Why FIU-IND’s Periodic Naming of Non-Compliant Firms Changes the Stakes
FIU-IND has published three lists of non-compliant NBFCs in 2026 alone. The latest, dated 17 August 2026, names 3,293 firms that have not completed registration on the FINnet 2.0 portal. For any reporting entity that is required to register with FIU-IND but has not yet completed the required registration, the question is no longer simply whether the obligation applies. It is whether the entity can afford to remain outside FIU-IND’s reporting framework.
This article explains which non-banking financial institutions must complete FIU-IND registration for NBFC and other reporting entity categories, what the three 2026 lists mean, how to register on FINnet 2.0 and what penalties apply for continued non-compliance.
Non-banking reporting entity categories covered by FIU-IND registration
| Entity type | Statutory basis | FIU-IND registration required |
| Non-banking financial companies | PMLA Section 2(1)(l) | Yes |
| Chit fund companies | PMLA Section 2(1)(l) | Yes |
| Housing finance institutions | PMLA Section 2(1)(l), read with Section 2(1)(m) | Yes |
| Payment system operators | PMLA Section 2(1)(l), read with Section 2(1)(rc) | Yes |
| Authorized persons (forex dealers, money changers) | PMLA Section 2(1)(l) | Yes |
| Multi-state cooperative societies | FIU-IND guidelines, October 2024 | Yes |
| Department of Posts | PMLA Section 2(1)(l) | Yes |
Who must register: the PMLA “financial institution” definition
The obligation starts with a statutory definition. PMLA Section 2(1)(wa) defines a “reporting entity” as a banking company, financial institution, intermediary or a person carrying on a designated business or profession. Section 2(1)(l) then defines “financial institution” to include a non-banking financial company, a chit fund company, a housing finance institution, an authorized person, a payment system operator and the Department of Posts.
Reporting entities falling within these categories are required to register with FIU-IND so that they can comply with their reporting obligations under the PMLA and Rules. Section 12 of the PMLA requires reporting entities to maintain records and furnish prescribed information to FIU-IND and FINnet registration provides the mechanism for submitting that information. The obligation applies regardless of the entity’s transaction volume, geographic location within India or whether it considers itself “too small” for anti-money laundering obligations.
Which NBFCs must register with FIU-IND?
For NBFCs specifically, FIU-IND registration applies to every RBI-licensed type: NBFC-ICC (investment and credit companies), NBFC-MFI (microfinance institutions), NBFC-P2P (peer-to-peer lending platforms), NBFC-IFC (infrastructure finance companies), core investment companies, NBFC-Factors and account aggregators. If an NBFC holds an RBI certificate of registration, FIU-IND registration is mandatory.
Chit fund companies registered under state chit fund legislation (the Chit Funds Act, 1982 or corresponding state laws) fall within the PMLA definition by explicit statutory inclusion. Chit businesses handle large volumes of pooled cash and periodic disbursements, making them a natural focus for anti-money laundering controls. Many chit fund operators, particularly smaller ones, may not be aware that FIU-IND registration applies to them.
Housing finance companies, which have been regulated and supervised by the RBI since the transfer of regulatory powers from NHB in 2019, are also covered. Payment system operators are separately defined in PMLA Section 2(1)(rc) and included in the “financial institution” definition. Firms should assess whether their payment business falls within this category by reference to the nature of the payment system they operate and their applicable regulatory status. In October 2024, FIU-IND issued guidelines extending registration and reporting requirements to multi-state cooperative societies carrying on financial activities.
Three non-compliant lists in six months
FIU-IND has published successive public lists of NBFCs that had not fulfilled their registration obligations on FINnet 2.0. In 2026, FIU-IND has published three such lists.
The first list, dated 28 February 2026, named 4,012 NBFCs: 102 in the Middle Layer and 3,910 in the Base Layer. These NBFCs had not fulfilled their registration obligation on FINnet 2.0.
The second list, dated 30 June 2026, showed a larger non-compliant universe. FIU-IND reported that 67 of 536 Middle Layer NBFCs and 3,548 of 8,286 Base Layer NBFCs remained unregistered, a total of 3,615 non-compliant entities.
The third list, dated 17 August 2026, named 3,293 firms: 65 Middle Layer and 3,228 Base Layer. The steady decline from 4,012 in February to 3,615 in June and 3,293 in August suggests that some firms are completing registration. But over 3,200 firms remain non-compliant after three successive lists. The repeated publication of these lists makes non-compliance increasingly visible to the entities concerned and to external stakeholders.
