RBI’s 2025 project-finance framework: a checklist for NBFC project files

Start with the current rulebook

The RBI issued its Project Finance Directions on 19 June 2025, with effect from 1 October 2025. The framework brought project-finance requirements together across several lender categories, including NBFCs. The original notification remains useful background, but a current project file needs the applicable consolidated directions too.

Source: RBI’s original Project Finance Directions, 2025 (PDF, hosted by UP RERA) ↗

What to check for an NBFC

The NBFC Credit Facilities Directions, updated on 15 July 2026, contain the project-finance provisions in Chapter VI. They address financial closure, documented commercial-operation dates and a disbursement schedule linked to completion stages. Paragraph 75 connects drawdowns with completion, equity and other funding, and remaining clearances; it calls for LIE or architect certification of completion stages. Applicability and transition treatment require a project-specific review.

Source: RBI NBFC Credit Facilities Directions, Chapter VI ↗

Build one consistent project record

Our practical recommendation is to begin with a single project information sheet. Record the project cost, sources of funds, implementation schedule and the assumptions used in the financial model. Give each document a version date and an owner. This makes it easier to see whether the technical report and the proposed financing still describe the same project.

For example, a revised equipment order may change both the construction sequence and the expected operating capacity. Updating the cash-flow model alone leaves the engineer working from an old baseline. Bring the change into the cost estimate, programme and information shared with the lender at the same time.

Prepare the drawdown evidence early

Treat each proposed drawdown as a small evidence pack. Our suggested working index includes the request, the relevant work packages, progress information, expenditure support, funding updates and open conditions. Ask the institution what format and professional certifications it needs before collecting signatures.

A concise exceptions list is useful: what is missing, who will provide it and when it is expected. This lets the lender distinguish a document still being assembled from a substantive project risk. It also avoids repeating a general request for “all pending information” without identifying the actual gap.

Keep changes visible

When a completion forecast moves, show the reason, the critical dependencies and the effect on remaining cost and operating assumptions. A revised date without that explanation gives the credit team little basis for a decision. An owner’s optimistic target and the engineer’s assessed programme should be distinguishable in the file.

Before agreeing an appointment, confirm whether BitCon is acting for the promoter or independently for the lender. We do not arrange debt on a project where we act as the lender’s independent consultant. The appointment letter should make the reporting relationship and scope clear.

These preparation steps are our working suggestions, not a substitute for the lender’s credit process. The institution’s compliance team should confirm the current directions, transition provisions and stressed-asset treatment applicable to the exposure.