Schedule I explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Serial numbers F.9 to F.11 close the financial services block of the sectoral Table in Schedule I to the Foreign Exchange Management (Non-debt Instruments) Rules, 2019. F.9 is the pension sector. F.10, "Other Financial Services", is the entry under which non-banking financial activities regulated by a financial sector regulator take foreign investment. F.11, added in August 2024, covers white label ATM operations. The Rules are made under clauses (aa) and (ab) of sub-section (2) of section 46 of the Foreign Exchange Management Act, 1999.
This article states the position as per the Rules notified on 17 October 2019 (S.O. 3732(E)) as amended by the notifications named in this article; the latest amendment consulted is S.O. 4870(E) dated 2 September 2026. Later amendments, press notes and sector regulators' conditions should be checked before acting. For a foreign-funded finance company, see our FEMA advisory service.
Pension sector: 49%, automatic route, with ownership and control of an Indian pension fund remaining with resident Indian entities. Other Financial Services: hundred per cent, automatic route, where the activity is regulated by a financial sector regulator; an activity that is not regulated, only partly regulated or of doubtful regulatory oversight may take foreign investment up to hundred per cent only under the Government approval route. White Label ATM Operations: hundred per cent, automatic route, with a minimum net worth of one hundred crore rupees maintained at all times.
The entries after the amendment
| Serial number | Sector or activity | Sectoral cap | Entry route |
|---|---|---|---|
| F.9 | Pension Sector | 49% | Automatic |
| F.9.1 | Other conditions (a) to (c) | - | - |
| F.10 | Other Financial Services | Hundred per cent | Automatic |
| F.10.1 | Other conditions (a) to (e) | - | - |
| F.11 | White Label ATM Operations (WLAO) | Hundred per cent | Automatic |
| F.11.1 | Other conditions (a) to (c) | - | - |
The Table prints the hundred per cent cap as a percentage figure; it is written in words throughout this article.
Which notification changed what
| Provision | Change | Notification |
|---|---|---|
| F.9, F.9.1, F.10, F.10.1 | As notified on 17 October 2019 | None of the 19 amending notifications up to 2 September 2026 changes them |
| F.11, F.11.1 | Inserted after serial number F.10 | Foreign Exchange Management (Non-debt Instruments) (Fourth Amendment) Rules, 2024, S.O. 3492(E) dated 16 August 2024, clause 6, item (iii) |
S.O. 3492(E) came into force on the date of its publication in the Official Gazette.
Serial number F.9: pension sector
(a) Foreign investment in this sector shall be in accordance with the Pension Fund Regulatory and Development Authority (PFRDA) Act, 2013.
(b) Foreign investment in pension funds is subject to the condition that entities investing in capital instruments issued by an Indian pension fund as per section 24 of the PFRDA Act, 2013 shall obtain necessary registration from the PFRDA and comply with other requirements under that Act and the rules and regulations framed under it for so participating in pension fund management activities in India.
(c) An Indian pension fund shall ensure that its ownership and control remains at all times with resident Indian entities as determined by the Government of India or the PFRDA as per the rules or regulations issued by them.
Serial number F.10: other financial services
(a) Meaning. "Other Financial Services" means financial services activities regulated by financial sector regulators, namely the Reserve Bank, the Securities and Exchange Board of India, the Insurance Regulatory and Development Authority, the Pension Fund Regulatory and Development Authority, the National Housing Bank or any other financial sector regulator as may be notified by the Government of India.
(b) Regulator's conditions. Foreign investment in such activities is subject to conditionalities, including minimum capitalisation norms, as specified by the concerned regulator or Government agency.
(c) Unregulated or partly regulated activity. Such activities need to be regulated by one of the financial sector regulators. In all financial services activity which is not regulated by any financial sector regulator, or where only part of the activity is regulated, or where there is doubt regarding the regulatory oversight, foreign investment up to hundred per cent will be allowed under the Government approval route, subject to conditions including minimum capitalisation requirement, as may be decided by the Government.
(d) Statutory limits. Where an activity is specifically regulated by an Act, the foreign investment limits shall be restricted to those levels or limits that may be specified in that Act, if so mentioned.
(e) Downstream investment. Downstream investments by any of these entities that are treated as indirect foreign investment for the investee entity shall be subject to the Rules; see downstream investment conditions under rule 23.