The document states that this non-compliance “keeps these NBFCs outside FIU-IND’s reporting ambit, depriving the system of critical transaction data essential for monitoring suspicious activities.” That language signals how FIU-IND frames the problem: these firms are not just failing to complete a form. They are creating gaps in India’s financial intelligence framework.
Important distinction: registration vs. AML compliance.
FIU-IND registration is not the same as having an effective AML/CFT program. Completing FINnet 2.0 enrolment establishes the reporting entity within FIU-IND’s reporting framework. It does not, by itself, demonstrate that the entity has adequate customer due diligence, transaction monitoring, sanctions screening, record-keeping, suspicious transaction escalation or other AML/CFT controls required under the applicable framework.
How to check if your entity is listed
FIU-IND publishes each non-compliant list as a downloadable PDF on its archive page. Each entry includes the NBFC’s name, regional office, Corporate Identification Number, layer classification and registered address.
Download the August 2026 list and search for your entity by name or CIN. If your firm appears, the immediate priority is completing FINnet 2.0 registration before the next list is published. Completing all three registration stages (entity registration, Principal Officer registration and Designated Director registration) addresses the registration deficiency identified in these lists. Previously published PDFs remain available on FIU-IND’s website as historical records.
Note that these lists currently cover only NBFCs. FIU-IND registration for NBFC entities receives the most public attention because of these lists. As of the date of this article, FIU-IND does not appear to have published equivalent public lists for non-compliant chit fund companies, housing finance institutions or payment system operators. The absence of a public list for these entity types does not mean the registration obligation does not apply. Firms in these categories should not interpret the absence of a published list as an exemption.
FINnet 2.0 registration: step by step
FIU-IND registration for NBFCs and other financial institutions follows a three-stage process on the FINnet 2.0 portal.
Stage 1: Entity registration. The firm creates an account on the FINnet 2.0 portal and submits organizational details including the CIN, PAN, GST registration (where applicable), RBI certificate of registration (for NBFCs), state registrar certificate (for chit fund companies) or NHB/RBI authorization (for housing finance companies). The entity must provide its registered address, contact details and nature of business.
Stage 2: Principal Officer registration. Every reporting entity must appoint a Principal Officer under Rule 2(1)(ca) of the PML Rules. The Principal Officer furnishes information to FIU-IND and must register on the portal with identification and other details as required by the current FINGate enrolment process, along with official email and contact details. The entity should formally document the appointment through appropriate corporate governance records.
Stage 3: Designated Director registration. The entity must also designate a Director responsible for overall compliance under Rule 2(1)(b) of the PML Rules. The entity submits the Designated Director’s credentials separately on the portal.
An entity can begin filing reports on FINnet 2.0 only after completing all three stages. For the NBFC registration exercise reflected in FIU-IND’s 2026 non-compliance lists, partial completion does not satisfy the stated registration requirement.
Documents required for FINnet 2.0 registration
Information and documents to have ready for FINnet 2.0 enrolment (the exact information and documents requested may depend on the entity category and the current FINGate workflow):
- Certificate of incorporation and CIN
- RBI certificate of registration (NBFCs) or state registrar certificate (chit fund companies)
- PAN of the entity
- Identification and other details for the Principal Officer and Designated Director, as required by the current FINGate enrolment process
- Corporate governance records documenting the appointment of the Principal Officer and Designated Director
Additional compliance documentation (not necessarily uploaded to the portal but required for ongoing obligations):
- AML/CFT/CPF policy document
- Details of promoters and beneficial owners
- Records supporting customer due diligence and transaction monitoring
Post-registration reporting obligations
Completing FIU-IND registration for NBFCs and other financial institutions is the starting point, not the end. Once registered, reporting entities must maintain records and furnish information to FIU-IND on an ongoing basis under Section 12 of the PMLA and the PML Rules. The applicable reporting categories depend on the nature of the reporting entity’s activities and the transactions it handles.
Key FIU-IND reports and filing timelines
Cash Transaction Reports (CTR): Filed by the 15th of the succeeding month for cash transactions exceeding INR 10 lakh, including integrally connected cash transactions, where the prescribed reporting threshold is met during the month.
Suspicious Transaction Reports (STR): Filed within seven working days of the Principal Officer being satisfied that the transaction is suspicious. There is no monetary threshold. If a transaction gives the Principal Officer reason to believe that it involves proceeds of crime or is connected to money laundering or terrorist financing, it must be reported regardless of amount.
Cross-Border Wire Transfer Reports (CBWTR): Filed for cross-border wire transfers of more than INR 5 lakh.
Counterfeit Currency Reports (CCR): Filed for reportable transactions involving forged or counterfeit currency notes or bank notes used as genuine and other prescribed cases involving forgery of valuable securities or documents.
