NBFCs Need an NCR-Specific Scope

The National Capital Region spreads across three states, and the supervisory, reporting and structural facts below are the reasons a Delhi concurrent audit cannot be lifted from a template written for another city.

  • One RBI office for Delhi, Gurgaon, Faridabad, Sonepat and Noida. RBI’s chart of regional offices for NBFC matters places under the New Delhi office, 6, Sansad Marg, New Delhi 110001, the “State of Delhi, the districts of Faridabad, Gurgaon and Sonepat of State of Haryana and Noida in Ghaziabad district of Uttar Pradesh”. The rest of Haryana, with Himachal Pradesh, Punjab and Chandigarh, falls under the Chandigarh office, and the rest of Uttar Pradesh, with Uttarakhand, under the Kanpur office. An NBFC with its registered office in Connaught Place, Cyber City or Sector 62 Noida therefore has the same supervisory office; one registered in Ghaziabad, Meerut, Panipat or Rewari does not. The registration-side consequences of this split are covered in the firm’s NBFC license consultant in Delhi guide; the audit-side consequence is that supervisory correspondence, returns and inspection follow-up for most NCR lenders flow through a single office, and the concurrent audit record should be kept in a form that answers that office’s questions directly.
  • The anti-money-laundering regulator is in the same city. FIU-IND, established on 18 November 2004 under the Ministry of Finance, describes itself as the central national agency for receiving, processing, analysing and disseminating information on suspect financial transactions, and operates from New Delhi. Every NBFC is a reporting entity under the Prevention of Money Laundering Act, 2002, and the KYC Directions, 2025 (RBI/DOR/2025-26/361) require, at paragraph 12(4), a “Concurrent / internal audit system to verify compliance with KYC / AML policies and procedures”. Section 4 turns that requirement into a test programme.
  • The NCR’s NBFC mix is structural, not product-led. Where Bangalore’s lenders are defined by digital origination and Mumbai’s by scale, Delhi NCR’s NBFC population is marked by promoter-group holding companies that may be Core Investment Companies, by Base Layer companies that must hold ₹10 crore of Net Owned Fund by 31 March 2027, by co-lending arrangements with banks that came under new directions on 1 January 2026, and by peer-to-peer platforms with their own 2025 directions. Sections 5 to 7 take each in turn.

Setting up or re-scoping a concurrent audit for your Delhi NCR NBFC? Marcken Consulting LLP offers a no-charge 30-minute consultation to map your structure, your products and your reporting obligations to the scope that fits. Call +91 99980 59923 or write to crm@marckenconsulting.com.

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3. What RBI Actually Requires, and Where Concurrent Audit Fits

RBI has not issued a direction that makes a general concurrent audit compulsory for NBFCs; concurrent audit as a named system belongs to RBI’s guidelines for commercial banks. The firm’s concurrent audit consultant in Bangalore guide sets out that position in full, with a side-by-side comparison of concurrent, internal and statutory audit, and it is not repeated here. Four points from the current rulebook decide how a Delhi engagement is framed:

  • KYC and AML are the exception. Paragraph 12(4) of the KYC Directions, 2025 requires the NBFC’s KYC policy to include a concurrent or internal audit system to verify compliance with KYC and AML policies and procedures. A company that has neither function in place is short of the direction, whatever its size.
  • Loans under co-lending arrangements must be audited. Paragraph 27 of the Reserve Bank of India (Co-Lending Arrangements) Directions, 2025 states that “the loans under the CLA shall be included in the scope of internal/statutory audit”. A concurrent cycle is the practical way to meet that requirement on a live portfolio (Section 6).
  • Independence decides who can hold the role. The Reserve Bank of India (Non-Banking Financial Companies – Statutory Audit) Directions, 2026 of 31 July 2026 provide that concurrent auditors of an NBFC should not be considered for appointment as its statutory auditors and require a gap of at least one year between non-audit work for the NBFC and appointment as its statutory auditor. The concurrent auditor and the statutory auditor are therefore two different firms, and Marcken Consulting LLP documents that separation in every engagement letter.
  • Internal audit is mandatory beyond certain thresholds. Section 138 of the Companies Act, 2013 read with Rule 13 of the Companies (Accounts) Rules, 2014 requires an internal auditor for a private company whose turnover reached ₹200 crore or whose outstanding borrowings from banks or public financial institutions reached ₹100 crore in the preceding financial year, and RBI’s risk-based internal audit framework applies to deposit-taking NBFCs and to non-deposit-taking NBFCs of ₹5,000 crore and above, now consolidated in the Internal Audit Function Directions, 2026. Below those thresholds, concurrent audit is often the only continuous independent assurance a Delhi NCR board has.

