RBI Releases Upper-Layer NBFC List, Tata Sons Finds Mention

The Reserve Bank of India on Thursday released a list of non-banking financial companies classified under the Upper Layer framework for 2026-27. In the list, it retained Tata Sons Pvt Ltd, while clarifying that the inclusion would not prejudice the outcome of the conglomerate's application for de-registration.

The central bank identified 17 entities as part of the Upper Layer under the revised scale-based regulatory framework, which classifies non-banking financial companies into base, middle, upper and top layers depending on their size, interconnectedness and potential systemic importance.

In a footnote accompanying the notification, the RBI said the inclusion of Tata Sons in the list was "without prejudice" to the outcome of the company's application for de-registration, which remains under examination.

The latest announcement is significant because Tata Sons has been attempting to exit the upper-tier regulatory framework after restructuring its financial holdings. Under existing rules, entities designated as upper-layer NBFCs are subject to enhanced supervisory oversight and stricter compliance requirements. These requirements can include tighter governance norms, higher capital requirements and, in some cases, listing-related obligations.

The issue assumes greater importance because Tata Sons, the principal holding company of the Tata Group, had earlier sought relief from requirements that could potentially have compelled it to undertake an initial public offering. The conglomerate has maintained that it does not intend to pursue a public listing and has instead focused on reducing debt and reorganising its ownership structure to facilitate de-registration as a core investment company.

The RBI also said the 2026-27 list had been prepared on the basis of revised identification criteria after a review undertaken during 2025-26. Consequently, the central bank did not publish a list for 2025-26.

The list includes REC Ltd, Power Finance Corp Ltd, Indian Railway Finance Corp Ltd, Bajaj Finance Ltd, Shriram Finance Ltd, LIC Housing Finance Ltd, Tata Capital Ltd, Tata Sons Pvt Ltd, HDB Financial Services Ltd and Piramal Finance Ltd, among others.

Further, the RBI said that entities classified as upper-layer NBFCs will be subject to the enhanced regulatory framework for at least five years, even if they subsequently fail to meet the qualifying criteria. Accordingly, PNB Housing Finance Ltd and Sammaan Capital Ltd will continue to remain in the category despite not meeting the latest thresholds.