RBI releases second NBFC upper layer list
2 min readThe Reserve Bank of India’s second list of non‑banking finance companies (NBFCs) placed in the upper layer (UL) under the scale‑based regulation framework now includes 17 entities, which is one more than the first list released in 2022. While four government‑owned NBFCs have qualified, Tata Sons Pvt Ltd remains classified as an NBFC‑UL.
Key Takeaways
- RBI’s second NBFC upper-layer (UL) list now includes 17 entities, one more than the original 2022 list.
- Four government-owned NBFCs made the list: REC, Power Finance Corporation, IRFC and HUDCO.
- Tata Sons remains classified as an NBFC-UL, subject to tighter oversight and a mandate to go public within three years.
- PNB Housing Finance and Sammaan Capital were dropped from the UL for failing to meet the asset threshold.
Entities in the UL are NBFCs whose assets equal or exceed ₹1 lakh crore, triggering tighter oversight, stricter governance standards, bank‑style supervision and a mandate to go public within three years. The four state‑owned NBFCs that made the list are REC, Power Finance Corporation, Indian Railway Finance Corporation (IRFC) and HUDCO.
PNB Housing Finance and Sammaan Capital have been dropped from the UL because they fail to meet the asset threshold in this review. Nevertheless, they will remain under the enhanced regulatory regime for no less than five years from the date they were first placed in the layer, irrespective of any future changes in their size.
The RBI clarified that placing Tata Sons Pvt Ltd—a core investment firm 66 % held by the various Tata Trusts—on the NBFC‑UL list does not prejudice the pending decision on its de‑registration request, which is still under review. According to the prevailing listing rules, the firm was obliged to list its shares by September 2025.
Tata Sons’ board is split on the listing issue. Directors opposing the listing argue that making Tata Sons public could jeopardize the philanthropic work of the Tata Trusts in sectors like healthcare, education and scientific research.
Those in favour of a listing contend that it would improve transparency and governance, provide a market‑based valuation and ease access to capital for emerging ventures such as semiconductors, electric vehicles and aviation.
Rajat Sethi, a partner at S&R Associates, remarked, “Should the RBI refuse Tata Sons’ de‑registration, the company might need to shrink its asset base below the ₹1 lakh crore mark or embark on a major restructuring—both challenging steps considering its function as the holding company of the Tata Group.”
Published on August 6, 2026