4. The KYC and AML Concurrent Audit: Turning Paragraph 12(4) into a Test Programme

For a Delhi NCR NBFC the KYC and AML scope is the natural anchor of the concurrent audit, because the direction asks for it, because the receiving agency is in the same city, and because the obligations are specific enough to test. The KYC Directions, 2025 require the NBFC to nominate a Designated Director, a Board-nominated person responsible for overall compliance with Chapter IV of the PML Act and the Rules, and a Principal Officer responsible for monitoring transactions and reporting, and to communicate both appointments to FIU-IND and RBI; the Principal Officer cannot also be the Designated Director (paragraphs 14 and 15). Paragraph 49 requires the NBFC to furnish to the Director, FIU-IND, the information referred to in Rule 3 of the PML (Maintenance of Records) Rules, 2005 in accordance with Rule 7. FIU-IND’s own published guidance sets the reporting cadence: cash transaction reports for cash transactions exceeding ₹10 lakh, cross-border wire transfer reports for transfers exceeding ₹5 lakh and non-profit organisation transaction reports by the 15th day of the succeeding month, and suspicious transaction reports within seven working days of the conclusion that a transaction is suspicious, with no minimum amount. Records of transactions must be kept for at least five years from the date of the transaction and customer identification records for at least five years after the relationship ends (paragraph 47), and KYC must be updated at least once every two years for high-risk customers, eight years for medium-risk and ten years for low-risk customers (paragraph 42). Where the NBFC suspects money laundering and believes that completing due diligence would tip off the customer, it must not pursue the process and must file a suspicious transaction report instead (paragraph 19).

Area What the concurrent auditor tests each cycle Evidence examined
Governance Designated Director and Principal Officer appointed, distinct, and notified to FIU-IND and RBI; KYC policy approved by the Board and current against the 2025 Directions Board minutes, intimation letters, FINnet registration record
Customer due diligence Sampled files for identity and address verification, beneficial ownership, risk categorisation and periodic updation within the two, eight and ten year intervals Customer files, system risk flags, updation logs
Transaction monitoring Alerts generated, reviewed and closed with reasons; cash transactions above ₹10 lakh captured; structuring patterns across linked accounts examined Alert register, closure notes, cash ledger
Reporting to FIU-IND CTR, CBWTR and NTR filed by the 15th of the succeeding month; STRs filed within seven working days; filed reports reconciled to the underlying ledger; nil-report decisions documented FINnet acknowledgements, reporting register, reconciliation workings
Record keeping and training Five-year retention operating in practice; staff and agent training records; tipping-off controls Archive samples, training logs, policy acknowledgements

The output of this part of the programme is a paragraph 12(4) compliance record the Principal Officer can hand to RBI’s supervisory team or to FIU-IND without reconstruction.