Where an NBFC fits
The Table does not use the term "NBFC" in serial number F.10. A non-banking financial company's activity falls under F.10 because it is a financial services activity regulated by the Reserve Bank, one of the regulators named in condition (a). Two other provisions of Schedule I bear on such companies:
- Paragraph 3(b)(v)(B): foreign investment in investing companies registered as NBFCs with the Reserve Bank is under the hundred per cent automatic route. Paragraph 3(b)(v)(A) requires prior Government approval for investing companies not so registered and for core investment companies. See sectoral caps, investing companies and joint audit.
- The opening line of block F and the proviso to paragraph 3(b)(iii): financial services other than those indicated under F require prior Government approval.
Reading F.10 as a sequence of questions
| Question | If yes |
|---|---|
| Is the activity listed elsewhere under F (banking, insurance, pension and so on)? | That entry applies |
| Is the activity regulated by a financial sector regulator named or notified under condition (a)? | F.10: hundred per cent, automatic route, with the regulator's conditions including minimum capitalisation norms |
| Is the activity unregulated, only partly regulated, or of doubtful regulatory oversight? | Up to hundred per cent under the Government approval route, with conditions decided by the Government |
| Does an Act regulating the activity specify a foreign investment limit? | The limit in that Act applies (condition (d)) |
Serial number F.11: white label ATM operations
(a) Net worth. Any non-bank entity intending to set up White Label ATMs (WLAs) should have a minimum net worth of one hundred crore rupees as per the latest financial year's audited balance sheet, to be maintained at all times.
(b) Overlap with F.10. In case the entity is also engaged in any "Other Financial Services" referred to in serial number F.10, the foreign investment in the company setting up WLA shall also comply with the minimum capitalisation norms, if any, for foreign investments in such other financial services.
(c) Reserve Bank guidelines. FDI in the WLAO will be subject to the specific criteria and guidelines issued by the Reserve Bank under the Payment and Settlement Systems Act, 2007.
The Reserve Bank's guidelines are named by the Table and are not set out in the Rules.
A worked example
Fenwick Capital Partners LP, a foreign fund, considers three Indian companies.
- Dhanvriddhi Finance Limited is a lending company registered with the Reserve Bank. Its activity is regulated by a financial sector regulator, so serial number F.10 applies: hundred per cent, automatic route, subject to the Reserve Bank's conditions including any minimum capitalisation norms.
- Nivesh Sahayak Private Limited offers a financial service that no financial sector regulator regulates. Condition F.10.1(c) applies: foreign investment up to hundred per cent is allowed only under the Government approval route, with conditions the Government may decide.
- Suvidha ATM Networks Private Limited, a non-bank entity, plans to set up white label ATMs. Serial number F.11 allows hundred per cent on the automatic route. Suvidha needs a net worth of at least one hundred crore rupees on its latest audited balance sheet and must maintain it at all times, and must meet the Reserve Bank's criteria under the Payment and Settlement Systems Act, 2007.
Fenwick also wants 30% of an Indian pension fund. Serial number F.9 allows up to 49% on the automatic route; Fenwick must obtain the registration the PFRDA Act requires, and ownership and control must remain with resident Indian entities.
Need help with foreign investment in a finance company?
The first question is who regulates the activity; the route follows from the answer. Our FEMA advisory team checks the regulatory status, the entry under block F and the capitalisation conditions before funds are remitted.
Key takeaways
- Pension sector: 49%, automatic route, under the PFRDA Act, 2013.
- Other Financial Services: hundred per cent, automatic route, for activities regulated by a financial sector regulator.
- Unregulated, partly regulated or doubtful activities: up to hundred per cent under the Government approval route.
- A limit in a specific Act regulating the activity prevails.
- White Label ATM Operations: hundred per cent, automatic route, inserted by S.O. 3492(E) dated 16 August 2024.
- A non-bank WLA entity needs a minimum net worth of one hundred crore rupees at all times.
Read next
- Schedule I paragraph 3(b): sectoral caps, investing companies and joint audit
- Serial numbers F.4 to F.7 of the Table: stock exchanges, power exchanges and credit information companies
- Serial number F.8 of the Table: insurance companies, intermediaries and LIC
- NBFC regulations: the Reserve Bank framework
Disclaimer: Based on the Gazette text of the instrument this article names, as notified and as amended by the notifications named in the article (for the Foreign Exchange Management (Non-debt Instruments) Rules, 2019 the latest amendment consulted is S.O. 4870(E) dated 2 September 2026), as consulted on 2 October 2026. There is no official consolidated text; the provisions were read with each amendment applied. Sectoral caps, entry routes, conditions, forms and time limits change by notification, press note and circular; later changes should be checked on the Gazette, DPIIT and Reserve Bank sites. This article is general information, not legal advice; check the official text before acting.