In short: Marcken Consulting LLP is an NBFC license consultant for Jaipur and Rajasthan companies seeking a Certificate of Registration (CoR) from the Reserve Bank of India under Section 45-IA of the RBI Act, 1934. Our practice handles eligibility assessment, Net Owned Fund (NOF) structuring, the business plan RBI actually wants to see, and the PRAVAAH portal filing itself, then stays with the promoter through RBI’s queries all the way to the CoR. Jaipur’s case is built on the state’s industrial and trading ecosystem rather than regulatory proximity alone: RBI’s own Jaipur Regional Office sits in the city with jurisdiction over the whole of Rajasthan, Rajasthan hosts significant MSME activity in textiles, apparel, engineering and chemicals that have been historically underserved by mainstream bank credit. A standard NBFC-ICC today needs a minimum NOF of ₹10 crore, fully paid up and unencumbered, and the application itself now moves entirely through PRAVAAH (Platform for Regulatory Application, Validation and Authorisation), which replaced the older COSMOS portal for all RBI-regulated entities from 1 May 2025. A significant 2026 change also matters here: RBI has created a formal three-tier classification for companies that neither take public funds nor have a customer interface, effective 1 July 2026, covered in Section 7. This guide sets out what actually counts as an NBFC, the Net Owned Fund by category, the registration process end to end, realistic costs and timelines, and how Marcken Consulting LLP’s NBFC practice takes a Jaipur company through the process.
Where Marcken Consulting LLP fits: RBI grants the Certificate of Registration itself, but getting there depends entirely on work that has to be right before the application is even filed — the Net Owned Fund evidenced correctly, the business plan that survives RBI’s queries, the “fit and proper” documentation for every director, and a promoter and shareholding structure that won’t need to be unwound later. Marcken Consulting LLP, a Chartered Accountancy and IBBI-Registered Valuer firm headquartered in Ahmedabad, builds that foundation and is the single point of accountability for the application through to the CoR.
1. What Does an NBFC License Consultant in Jaipur Do?
Getting an NBFC license wrong is expensive in a specific way: RBI does not give partial credit for an application that’s mostly right, and a rejected or withdrawn filing sets a promoter back months, not weeks, before they can refile. Marcken Consulting LLP’s role is to get the eligibility, structure and paperwork right the first time, across four pieces of work:
- Eligibility and category assessment — confirming the company actually meets the “principal business” test for a non-banking financial company (Section 3), and choosing the right category — NBFC-ICC, NBFC-Factor, NBFC-MFI, NBFC-P2P, Account Aggregator or another — since each carries a different Net Owned Fund floor and a different compliance regime (Sections 4 and 5).
- Net Owned Fund structuring — confirming the NOF is computed correctly under Section 45-IA, deposited as an unencumbered fixed deposit, and supported by a statutory auditor’s certificate RBI will actually accept.
- The business plan and application — RBI’s five-year business plan requirement is where many applications actually fail; we build the plan, the promoter and director “fit and proper” documentation, and file through the PRAVAAH portal (Section 8).
- Coordination through to the Certificate of Registration — responding to RBI’s rounds of clarification, which for a digital-lending or fintech-linked model now routinely cover Lending Service Provider (LSP) and Default Loss Guarantee (DLG) arrangements, with Marcken Consulting LLP staying with the promoter until the CoR is issued.
2. Why Jaipur and Rajasthan Matter for NBFC Registration
Jaipur’s case for NBFC licensing rests on a foundation built around where RBI’s own regional supervision is seated for this state, on the industrial and financial base that actually needs non-bank credit, and on Rajasthan’s role in India’s textile and manufacturing ecosystem.
- RBI’s own Regional Office for Rajasthan: Reserve Bank of India, Jaipur Regional Office, Rambagh Circle, Tonk Road, Jaipur – 302 004 — the office whose jurisdiction covers the entire state of Rajasthan, and the office through which a Rajasthan-registered applicant’s physical application set and post-registration supervision are routed.
- A real, local financial services culture: Jaipur sits at the centre of Rajasthan’s business and trading ecosystem, with a natural investor base and existing financial services infrastructure that makes non-bank financial intermediation a logical next step for the state’s capital.
