Chapter IIIB — Non-Banking Institutions and Financial Institutions
Section 45NAA: Powers in respect of group companies
Reviewed by CA Nikhil Gupta · Last reviewed 18 September 2026
Section 45NAA gives RBI powers in relation to group companies of an NBFC where group-level information or inspection is necessary for consolidated supervision and the statutory conditions are met.
Operative provisionOfficial sources mappedProvision-specific decode
Finin2min - Section 45NAA in 2 minutes
Statutory structure and clause / subsection decode
This map separates the operative limbs of this provision so thresholds, powers, conditions and exceptions are not collapsed into a single summary.
Scope
Section 45NAA gives RBI powers in relation to group companies of an NBFC where group-level information or inspection is necessary for consolidated supervision and the statutory conditions are met.
Operative limb
The section recognises that risk can be shifted through affiliates and allows RBI to obtain information/inspect relevant group entities rather than limiting supervision to the licensed NBFC shell.
Legal boundary
Use group structure, related-party data and the 2025 governance/SBR framework to identify entities and transactions within supervisory scope.
Worked practical example
Facts. A holding company that is not itself an NBFC may still need to provide information when RBI validly invokes Section 45NAA for supervision of the regulated group.
Compliance points and common mistakes
- Do not decide the issue from the heading alone. Map the facts to the operative words of Section 45NAA and to each relevant subsection, clause, proviso or explanation shown above.
- Keep the statutory question separate from the operational overlay. Use group structure, related-party data and the 2025 governance/SBR framework to identify entities and transactions within supervisory scope.
- Do not convert an exception, exemption or discretionary RBI/Government power into an automatic entitlement. Record the authority, conditions and effective date.
- Where the provision is historical, omitted or repealed, state that status prominently and do not present it as a current compliance obligation.
Connected provisions and instruments
Section 45NAA has no universal instrument dependency in this package. Add an RBI circular or direction only when its subject, entity and effective date cover the issue being analysed.
Questions and answers
What is the purpose of Section 45NAA?
Powers in respect of group companies: Section 45NAA gives RBI powers in relation to group companies of an NBFC where group-level information or inspection is necessary for consolidated supervision and the statutory conditions are met.
Which statutory limb should be checked first?
Scope - Section 45NAA gives RBI powers in relation to group companies of an NBFC where group-level information or inspection is necessary for consolidated supervision and the statutory conditions are met.
What is the next legal boundary?
Operative limb - The section recognises that risk can be shifted through affiliates and allows RBI to obtain information/inspect relevant group entities rather than limiting supervision to the licensed NBFC shell.
What record should support the conclusion?
Section 45NAA file evidence: Maintain an up-to-date group chart, ownership/control evidence, related-party exposures, inter-company agreements and requested group information.
Primary sources
- Department of Financial Services - consolidated RBI Act (states amendments through Finance Act, 2022)
- India Code - Reserve Bank of India Act, 1934
Source control for Section 45NAA: use the official consolidated RBI Act for the statutory text and footnotes, then separately reconcile any post-Finance Act 2022 amendment, commencement notification or RBI instrument relevant to the event date.