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TAX & POLICY2 MIN READ

RBI governor says upper-layer NBFCs must list and CICs using public funds must register, citing Tata Sons

Sanjay Malhotra did not comment on individual firms but named Tata Sons as a CIC that must register. The RBI turned down its request to surrender registration on 11 September.

By Spectate Media desk
Spectate Media graphic: Tata Sons total assets compared with the RBI upper-layer NBFC threshold

Reserve Bank of India Governor Sanjay Malhotra said on Friday, 23 October 2026, that upper-layer non-banking finance companies must list on stock exchanges and that core investment companies (CICs) with direct or indirect access to public funds must register with the RBI. He was speaking at the NDTV World Summit in New Delhi, Business Standard reported. Spectate Media has not seen a transcript.

What the governor said

Malhotra said that "if it is in the upper layer, then it is required to list", as quoted by Business Standard. CICs with no direct or indirect access to public funds can be exempted from registration. He said he does not answer questions on specific regulated entities, but cited Tata Sons as an example of a CIC that must register because of systemic risk.

Where Tata Sons stands

The RBI placed Tata Sons in the upper layer in September 2022, with a listing deadline of September 2025, according to LiveLaw. UNI reported on 15 September that Tata Sons had applied in March 2024 to surrender its CIC registration and that the RBI declined on 11 September. UNI gave the reason as asset size: the RBI's revised upper-layer threshold of ₹1 lakh crore, set in June 2026, against about ₹2.01 lakh crore in assets for Tata Sons. UNI also reported that the RBI had filed a caveat in the Bombay High Court so it could be heard before any order if someone petitions. No petitioner was named, and Spectate Media found no report that Tata Sons has filed one.

Business Standard says Tata Sons repaid its debt before seeking to surrender registration. Tata Trusts has proposed merging Tata Electronics Systems Solutions and Tata Consulting Engineers into Tata Sons to change its business mix so it no longer qualifies as an NBFC or CIC. The plan needs approval from the Tata Sons board and an RBI no-objection.

Key numbers

  • Upper-layer threshold: ₹1 lakh crore (RBI revised, June 2026)
  • Tata Sons assets: About ₹2.01 lakh crore (Per UNI, 15 September)
  • Request declined: 11 September (Surrender of CIC registration)
  • Listing deadline: September 2025 (Set in September 2022)

What boards and CFOs should note

Three points stand out. First, the test the governor described turns on the upper layer and on access to public funds, not on a group's own preference. Second, the restructuring proposal is still pending approvals. Third, no listing has been announced, and the RBI position was last tested in court only through a caveat.

Source: Business Standard, 23 October 2026. This is a summary of a news report, published as general information. It is not legal, tax or investment advice.

This article is journalism and commentary. It is not a recommendation to buy or sell any security, and it is not professional advice. Read the full disclaimer.

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