- An industrial and trading base that genuinely needs non-bank credit: Rajasthan is one of India’s major textile, apparel and engineering-goods manufacturing hubs, with concentrated MSME activity in hand-printed textiles and apparel (Jaipur’s Pink City and surrounding areas), marble and stone, chemicals, and engineering goods. A large share of these units — smaller manufacturers and traders without the collateral or documentation profile larger banks prefer — sit exactly in the gap that MSME-focused, gold-loan and equipment-finance NBFCs are built to serve.
- Jaipur’s specific context for factoring and supply-chain finance: Jaipur’s textile and apparel exporters and wholesalers have historically relied on trade credit and invoice discounting in ways that conventional bank factoring doesn’t always reach, making an NBFC-Factor structure directly relevant to the local industrial base.
Considering NBFC registration for your Jaipur or Rajasthan company? Marcken Consulting LLP offers a no-charge 30-minute consultation to walk through eligibility, Net Owned Fund and the right category for your business.
3. What Actually Makes a Company an NBFC
Section 45-I(f) of the RBI Act, 1934 defines a non-banking financial company, but the practical test promoters need to clear is what’s informally called the 50-50 test: a company is treated as conducting financial business as its principal business if more than 50% of its total assets are financial assets, and more than 50% of its gross income comes from those assets. A company that clears this test cannot commence or carry on non-banking financial business without a Certificate of Registration from RBI under Section 45-IA — and doing so anyway is a criminal offence under Section 58B(4A) of the Act, carrying imprisonment of between 1 and 5 years and a fine of between ₹1 lakh and ₹5 lakh.
Two structural points matter early. First, only a company incorporated under the Companies Act, 2013 (or its 1956 predecessor) can hold a CoR — an individual, partnership or LLP cannot register directly. Second, certain categories are carved out of RBI’s registration requirement because they’re already regulated elsewhere — housing finance companies were transferred to RBI’s own regulatory umbrella in 2019 and are no longer a separate NHB-regulated exemption, while Nidhi companies (Ministry of Corporate Affairs), chit-fund companies and entities regulated by SEBI or IRDAI for their core activity remain outside RBI’s NBFC framework to avoid duplicate oversight.
4. Choosing the Right NBFC Category
RBI’s NBFC categories are built around what the company actually does, and the category chosen at registration shapes the Net Owned Fund requirement, the permitted activities and the ongoing compliance load for the life of the company:
| Category | What it does |
|---|---|
| NBFC-ICC (Investment and Credit Company) | The broadest, most commonly chosen category — lending, investment in shares/securities, and related financing activity under one licence. |
| NBFC-Factor | Purchases receivables from businesses at a discount — factoring must be the company’s principal business, directly relevant to Jaipur’s textile exporters and supply-chain finance needs. |
| NBFC-MFI | Micro-finance lending to low-income borrowers, subject to income-linked borrower eligibility and lending caps. |
| NBFC-P2P | Operates a peer-to-peer lending platform connecting individual lenders and borrowers — does not lend on its own book. |
| NBFC-AA (Account Aggregator) | Consolidates and shares a customer’s financial information across institutions, with the customer’s consent, under the Account Aggregator framework — does not hold or move funds itself. |
| Core Investment Company (CIC) | Holds investments in group companies’ shares and debt, largely for group-structuring purposes rather than public-facing lending. |
| Housing Finance Company (HFC) | Finances housing, now registered with and regulated by RBI directly rather than the National Housing Bank. |
For most Jaipur promoters approaching Marcken Consulting LLP for the first time, NBFC-ICC is the starting point, precisely because it doesn’t force an early, narrow commitment to one specific product line the way a factoring, MFI or P2P licence does. However, NBFC-Factor deserves special consideration for Jaipur’s textile and apparel exporters given the specific fit with local supply chains.
