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-

We are delighted to share this week's AKP Banking & Finance Weekly Digest. Please feel free to write to us with your feedback at info@akandpartners.in. 1.              Regulatory Updates   1.1.          India   Reserve Bank of India (RBI)   1.1.1.      RBI issues Statement on Developmental and Regulatory Policies Reserve Bank of India (“ RBI ”) issued its Statement on Developmental and Regulatory Policies setting out a pipeline of draft measures for public consultation across

We are delighted to share this week's AKP Corporate & Compliance Weekly Digest. Please feel free to write to us with your feedback at info@akandpartners.in. 1.              Labour Law   1.1.        Centre tells Delhi High Court Industrial Relations Code rules will be finalised by February-end Central Government informed the Delhi High Court that the rules under the Industrial Relations Code, 2020 would be finalised by the end of February, and said it had issued a notificatio

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

We are delighted to share this week's AKP Banking & Finance Weekly Digest. Please feel free to write to us with your feedback at info@akandpartners.in. 1.              Regulatory Updates   1.1.          India   Reserve Bank of India (RBI)   1.1.1.      RBI issues draft Directions to harmonise natural calamity relief norms across Regulated Entities Reserve Bank of India (“ RBI ”) issued draft Directions to rationalise and harmonise prudential norms for relief and resolution of

We are delighted to share this month's AKP Dispute Resolution Monthly Digest. Please feel free to write to us with your feedback at info@akandpartners.in. 1. Arbitration Law 1.1 Real Estate and Construction 1.1.1. Supreme Court Held Party Filing Statement of Claim First Is the “Claimant” Mere Absence of Notice Does Not Invalidate Proceedings The Supreme Court has held that in arbitral proceedings, the "Claimant" is the party that files the Statement of Claim first in point of

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