5. Group Structures: Core Investment Companies and Intra-Group Lending

Delhi NCR’s promoter groups commonly hold their operating companies through an investment company, and the question of whether that company is a Core Investment Company, and whether it must register as one, is a recurring finding in NCR engagements. The Reserve Bank of India (Core Investment Companies) Directions, 2025 (RBI/DOR/2025-26/367, 28 November 2025) treat a company as a CIC when, as at the last audited balance sheet, it holds not less than 90 percent of its net assets as investments in equity, preference shares, bonds, debentures, debt or loans in group companies; its equity investments in group companies, including instruments compulsorily convertible within ten years, together with sponsor units of InvITs, are not less than 60 percent of net assets; it does not trade in those investments except through block sale for dilution or disinvestment; and it carries on no other financial activity beyond bank deposits, money market instruments, government securities, group bonds and debentures, loans to group companies and guarantees for group companies. Registration is required for a CIC with total assets of not less than ₹100 crore, individually or together with other CICs in the group, that raises or holds public funds, which the Directions define to include bank finance, inter-corporate deposits, commercial paper and debentures. A CIC with assets below ₹100 crore, or with assets of ₹100 crore and above that does not access public funds, is not required to register (paragraph 16). A registered CIC must keep its Adjusted Net Worth at not less than 30 percent of aggregate risk-weighted assets (paragraph 20), its outside liabilities at not more than 2.5 times Adjusted Net Worth (paragraph 23), and the number of layers of CICs in the group, including the parent, at two (paragraph 19). CICs sit in the Middle Layer of the Scale Based Regulation framework whatever their size.

For the concurrent auditor, the group structure produces a short list of tests that run every quarter: whether the 90 and 60 percent conditions still hold after the quarter’s investments and redemptions; whether any new borrowing, inter-corporate deposit or commercial paper has turned an unregistered holding company into one that holds public funds; whether Adjusted Net Worth and the outside-liabilities ceiling are within limits after dividends and fresh debt; whether loans to group companies and guarantees are within the Board-approved policy and priced and documented as the Governance Directions, 2025 and the Credit Facilities Directions, 2025 require for exposures to directors, their relatives and related entities; and whether the layer count has been breached by a new intermediate holding company. Findings here reach the promoters directly, and they are far cheaper to resolve in-quarter than in response to a supervisory letter.

6. Co-Lending Arrangements from 1 January 2026

Many NCR NBFCs fund part of their book through co-lending with banks, and since 1 January 2026 those arrangements have been governed by the Reserve Bank of India (Co-Lending Arrangements) Directions, 2025 (RBI/DOR/2025-26/139, issued on 6 August 2025). The Directions apply to commercial banks other than small finance banks, local area banks and regional rural banks, to All-India Financial Institutions and to NBFCs including housing finance companies, and they exclude digital lending, consortium lending and syndication from their scope. Arrangements in existence before the effective date continue under the regulations that applied to them. Under the new framework each regulated entity must retain a minimum 10 percent share of each individual loan (paragraph 10); the borrower is charged a blended interest rate, being the average of the partners’ rates weighted by their funding shares (paragraph 17); all transactions are routed through an escrow account with a bank (paragraph 26); each partner’s share of a loan must be reflected in its books within 15 calendar days (paragraph 22); the originating entity may provide a default loss guarantee of up to five percent of loans outstanding (paragraph 32); and the loan agreement must disclose upfront the segregation of the partners’ roles and identify the single point of interface for the customer (paragraph 13). Paragraph 11 requires the credit policy to incorporate the arrangement, and paragraph 27 brings the loans under the arrangement into the scope of internal and statutory audit.

Direction requirement Concurrent audit test
Minimum 10 percent retention by each partner Loan-level share recomputed from the escrow and the partner’s books; exceptions listed
Blended interest rate Sampled borrower rates recomputed from each partner’s rate and funding share; Key Facts Statement agrees to the blended rate
Escrow routing and the 15-day reflection rule Escrow statements reconciled to disbursements and collections; ageing of unreflected shares
Default loss guarantee within five percent Guarantee outstanding against loans outstanding, by arrangement, each quarter
Borrower disclosure and single point of interface Sampled loan agreements checked for the role segregation and interface disclosure; grievance log reviewed
Asset classification across partners Overdue status and provisioning for the NBFC’s share tested under the Income Recognition, Asset Classification and Provisioning Directions, 2025, and compared with the partner bank’s classification

