NBFCs that do not require RBI registration in India 1. The starting point: when is registration required? A company is treated as an NBFC if it satisfies the principal business criteria (commonly referred to as the “50-50 test”) and carries on the business of a non-banking financial institution. If it qualifies as an NBFC, it ordinarily requires a Certificate of Registration (CoR) under section 45IA of the RBI Act, 1934. The RBI’s consolidated framework for this is set out in

Executive Summary On September 15, 2025, the Reserve Bank of India (“ RBI ”) issued a single, consolidated Master Direction (“ MD ”) to regulate Payment Aggregators (“ PAs ”) operating in India, bringing together rules for online, physical/point of sale and cross-border aggregation in a coherent framework. The MD applies to all banking, non-banking (Indian), and scheduled commercial banking entities that interact with the three categories of PAs: physical, online and cross-

Introduction The Reserve Bank of India (“ RBI ”), exercising the powers granted by the Banking Regulation Act, 1949, RBI Act, 1934 and the National Housing Bank Act, 1934, and in the public interest, issued the new Non-Fund-Based (“ NFB ”) Credit Facilities Directions, 2025 (“ NFC Directions ”). These NFC Directions represent a landmark reform in the management of credit guarantees, letters of credit, and co-acceptances. The resultant overhaul aims to bring consistency, tra

The Indian Context: From Caution to Strategic Engagement For over a decade, India's approach to foreign bank presence remained restrictive. Despite the 2005 roadmap allowing foreign banks to choose between branch and wholly owned subsidiary modes, not a single foreign bank selected the subsidiary route. The preference for branch presence reflected a fundamental asymmetry: foreign banks gained market access while India bore limited jurisdiction and control over these entitie

Introduction The Reserve Bank of India’s Master Direction on Cash Reserve Ratio (“ CRR ”) and Statutory Liquidity Ratio (“ SLR ”), 2025 (“ Directions ”) represents a recalibration of the liquidity regulation ecosystem that underpins India’s banking stability. This framework aims to consolidate a patchwork of circulars and notifications into a single, coherent directive bringing long-overdue clarity to two of the most foundational prudential tools in RBI’s monetary policy ar

Securities and Exchange Board of India’s (“ SEBI ”) “accredited investor” framework in the Alternative Investment Funds (“ AIF ”) space is built around a simple trade-off: once all investors in a scheme are demonstrably sophisticated, SEBI is prepared to step back from some standardised protections and allow greater freedom of contract. The SEBI (AIFs) (Third Amendment) Regulations, 2025 (“ Third Amendment ”) crystallise this idea through a new label called the “Accredited In

Introduction The Reserve Bank of India (“ RBI ”) has, over time, moved from scattered circulars to a structured framework for regulating who may own shares in an Indian bank, how much they may own, and how far those shares may translate into voting power. The previous position for “banking companies” was set out in the Master Direction – Reserve Bank of India (Acquisition and Holding of Shares or Voting Rights in Banking Companies) Directions, 2023 (“ 2023 Directions ”), re

Introduction With the rapid growth of digital payments in India, safeguarding transactions has become one of our top priorities. On September 25, 2025, the Reserve Bank of India (“ RBI ”) introduced new guidelines - RBI (Authentication mechanisms for digital payment transactions) Directions, 2025 (“ Directions 2025 ”) for authentication mechanisms for digital payment transactions. From April 1, 2026, all Payment System Providers and Payment System Participants, including bank

The Reserve Bank of India (“ RBI ”) has released its Draft Directions on Lending to Related Parties for Non-Banking Financial Companies (NBFCs), 2025, inviting public feedback by October 31st, 2025. These proposed norms aim to tighten oversight, eliminate regulatory arbitrage, and bring India's NBFC sector closer to global standards of transparency and accountability. For banking and financial services industries, this is more than a compliance update, it's a strategic inflec

The Reserve Bank of India's (“ RBI ”) Commercial Banks – Governance Directions, 2025 (“Directions”) mark a decisive shift in how Indian banks are expected to approach power, responsibility, and risk. Far from being a mere consolidation of circulars, Directions aim to transform governance from a checklist exercise into an institutional culture rooted in independence, accountability, and an explicit alignment between risk and reward. A New Architecture of Accountability The Dir

Overview The Reserve Bank of India (Universal Banks - Licensing) Guidelines, 2025 (“ Guidelines ”) represent a significant update to India's banking licensing system regime. These Guidelines are a revised consolidation of the guidelines issued on February 22, 2013, for Licensing of New Banks in the Private Sector and guidelines for ‘On Tap' Licensing of Universal Banks in the Private Sector, 2016. What's new this time is a most transparent process for private bank licences an

Introduction On September 19, 2025, the International Financial Services Centres Authority (“ IFSCA ”) issued the Draft FinTech Sandbox Framework, ( “Draft Framework ”), a strategic initiative designed to empower both domestic and international entities to test disruptive financial technologies in a controlled, live environment. The Draft Framework seeks to promote the growth of fintech innovations at International Financial Services Centres (“ IFSCs ”) from Indian and foreig

Introduction The International Financial Services Centres Authority (“ IFSCA ”) has notified the IFSCA (Fund Management) Regulations, 2025 (“ FM Regulations, 2025 ”), introducing a refreshed regulatory framework for fund management activities within IFSCs. These new regulations repeal and replace the earlier IFSCA (Fund Management) Regulations, 2022 (“ FM Regulations, 2022 ”), aiming to enhance operational clarity, investor protection, and alignment with international stand

Introduction On 21 Nov 2025, the Ministry of Labour & Employment announced the implementation of the Four Labour Codes. The four laws namely- Code on Wages, 2019 and the Code on Social Security, 2020, Occupational Safety, Health and Working Conditions Code, 2020 and the Industrial Relations Code, 2020 have now been implemented. The move consolidated 29 laws into a unified framework. Key Highlights Replaces over two dozen statutes with four comprehensive Codes: The Code on Wag

Introduction In recent years, the Financial Intelligence Unit, India (“ FIU-IND ”) has significantly sharpened its enforcement approach...

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Prefer listening over reading? Tune in to our podcast for the full article: Lexpresso by AK & Partners – Legal Shots on Banking, Fintech...

Introduction The Reserve Bank of India (RBI) has issued the Prepayment Charges on Loans Directions, 2025 on July 2, 2025. These will...

Introduction The Reserve Bank of India (RBI) has issued the Reserve Bank of India (Project Finance) Directions, 2025 (“ New Directions...

Background The Reserve Bank of India (" RBI ") on June 12, 2025 issued the Reserve Bank of India (Know Your Customer (KYC)) (Amendment)...