The Reserve Bank of India (RBI) has proposed new guidelines that classify non-banking financial companies (NBFCs) with assets exceeding ₹1 trillion (approximately $12 billion USD) into an upper regulatory layer. This move could significantly impact Tata Sons, which reported total assets of ₹1.75 trillion as of March 2025 and has been categorized as an upper layer NBFC since the initial list was released in September 2022. The new draft circular, released on April 10, reduces RBI's discretion in determining which companies belong to this upper layer, potentially leaving Tata Sons with limited options unless it receives exemptions. The company has expressed intentions to deregister as a core investment company (CIC) to sidestep the listing requirements and tighter oversight that accompany this classification. The RBI has the authority to grant exemptions on a case-by-case basis, which could be crucial for Tata Sons' operational flexibility. Industry experts note that while Tata Sons has made structural changes to its liabilities, including giving up access to public funds, it remains under the upper layer classification unless specifically exempted by the RBI.