7. Peer-to-Peer Platforms and the Base Layer Net Owned Fund Deadline

Two further features of the NCR’s NBFC population shape the Delhi scope. The first is the presence of peer-to-peer lending platforms, now governed by the Reserve Bank of India (Non-Banking Financial Companies – Peer to Peer Lending Platform) Directions, 2025 (RBI/DOR/2025-26/370, 28 November 2025), which repeal the earlier P2P framework. The Directions require a Net Owned Fund of not less than ₹2 crore and a leverage ratio not exceeding two; cap a lender’s aggregate exposure across all platforms at ₹50 lakh, with a Chartered Accountant’s certificate of a minimum net worth of ₹50 lakh for any lender investing more than ₹10 lakh (paragraph 26); cap a single lender’s exposure to a single borrower at ₹50,000; limit loan maturity to 36 months; prohibit the platform from assuming any credit risk, directly or indirectly, or providing or arranging any credit enhancement or guarantee, so that the entire loss of principal or interest falls on the lender; require funds to move through lenders’ and borrowers’ escrow accounts within T+1 day; and require a Board-approved policy for matching lenders and borrowers in an equitable and non-discriminatory manner. For a platform, the concurrent audit recomputes the exposure caps and maturity limits from the platform data each cycle, tests the escrow for T+1 compliance, examines whether any arrangement with a lender or a partner amounts to a guarantee or credit enhancement in substance, and checks that lender disclosures carry the borrower’s identity only with consent and that borrower disclosures exclude the lender’s identity and contact details.

The second feature is the size profile. The Reserve Bank of India (Non-Banking Financial Companies – Registration, Exemptions and Framework for Scale Based Regulation) Directions, 2025 (RBI/DOR/2025-26/339) place non-deposit-taking NBFCs below an asset size of ₹1,000 crore in the Base Layer and set the Net Owned Fund for an NBFC-ICC, NBFC-MFI and NBFC-Factor at ₹10 crore, reached through a glide path of ₹5 crore by 31 March 2025 and ₹10 crore by 31 March 2027 (paragraphs 39 and 42), with ₹2 crore applying to NBFC-P2P, NBFC-AA and Type I NBFCs (paragraph 40). Many of the NCR’s investment and credit companies are Base Layer entities whose promoters must plan the capital, the reserves and the deductions that make up Net Owned Fund over the coming eighteen months. A concurrent audit that recomputes Net Owned Fund every quarter, after the statutory reserve transfer under Section 45-IC of the RBI Act, 1934 and after deducting group investments and loans as the formula requires, gives the Board the number before the deadline rather than after it.

Holding company, co-lending partner or P2P platform in Delhi NCR? Share your structure and your current audit arrangements, and Marcken Consulting LLP will tell you which directions apply and what a concurrent cycle should test. Call +91 99980 59923 or write to crm@marckenconsulting.com.

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8. How Marcken Consulting LLP Runs a Delhi NCR Engagement