Non-Profit Organisation Transaction Reports (NTR): Filed for receipts by non-profit organisations exceeding INR 10 lakh.
Property Transaction Reports (PTR): Filed for prescribed purchase and sale transactions involving immovable property valued at INR 50 lakh or more that are registered by the reporting entity, as applicable.
Beyond reporting, under Section 12 of the PMLA, transaction records are generally required to be maintained for five years from the date of the transaction, while specified client and account records are required to be retained for five years after the business relationship ends or the account is closed, whichever is later. Sector-specific regulatory requirements may prescribe longer periods. The firm must also provide appropriate AML/CFT training to relevant staff, maintain appropriate AML/CFT procedures and update its policies and controls as required. The entity must notify FIU-IND of any changes to the Principal Officer or Designated Director within the time frame prescribed by the PML Rules.
Penalties for non-compliance
PMLA Section 13 provides the penalty framework. Under Section 13(2)(d), FIU-IND’s Director may impose a monetary penalty ranging from INR 10,000 to INR 1 lakh for each failure to comply with the obligations under Sections 12 and 12A. The penalty applies per instance of non-compliance, meaning that multiple reporting failures can result in cumulative penalties. The potential exposure is not limited to failure to register. The PML Rules also provide that each day’s delay in reporting a reportable transaction or in rectifying a misreported transaction beyond the prescribed time, constitutes a separate violation.
Other consequences of non-compliance
Beyond monetary penalties, non-compliance carries additional consequences. For RBI-regulated entities, FIU-IND/PMLA compliance forms part of the broader regulatory compliance framework and material deficiencies may attract supervisory attention depending on the circumstances.
FIU-IND has already demonstrated willingness to act on reporting failures. Its compliance orders page shows enforcement actions against entities ranging from finance companies to payment services and securities firms.
Separately, in April 2026, FIU-IND signed an MOU with the Indian Cyber Crime Coordination Centre (I4C). The MOU establishes a framework for cooperation between FIU-IND and I4C in relation to cybercrime, fraud and financial intelligence.
There is also the reputational cost. A firm’s presence on a publicly downloadable FIU-IND non-compliant list is visible to regulators, counterparties, auditors, investors and clients. For NBFCs seeking to raise capital, secure partnerships or maintain banking relationships, appearing on a non-compliant list is a material disclosure risk. Public non-compliance can also create reputational considerations with regulators, counterparties, lenders, investors and customers.
FIU-IND registration for NBFC entities is only one part of the broader compliance effort. Entities should also ensure that the governance, AML/CFT controls and reporting processes required under the PMLA and applicable regulatory framework are in place.
What to do now
Completing FIU-IND registration for NBFCs is a defined administrative and compliance process, but entities should assess separately whether their underlying AML/CFT framework meets applicable legal and regulatory requirements. Most firms can make meaningful progress if they address the process systematically, though the timeline will depend on the entity’s internal readiness.
Start by checking whether your entity appears on FIU-IND’s August 2026 non-compliant list. If it does, treat registration as an immediate priority.
Appoint a Principal Officer and Designated Director if you have not already done so. Formally document the appointments through appropriate corporate governance records.
Draft or update your AML/CFT policy. The policy should cover customer due diligence, sanctions screening, transaction monitoring, suspicious transaction identification and escalation, record retention and staff training. For guidance on structuring an independent review of your AML/CFT framework, see our earlier guide on independent AML/CFT/CPF reviews under FIU-IND.
Gather the required documents (CIN, RBI certificate, PAN, identification for the Principal Officer and Designated Director) and register on the FINnet 2.0 portal. Complete all three stages. Partial registration still counts as non-compliance.
Once registered, establish your reporting workflows. Build the CTR and STR filing processes into your existing transaction monitoring systems rather than running them as a separate manual exercise.
The publication of three non-compliance lists in 2026 demonstrates that FIU-IND is continuing to publicly identify NBFCs that have not fulfilled their FINnet 2.0 registration obligations. Firms that complete registration now will avoid the reputational exposure and regulatory risk that comes with remaining on future lists.
For end-to-end support with FIU-IND registration, AML/CFT framework design, Principal Officer/Designated Director appointment and post-registration compliance setup, book a free consultation with Compliance7.
Related Compliance7 guides
- Core guide: FIU-IND Registration: Applicability, Process and Compliance Guide
- Related: FIU-IND Registration for NBFCs: Requirements, Reporting & Penalties
- Related: FIU-IND Registration for NBFCs: Understanding FINnet 2.0 Registration and Building a Strong AML Compliance Framework
This article is for informational purposes only and does not constitute legal or regulatory advice. For guidance specific to your business, consult a qualified compliance professional.
