The RBI's April 2026 framework effectively set a ₹1 lakh crore asset threshold for Upper Layer NBFC classification, making Tata Sons' inclusion automatic and non-discretionary — and mandatory listing within three years, placing Tata Sons on a clear compliance path toward a March 2027 deadline. A report by Corporate governance advisory firm InGovern Research Services urged the Reserve Bank of India to direct Tata Sons to initiate a public listing by March 2027 as an Upper Layer NBFC under the revised Scale-Based Regulatory (SBR) framework. The report argued that Tata Sons’ 2024 application to surrender its registration as a systemically important Core Investment Company (CIC) to avoid mandatory listing has become untenable due to the evolving 2026 regulatory framework and RBI clarifications on indirect public funds and leverage. 

InGovern contended that Tata Sons, which controls assets of around ₹1.75 lakh crore and major listed companies such as Tata Consultancy Services, Tata Motors, and Tata Power, should remain subject to stricter governance and disclosure norms under SEBI’s listing regulations to ensure transparency in related-party transactions and capital allocation. The advisory firm also called for RBI to formally reject Tata Sons’ deregistration request, apply the proposed ₹1 lakh crore asset threshold for automatic Upper Layer classification, and close perceived regulatory loopholes to preserve the credibility and integrity of India’s financial regulatory framework.

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