  1. Appointment and independence. The Audit Committee appoints the firm under an engagement letter that records scope, cycle, sampling basis and reporting format, and confirms that the firm is not the statutory auditor and will observe the separation required by the Statutory Audit Directions, 2026.
  2. Structure and jurisdiction review. The group chart is examined for Core Investment Company status and layer count, the registered office is matched to the RBI regional office that supervises it, and the FIU-IND registration, Designated Director and Principal Officer appointments are confirmed.
  3. Regulatory map. Each product, arrangement and entity is mapped to the directions it attracts, including the KYC, Governance, Credit Facilities, Income Recognition, Asset Classification and Provisioning and Prudential Norms on Capital Adequacy Directions of 28 November 2025 and, where relevant, the Core Investment Companies, Co-Lending Arrangements and Peer to Peer Lending Platform Directions. The map is the audit programme.
  4. Baseline review of policies. First-cycle review of the KYC and AML policy, the credit policy including any co-lending provisions, the policy on loans to directors and related parties and the outsourcing policy against the current directions.
  5. Cycle testing. Monthly or quarterly sampling and recomputation across Sections 4 to 7, with data drawn from the loan management and KYC systems and reconciled to the ledger, the bank and the escrow.
  6. Pre-filing reconciliation. RBI returns, FIU-IND reports and lender certificates reconciled to the books before submission.
  7. Audit Committee report and follow-up. Risk-ranked exceptions with owners and dates, re-tested at the next cycle until closed, and an annual summary for the statutory auditor and the Board.
Deliverable in a Delhi NCR engagement
Regulatory and structure map covering the NBFC, its holding company and the RBI office that supervises each entity
KYC and AML compliance record under paragraph 12(4) of the KYC Directions, 2025, with FIU-IND filing reconciliations
Quarterly Core Investment Company test: asset-composition conditions, public funds status, Adjusted Net Worth, outside liabilities and layer count
Co-lending arrangement test results by partner: retention, blended rate, escrow, 15-day reflection, default loss guarantee and classification
Quarterly Net Owned Fund recomputation against the 31 March 2027 requirement
Recomputed overdue ageing and provisioning schedule each cycle
Cycle exception reports to the Audit Committee and an annual summary for the statutory auditor

9. What a Concurrent Audit Costs in Delhi

No RBI direction prescribes a fee for the concurrent audit of an NBFC. In Delhi NCR the fee turns on the cycle (monthly or quarterly), the number of entities in the group that need to be covered, whether co-lending or peer-to-peer arrangements are in scope, the volume of KYC and FIU-IND reporting activity and whether branch visits outside Delhi are required. Marcken Consulting LLP scopes the programme before quoting and then fixes the fee for the year against that scope, so the Audit Committee knows what is being tested, how often and at what cost before the engagement letter is signed.

10. Quick Reference Checklist: When a Delhi NCR NBFC Should Appoint a Concurrent Auditor

  • The KYC policy has no functioning concurrent or internal audit of KYC and AML compliance, as paragraph 12(4) of the KYC Directions, 2025 requires.
  • FIU-IND reports have been filed late, or the company cannot reconcile what was filed to its ledger.
  • The group holds operating companies through an investment company and nobody has tested the Core Investment Company conditions or the public funds position since the last balance sheet.
  • The company has entered or renewed a co-lending arrangement since 1 January 2026.
  • The company is a Base Layer NBFC-ICC that has not yet reached ₹10 crore of Net Owned Fund ahead of 31 March 2027.
  • The company operates a peer-to-peer platform and relies on system settings alone to enforce the lender and borrower exposure caps.
  • A lender, rating agency or incoming investor has asked for independent assurance on the portfolio between statutory audits.
  • The registered office is in Delhi, Gurgaon, Faridabad, Sonepat or Noida and the company is preparing for or responding to RBI New Delhi Regional Office correspondence.
  • The Board wants findings surfaced and corrected in-quarter rather than in the statutory audit or a supervisory inspection.

11. Why Marcken Consulting LLP Is the Right Concurrent Audit Consultant in Delhi

Marcken Consulting LLP is led by CA Murli Chandak, an IBBI-Registered Valuer for Securities or Financial Assets, and its concurrent audit work for Delhi NCR NBFCs sits inside a practice that serves the same companies across registration, valuation, funding and compliance:

