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RBI Upper Layer NBFC Norms: Rs.1 Lakh Crore Asset Test

27 June 20262 min read
BANKING & FINANCERBI Upper LayerNBFC Norms: Rs.1Lakh Crore AssetTest27 June 2026safalsetu.com

Why in the news

The central bank issued final, revised norms that replace the old scoring approach with one simple size test for the top tier of non-bank lenders. The change makes a public listing of Tata Sons hard to avoid.

Key facts

  • Issued: 24 June 2026, effective immediately, under Sections 45-IA, 45JA, 45L and 45M of the RBI Act, 1934.
  • NBFC-UL test: asset size of Rs.1 lakh crore or above; replaces multi-parameter scoring.
  • Industry ask of Rs.2.5 lakh crore was rejected; RBI calls asset size a reasonably good proxy for systemic significance.
  • Review of the threshold every 3 years; identification is annual.

What changes

AreaNew position
ListingMandatory within 3 years of becoming NBFC-UL
Government-owned NBFCsExempt from listing because of developmental mandate
Concentration-risk relief for government NBFCsWithdrawn; they now face the same exposure rules as private NBFCs
Bank-owned NBFCsFollow commercial bank norms for same activities; keep SBR layer classification, curbing regulatory arbitrage
NBFC-IFC large exposure limitCeiling lifted from 35% to 45% of eligible capital
OversightCloser checks on CET-1 capital, liquidity coverage, exposures, stress testing and disclosure

Scale-Based Regulation (SBR)

  • Risk-based four-layer framework, issued 22 October 2021 and effective 1 October 2022; it sets capital, governance, prudential, large exposure and disclosure standards by size, activity and systemic importance.
LayerCriteria
Base (NBFC-BL)Assets below Rs.1,000 crore; non-deposit, non-systemic
Middle (NBFC-ML)Assets Rs.1,000 crore or more, or deposit-taking, or systemic
Upper (NBFC-UL)Assets Rs.1 lakh crore or more (June 2026 norm)
Top (NBFC-TL)At RBI’s discretion; currently empty

About NBFCs and the RBI Act

  • An NBFC is a company registered under the Companies Act that lends, invests, leases and so on but holds no banking licence; it cannot take demand deposits, is outside the payment system and has no deposit insurance. Around 9,500 are registered.
  • Chapter III-B of the RBI Act governs NBFCs: 45-I defines NBFC; 45-IA sets registration and Net Owned Funds; 45-IB liquid assets; 45-IC reserve fund of 20% of net profit; 45-JA policy powers; 45-L information and directions; 45-M statements.

Core Investment Companies and Tata Sons

  • A CIC is an NBFC holding at least 90% of net assets in group company securities or loans, minimum asset size Rs.100 crore, under the Master Direction on CICs, 2016. Examples: Tata Sons, Bajaj Holdings, L&T Holdings.
  • Tata Sons: CIC with standalone assets of about Rs.1.75-1.9 lakh crore; first named NBFC-UL in September 2022; missed the 30 September 2025 listing deadline; deregistration plea of 2024 pending after repaying over Rs.20,000 crore debt; the only unlisted name on the earlier UL list.

Sector snapshot

MetricValue
NBFCs registeredAbout 9,500
Sector assetsAbout Rs.47 lakh crore
Share of total creditAbout 12.5%
CRARAbout 26% (15% required)
GNPAAbout 3.0%
NBFC-UL list15 entities

Key terms

  • CET-1: top-quality capital; 9% requirement for NBFC-UL.
  • CRAR: minimum 15% for NBFCs.
  • LCR: high-quality liquid assets against 30-day net outflows; 100% target for NBFC-UL.
  • LEF: cap on exposure to one counterparty or group.

Exam angle

  • Threshold: Rs.1 lakh crore; reviewed every 3 years.
  • Top Layer is empty; listing deadline 3 years.
  • LEF for NBFC-IFC: 35% to 45%.

Test yourself

1. Under RBI's revised June 2026 norms, what asset size qualifies an NBFC as Upper Layer?

The single test is assets of Rs.1 lakh crore or more.

2. How long do identified NBFC-ULs have to list, under the revised RBI norms?

Listing is mandatory within 3 years of identification.

3. Under RBI's revised norms, the Large Exposure Framework limit for upper layer NBFC-IFCs changed to:

The LEF limit for NBFC-IFCs was raised from 35% to 45%.