The Reserve Bank of India (RBI), through the Reserve Bank of India (Non-Banking Financial Companies – Credit Information Reporting) Amendment Directions, 2025, introduced several changes to the credit information reporting framework applicable to NBFCs. While these amendments were notified on December 4, 2025, the industry has had nearly seven months to prepare. With the amendments becoming effective from July 1, 2026, NBFCs have now entered their first reporting cycle under the revised framework.

As the implementation date has now arrived, NBFCs should have either completed or be in the process of completing their first incremental reporting under the new framework. Rather than revisiting the amendments themselves, this is an appropriate time to ask a more practical question:

Has your NBFC actually implemented the revised reporting framework?

A review of the reporting process often reveals that compliance is no longer limited to changing reporting dates. The amendments require changes across loan management systems, customer master records, CKYC capture, validation mechanisms and internal reconciliation processes.

1.  Key Changes Effective from July 1, 2026

NBFCs are required to align their credit information reporting processes with the revised framework prescribed by the RBI. The key changes include:

• More frequent reporting of credit information, with reporting reference dates on the 9th, 16th, 23rd and the last day of every month. While reporting on the 9th, 16th and 23rd is limited to incremental accounts (within 4 calendar days), a complete data file containing all active loan accounts and accounts closed since the previous reporting reference date is required to be submitted by the 5th day of the following month. 
• Reporting of the borrower’s CKYC Number, wherever available or subsequently obtained, to improve customer identification and data quality. 
• Timely rectification and re-submission of rejected data before or along with the submission relating to the subsequent reporting reference date, thereby ensuring that incorrect data is not carried forward across reporting cycles.

Through a simple illustration, let us understand how the revised reporting framework operates in practice.

2.  Practical Illustration – How the New Reporting Framework Works

Assume an NBFC submitted its last credit information file as on 30 June 2026.

(i) Between 1st July and 9th July 2026, the following transactions occur:

(ii) Now, what should be reported on or before 13th July?

The NBFC is not required to upload its entire portfolio. Instead, the incremental report should contain only:

• Mr. A’s newly opened loan
• Ms. B’s updated outstanding balance
• Mr. C’s closed account
• Mr. D’s revised DPD
• Mrs. E’s CKYC Number
• Updated guarantor information

The remaining loan accounts remain outside this reporting cycle as no changes have occurred.

(iii) Now, Suppose the CIC rejects two records…

• Mr. D’s account because of an incorrect customer identifier; and 
• Mrs. E’s CKYC Number because of an incorrect CKYC format. 

Under the earlier Directions, these records had to be corrected within 7 days of receipt of the rejection report. However, under the revised framework, these rejected records should now be corrected and re-submitted before or along with the submission for the next reporting reference date (i.e., 16th July 2026).

This ensures that incorrect information is not carried forward into subsequent reporting cycles.

(iv) What happens at the Month End?

Although only incremental information is reported on the 9th, 16th, and 23rd, the NBFC is still required to submit a complete data file containing:

• all active loan accounts; and 
• all loan accounts closed since the previous reporting reference date, 

by the 5th of the following month. Accordingly, the July month-end position should be submitted as a complete file by 5th August 2026.

3.  A Quick Compliance Health Check 

Ask yourself:

• Was the first incremental file submitted within the prescribed timeline?
• Is your Loan Management System automatically identifying incremental accounts?
• Are CKYC Numbers flowing into your CIC reporting files?
• Is there a maker-checker process before uploading data?
• Is rejected data monitored and corrected before the next reporting cycle?
• Have reporting calendars and SOPs been updated?
• Have Operations, IT and Compliance teams been trained on the revised process?

Conclusion

The amendments themselves may not be new, but their implementation certainly is. With the revised reporting framework now in force, NBFCs should move beyond understanding the amendments and focus on ensuring that their systems, reporting processes and internal controls are functioning as intended. The first reporting cycle provides an ideal opportunity to identify operational gaps, strengthen data governance and ensure seamless compliance with the revised framework before supervisory observations arise.