The Reserve Bank of India (RBI) has proposed an overhaul of how “upper layer (UL)” non-banking financial companies (NBFCs) are classified, suggesting a shift to size as the defining criterion.

Although there’s no mention of any specific company-related issue, the draft proposal on upper layer NBFCs comes against the backdrop of a momentum building up for stock exchange listing of Tata Sons, the holding company of the salt-to-software conglomerate. In 2022, the RBI had mandated upper layer NBFCs, including Tata Sons, to list within three years. The deadline for listing expired in September 2025.

Under the draft proposal issued on Friday, NBFCs with assets of ₹1 trillion or more, based on their latest audited balance sheet, would be designated as “upper layer” entit

ies.