5. Minimum Net Owned Fund by Category
Net Owned Fund is computed under Section 45-IA — broadly, paid-up equity capital and free reserves, reduced by accumulated losses, deferred revenue expenditure and other intangible assets, and further adjusted for certain investments in and loans to group companies. It must be unencumbered and evidenced by a statutory auditor’s certificate; RBI will not accept an NOF figure that can’t be traced to an actual, lien-free deposit.
| Category | Minimum NOF (New Registrations) |
|---|---|
| NBFC-ICC | ₹10 crore (effective 1 October 2022; existing NBFCs have glide path until 31 March 2027) |
| NBFC-Factor | ₹10 crore (effective 1 October 2022; existing NBFCs have glide path until 31 March 2027) |
| NBFC-MFI (general) | ₹10 crore (effective 1 October 2022; existing NBFCs have glide path until 31 March 2027) |
| NBFC-MFI (North-East region) | ₹10 crore (effective 1 October 2022; existing NBFCs have glide path until 31 March 2027) |
| NBFC-P2P and Account Aggregator | ₹2 crore |
| Housing Finance Company | ₹20 crore |
| Infrastructure Finance Company / Infrastructure Debt Fund | ₹300 crore |
The NOF requirement doesn’t end at registration — RBI expects it to be maintained on a continuing basis, not treated as a one-time deposit to clear the application. Marcken Consulting LLP builds this into the readiness work rather than treating it as a closed item once the CoR arrives.
6. The Scale-Based Regulation Framework
Since October 2022, RBI has regulated NBFCs under a four-layer Scale-Based Regulation (SBR) framework rather than a single uniform rulebook: a Base Layer for the smallest, lowest-risk NBFCs; a Middle Layer with tighter governance and prudential norms; an Upper Layer for the largest and most systemically significant NBFCs, which RBI names explicitly and subjects to bank-like supervision; and a Top Layer held in reserve for cases of rapid, RBI-flagged growth in systemic risk. Which layer a company sits in at registration, and which layer it’s likely to move into as it scales, shapes the governance, disclosure and capital-adequacy expectations RBI will hold it to well before it becomes systemically large enough to matter in practice — something Marcken Consulting LLP maps out at the business-plan stage rather than leaving a client to discover after the first few years of growth.
7. Regulatory Updates Every Jaipur NBFC Applicant Should Track in 2026
RBI reworked the registration and exemption framework twice within a few months in 2026, and both changes are directly relevant to a Rajasthan promoter deciding whether to register at all — including the family-owned and group holding structures common among the state’s business houses.
The New Three-Tier NBFC Framework (effective 1 July 2026): Following a draft released on 10 February 2026, RBI notified the Reserve Bank of India (Non-Banking Financial Companies — Registration, Exemptions and Framework for Scale Based Regulation) Amendment Directions, 2026 on 29 April 2026, with effect from 1 July 2026. The amendment formally splits NBFCs that take no public funds and have no customer interface into two outcomes: Unregistered Type I NBFCs (asset size below ₹1,000 crore, exempt from registration) and Type I NBFCs (asset size ₹1,000 crore or more, must register), alongside standard Type II NBFCs (which take public funds or have a customer interface).
Existing NBFCs have a one-time window to apply for deregistration through PRAVAAH by 31 December 2026, provided they can show audited financials, a statutory auditor’s certificate confirming no public funds or customer interface, and a board resolution undertaking not to access either in future. Marcken Consulting LLP treats this as the first question to work through with a Rajasthan promoter weighing a group entity’s structure — including the holding and investment vehicles common to the state’s business houses — not the last.
PRAVAAH Has Fully Replaced COSMOS: RBI’s PRAVAAH portal (Platform for Regulatory Application, Validation and Authorisation) launched on 28 May 2024 and became the mandatory filing channel for every RBI-regulated entity, including new NBFC applications, from 1 May 2025 — the older COSMOS system is no longer used for a Certificate of Registration application.
8. The Registration Process: From Incorporation to Certificate of Registration
- Incorporate the company under the Companies Act, 2013, with an objects clause that clearly covers financial/NBFC activity, and obtain DIN and DSC for all proposed directors.
- Infuse and evidence the Net Owned Fund for the chosen category (Section 5), deposited in a scheduled commercial bank as an unencumbered fixed deposit, supported by a statutory auditor’s certificate and a banker’s confirmation that the funds carry no lien.
- Build the five-year business plan — proposed activities, target customer segments, projected financials, risk-management policy and capital planning. RBI reviews this closely, and a plan that reads as generic rather than specific to the company’s actual model — its target textile exporter base, its product mix, its geography within Rajasthan — is a common reason applications stall.
- Assemble the “fit and proper” file for every director and shareholder holding more than a threshold stake — KYC documents, credit reports, and at least one full-time director with a track record of banking or financial-services experience, which RBI treats as close to non-negotiable.