  • An NBFC practice from registration to audit: the firm’s NBFC registration, NBFC due diligence, NBFC takeover and business plan for NBFC service lines, and its NBFC license consultant in Delhi guide, deal with the same directions this guide applies to the audit.
  • A scope written from the directions that apply to the NCR: the KYC Directions, 2025, the Core Investment Companies Directions, 2025, the Co-Lending Arrangements Directions, 2025 and the Peer to Peer Lending Platform Directions, 2025 are read against the specific company before the first sample is drawn.
  • Independence documented from the start: the engagement is structured to comply with the Statutory Audit Directions, 2026, with the separation from the statutory auditor recorded in the engagement letter.
  • Valuation and transaction depth for the moments the book is tested by outsiders: the firm’s business valuation and IBBI-Registered Valuer work for Delhi NCR companies, and its equity funding and IPO guides, mean that when a fundraise, a change of control or a listing puts the loan book under diligence, the concurrent audit record and the valuation work are prepared by the same firm.
  • Compliance across the company: GST, ESOP and virtual CFO support for Delhi NCR businesses sit in the same practice, so a finding that touches tax, equity or reporting does not fall between advisers.
  • A single point of accountability: one engagement partner at Marcken Consulting LLP owns the Delhi NCR programme from scoping through cycle testing to Audit Committee reporting and follow-up.

This guide is part of a city series. The concurrent audit consultant in Bangalore guide covers digital lending and the 2026 cybersecurity directions, the concurrent audit consultant in Mumbai guide covers large and Middle Layer NBFCs, housing finance companies and group structures at scale, and the concurrent audit consultant in Ahmedabad guide covers MSME, gold loan and microfinance portfolios and family-promoted NBFCs.

12. Frequently Asked Questions

Does RBI require every NBFC to appoint a concurrent auditor?
No general direction does. The KYC Directions, 2025 do, however, require every NBFC’s KYC policy to provide for a concurrent or internal audit system to verify compliance with KYC and AML policies and procedures, and the Co-Lending Arrangements Directions, 2025 require loans under a co-lending arrangement to be within the scope of internal and statutory audit. Beyond those, concurrent audit is a Board, lender or investor decision.

Which RBI office supervises an NBFC registered in Gurgaon or Noida?
RBI’s chart of regional offices for NBFC matters places the districts of Faridabad, Gurgaon and Sonepat in Haryana, and Noida, under the New Delhi office at 6, Sansad Marg, together with the State of Delhi. Other Haryana districts fall under the Chandigarh office and the rest of Uttar Pradesh under the Kanpur office.

Our promoters hold the group through an investment company. Does it have to register as a Core Investment Company?
Only if it meets the asset-composition conditions in the Core Investment Companies Directions, 2025 and has total assets of ₹100 crore or more, alone or together with other CICs in the group, and raises or holds public funds. A CIC below ₹100 crore, or one at or above that size that does not access public funds, is not required to register, but the position has to be re-tested whenever the group borrows, issues debt or restructures, which is what the quarterly concurrent test does.

What does the concurrent auditor test in a co-lending arrangement?
The 10 percent minimum retention, the blended interest rate, escrow routing, the 15-day reflection of loan shares, the default loss guarantee against the five percent ceiling, the borrower disclosures and the classification of the NBFC’s share of each loan, all drawn from the Co-Lending Arrangements Directions, 2025 that took effect on 1 January 2026.

When must a Base Layer NBFC-ICC reach ₹10 crore of Net Owned Fund?
By 31 March 2027, under the glide path in the Registration, Exemptions and Framework for Scale Based Regulation Directions, 2025, after reaching ₹5 crore by 31 March 2025. NBFC-P2P, NBFC-AA and Type I NBFCs have a ₹2 crore requirement.

Can our statutory auditor also act as our concurrent auditor?
No. The Statutory Audit Directions, 2026 provide that concurrent auditors of an NBFC should not be considered for appointment as its statutory auditors, and require at least a year between non-audit work and appointment as statutory auditor. The two roles are held by different firms.

Speak to Us

Marcken Consulting LLP offers a no-charge 30-minute consultation to discuss your Delhi NCR NBFC’s concurrent audit scope, group structure, KYC and AML 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

Book a Free Consultation Chat on WhatsApp

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

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