NBFC Account Aggregator Compliance in India
CA for RBI AA Consent Framework, Audits & Reporting

An NBFC Account Aggregator is a specialised non-banking financial company licensed by the RBI under the Master Direction – Non-Banking Financial Company - Account Aggregator (Reserve Bank) Directions, 2016. Its single permitted business is consent-based financial data sharing: it retrieves a customer's financial information from Financial Information Providers (FIPs) — such as banks, NBFCs, insurers, and depositories — and shares it with Financial Information Users (FIUs), typically lenders and wealth platforms, strictly on the customer's explicit and revocable consent. The AA is the consent layer of the Data Empowerment and Protection Architecture (DEPA).

AA compliance lives at the intersection of finance, regulation, and technology — and that is precisely where a Chartered Accountant adds value. A Chartered Accountant for NBFC Account Aggregator compliance monitors and certifies the Net Owned Fund, prepares and files the RBI returns and the Statutory Auditor Certificate, coordinates the Information Systems and cybersecurity audits with the technology team, and keeps the consent-framework controls, governance, and reporting consistent with the RBI's AA Directions. The numbers, the audits, and the regulatory narrative all stay aligned.

Just as importantly, a CA firm for Account Aggregator compliance runs the whole thing on a calendar. The RBI evaluates an AA on a continuing record — NOF maintained, returns filed, IS audits completed, consent controls demonstrable — and a lapse on any one front is a supervisory risk. When you hire a Chartered Accountant for NBFC Account Aggregator compliance, you get a single accountable team keeping the licence in good standing, so your business can focus on the data network rather than the regulator's checklist.

Every NBFC-AA carries the standard NBFC compliance load — RBI returns, the Statutory Auditor Certificate, NOF discipline, ROC filings, and governance. What sets AA compliance apart is the layer on top, and it is a heavy one. A lending NBFC is judged largely on its financials, asset quality, and prudential norms; an Account Aggregator is judged additionally on its consent architecture, its data security, its data-blind design, and its IT systems. The Information Systems audit and the consent-artefact trail are central to AA compliance in a way they simply are not for a conventional NBFC.

That difference changes how the compliance function must be built. An AA cannot be serviced by a generalist who treats it as just another NBFC — it needs a team that understands the RBI's AA Directions, the ReBIT consent specifications, and the technology controls, and can still deliver the standard RBI and ROC compliance underneath. We bring both layers together, with internal audit and IS-audit coordination where the technology side demands deeper assurance.

At N D Savla & Associates, we provide end-to-end support for NBFC Account Aggregator compliance and the wider NBFC obligations that sit beneath it. Our AA compliance services cover:

• Consent framework compliance — review and upkeep of the consent architecture against RBI/ReBIT specifications, consent-artefact management, and audit-and-dispute readiness.
• Net Owned Fund monitoring and certification — ongoing tracking of NOF against the ₹2 crore minimum, with the supporting computations and certificates.
• RBI returns and Statutory Auditor Certificate — preparation and filing of the applicable RBI/DNBS returns and the annual SAC, with audited financial statements.
• IS and cybersecurity audit coordination — managing the Information Systems / system audits and the RBI cybersecurity framework requirements through CISA-qualified auditors, supported by our internal audit team.
• Governance and data compliance — fit-and-proper support, board and policy upkeep, grievance redressal, and alignment with related data and AML obligations such as CKYC and FIU-IND reporting where applicable.
• ROC, event-based and regulatory support — corporate filings, intimations of changes in directors or control, and NBFC legal support where regulatory questions arise.

Account Aggregator compliance rewards a team that genuinely understands both the regulation and the technology controls behind it. As a Chartered Accountant firm with strong RBI-facing experience across the NBFC space, we run the AA's financial, regulatory, and audit-coordination obligations as one system — the same team that certifies your Net Owned Fund files your returns and coordinates your IS audit, so nothing falls between functions.

Clients choose us because AA compliance stops being a scramble. You get a defined calendar with continuous NOF and control monitoring, returns and audits prepared ahead of deadlines, clear flags when the RBI's AA expectations evolve, and a compliance record that holds up in supervision, funding rounds, and partner due diligence. From the consent framework to the Statutory Auditor Certificate, we keep your NBFC-Account Aggregator licence secure and in good standing.