- File on PRAVAAH — create an applicant login, complete the Certificate of Registration application with the full document set, and receive the Company Application Reference Number (CARN) on submission.
- Submit the physical application — a paginated hard copy of the application and supporting documents, along with the CARN acknowledgement, to RBI’s Jaipur Regional Office, which holds jurisdiction over the company’s registered office anywhere in Rajasthan.
- Respond to RBI’s queries — RBI’s Department of Regulation typically raises one or more rounds of clarification; for a digital-lending or fintech-linked model, these now routinely examine Lending Service Provider (LSP) and Default Loss Guarantee (DLG) arrangements in detail.
- Receive the Certificate of Registration once RBI is satisfied on eligibility, NOF, business plan and promoter background.
Timelines vary widely depending on how complete the filing is at the outset: a well-prepared, straightforward NBFC-ICC application commonly clears in roughly 3 to 6 months from the PRAVAAH filing date, while an application with a digital-lending, LSP or DLG structure, or one that draws multiple rounds of RBI clarification, can run 9 to 14 months. Section 45-IA does not prescribe a statutory deadline by which RBI must decide, so there’s no fixed backstop to plan against — which is exactly why Marcken Consulting LLP puts the same weight on the completeness of the initial filing as RBI itself does.
9. What the Registration Actually Costs
Three cost layers apply, and only the smallest is capital rather than expense:
- The Net Owned Fund itself — ₹10 crore for a standard NBFC-ICC, held as an unencumbered deposit rather than spent; this is capital deployed into the business, not a fee.
- RBI’s own application fee — industry guidance on the current figure is inconsistent following the move to PRAVAAH. Marcken Consulting LLP confirms the exact current fee directly against RBI’s own published schedule immediately before filing.
- Professional and incidental costs — company incorporation fees, notarisation and stamp-paper costs for declarations and affidavits, the statutory auditor’s NOF certificate, and Marcken Consulting LLP’s own fee for preparing the business plan, structuring the application and managing RBI’s queries through to the CoR, scoped and quoted separately from the outset so a promoter can see exactly what’s capital, what’s a regulatory cost, and what’s advisory fee before the filing begins.
10. Life After the Certificate of Registration
The CoR is the start of an ongoing compliance relationship with RBI, not the end of one. A registered NBFC is expected to maintain a minimum Capital to Risk-Weighted Assets Ratio (CRAR) of 15%, file periodic regulatory returns (their exact frequency and form depend on the company’s SBR layer), operate under a board-approved Fair Practices Code, and run KYC and anti-money-laundering procedures consistent with RBI’s Master Directions. Promoters, lenders and counterparties can independently check any company’s current registration status on RBI’s published list of registered NBFCs. Marcken Consulting LLP builds this compliance calendar into the engagement from day one, rather than leaving a newly registered NBFC to discover its reporting obligations after the fact.
11. What a Marcken Consulting LLP NBFC Registration Engagement Includes
| Deliverable |
|---|
| Eligibility and category assessment, including whether the 2026 Unregistered Type I framework removes the need to register at all |
| Net Owned Fund computation and the statutory auditor’s certificate RBI requires |
| The five-year business plan, financial projections and risk-management framework, tailored to your specific model |
| “Fit and proper” documentation for directors and significant shareholders |
| PRAVAAH filing and preparation of the physical application set for RBI’s Jaipur Regional Office |
| Responses to RBI’s rounds of clarification through to the Certificate of Registration |
| Post-registration compliance calendar: CRAR, returns, Fair Practices Code and KYC/AML set-up |
For companies further along the NBFC lifecycle, Marcken Consulting LLP’s own NBFC due diligence and NBFC takeover service pages cover acquisition and change-of-control scenarios. Our general NBFC registration service page covers this practice more broadly across India, and our IPO consultant in Jaipur guide is the reference point once a registered NBFC later considers a public listing.
12. Why Marcken Consulting LLP Is the Right NBFC License Consultant in Jaipur
Marcken Consulting LLP is led by CA Murli Chandak, an IBBI-Registered Valuer for Securities or Financial Assets, and NBFC registration sits at the centre of this firm’s practice rather than as a side offering bolted onto general company incorporation:
- A dedicated NBFC practice, not a generic registration desk: Marcken Consulting LLP already runs standalone NBFC registration, NBFC due diligence, NBFC takeover and business plan for NBFC service lines — a promoter isn’t the first NBFC case this firm has built a business plan or an NOF certificate for.
- The financial-structuring work built in, not outsourced: Net Owned Fund computation, restated financials, and the statutory auditor’s certificate RBI’s Department of Regulation actually accepts on first submission all sit inside the same Chartered Accountancy practice, rather than being handed off between a registration agent and a separate CA firm.
- Valuation authority that carries beyond registration day: where an NBFC registration sits alongside a fundraise, a promoter restructuring, or a later change of control, the same business valuation and IBBI-Registered Valuer work this firm runs applies directly — there’s no need to bring in a second firm when the company’s next milestone arrives.
- Compliance built for what comes after the CoR: GST and income-tax positions, related-party documentation, and the governance structure RBI expects a newly registered NBFC’s board to already have in place, so the company isn’t rebuilding its compliance function in year two.
- One firm, one point of accountability: promoter meetings, document collection and RBI liaison run through Marcken Consulting LLP from application to CoR — not split across a registration agent, a separate auditor and a separate valuer.
What that adds up to, in practice, is an application RBI can actually process quickly, because the eligibility, NOF and business plan were built correctly by one accountable firm the first time — not patched together in response to RBI’s queries after a generic filing agent’s work fell short.
13. Frequently Asked Questions
Q1. What is the minimum capital required to start an NBFC in India?
For a standard NBFC-ICC, NBFC-Factor or NBFC-MFI, the minimum Net Owned Fund is ₹10 crore for new registrations, effective from 1 October 2022. Other categories carry different floors — ₹2 crore for an NBFC-P2P or Account Aggregator, up to ₹300 crore for an Infrastructure Finance Company. Existing entities have glide paths.
Q2. Do I still apply through the COSMOS portal?
No. PRAVAAH (Platform for Regulatory Application, Validation and Authorisation) has been the mandatory filing channel for all RBI-regulated entities, including NBFC Certificate of Registration applications, since 1 May 2025.
Q3. Does every company that lends or invests need to register with RBI?
No — from 1 July 2026, a company that neither avails public funds nor has a customer interface, and whose assets stay below ₹1,000 crore, can operate as an Unregistered Type I NBFC, exempt from registration under RBI’s 2026 amendment directions.
Q4. How long does NBFC registration actually take?
A well-prepared, straightforward NBFC-ICC application typically clears in 3 to 6 months from the PRAVAAH filing date. Applications involving digital-lending, LSP or DLG structures, or multiple rounds of RBI clarification, commonly take 9 to 14 months.
Q5. What happens if a company carries on NBFC business without registering?
It’s a criminal offence under Section 58B(4A) of the RBI Act, 1934, carrying imprisonment of between 1 and 5 years and a fine of between ₹1 lakh and ₹5 lakh, on top of RBI’s power to direct the company to stop the business immediately.
Q6. What is the Scale-Based Regulation framework?
Since October 2022, RBI has regulated NBFCs across four layers — Base, Middle, Upper and Top — with progressively stricter governance, disclosure and capital norms as a company moves up the layers.
Q7. Can a private limited company register as an NBFC?
Yes — both private and public limited companies incorporated under the Companies Act can hold a Certificate of Registration. Individuals, partnerships and LLPs cannot register directly.
Q8. Is a business plan really necessary, or is it a formality?
It’s one of the most closely scrutinised parts of the application. RBI reviews the five-year plan for whether the proposed activities, target market, financial projections and risk-management approach are specific and credible for that particular company.
Q9. Do NBFCs need a minimum capital adequacy ratio after registration?
Yes — a registered NBFC is expected to maintain a minimum Capital to Risk-Weighted Assets Ratio (CRAR) of 15% on an ongoing basis, alongside periodic RBI returns, a Fair Practices Code and KYC/AML procedures.
Q10. When should we bring in Marcken Consulting LLP?
Before incorporating the entity, if possible — the objects clause, shareholding structure and director selection all affect the application later, and unwinding a structural choice after incorporation costs more time than getting it right at the outset.
Speak to Us
Marcken Consulting LLP offers a no-charge 30-minute consultation to discuss your company’s NBFC registration, structuring or compliance position.
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 date of filing. This guide is general information, not investment, legal or regulatory advice.
