By BillCut
Last updated: 24 October 2026
The upper layer NBFC list 2026 names 19 large lenders that the Reserve Bank of India regulates more strictly. If your loan is from one of them, your interest rate, EMI and loan terms do not change because of this list. It changes how the company is governed, including a rule that it must list on a stock exchange.
The topic is in the news because on 23 October 2026, RBI Governor Sanjay Malhotra said that an entity in the upper layer is required to list, according to a Business Standard report of his remarks.
What is the upper layer of NBFCs?
Non-banking financial companies (NBFCs) are lenders that are not banks. The Reserve Bank of India sorts them into four layers based on size, activity and risk, under its Scale Based Regulation directions.
| Layer | Who sits in it |
|---|---|
| Base Layer | Non-deposit taking NBFCs with assets below Rs 1,000 crore, plus some special types |
| Middle Layer | All deposit taking NBFCs, non-deposit taking NBFCs with assets of Rs 1,000 crore or more, and types such as housing finance companies |
| Upper Layer | NBFCs specifically identified every year by the Reserve Bank of India as needing stricter rules |
| Top Layer | Meant to stay empty, used only if an upper layer NBFC’s systemic risk rises sharply |
Under the same directions, as amended in June 2026, the upper layer consists of NBFCs with an asset size of Rs 1,00,000 crore and above. Once a company is placed in the upper layer, the stricter rules apply for at least five years, even if it later falls below the criteria.
Which lenders are on the upper layer NBFC list 2026 ₹
The Reserve Bank of India published the list of upper layer NBFCs for 2026-27 on 6 August 2026, based on financials as on 31 March 2026. It has 17 names identified under this year’s criteria, plus two that continue from the 2024-25 list.
| NBFC | Category as listed by the RBI |
|---|---|
| REC Limited | Infrastructure finance company |
| Power Finance Corporation Limited | Infrastructure finance company |
| Indian Railway Finance Corporation Limited | Infrastructure finance company |
| Bajaj Finance Limited | Deposit taking investment and credit company |
| Shriram Finance Limited | Deposit taking investment and credit company |
| LIC Housing Finance Limited | Deposit taking housing finance company |
| Cholamandalam Investment and Finance Company Limited | Non-deposit taking investment and credit company |
| Tata Capital Limited | Non-deposit taking investment and credit company |
| Tata Sons Private Limited | Core investment company |
| Muthoot Finance Limited | Non-deposit taking investment and credit company |
| Aditya Birla Capital Limited | Non-deposit taking investment and credit company |
| Housing and Urban Development Corporation Limited | Infrastructure finance company |
| Mahindra & Mahindra Financial Services Limited | Deposit taking investment and credit company |
| L&T Finance Limited | Non-deposit taking investment and credit company |
| Bajaj Housing Finance Limited | Non-deposit taking housing finance company |
| HDB Financial Services Limited | Non-deposit taking investment and credit company |
| Piramal Finance Limited | Non-deposit taking investment and credit company |
| PNB Housing Finance Limited | Deposit taking housing finance company, continuing from 2024-25 |
| Sammaan Capital Limited | Non-deposit taking investment and credit company, continuing from 2024-25 |
The RBI notes that Tata Sons is included without prejudice to the outcome of its pending application for de-registration. Being on this list is about size and regulation. It is not a rating of whether a lender is better, safer or riskier for you.
Why must upper layer NBFCs list on a stock exchange?
The Reserve Bank of India’s NBFC governance directions say an upper layer NBFC must be listed within three years of being identified in the upper layer. Until then, it must follow disclosure rules on the same lines as a listed company. Since June 2026, this does not apply to upper layer NBFCs fully owned and controlled by the government.
The same directions also require a board with the right mix of qualifications and experience, and a report to the RBI if an independent director leaves early. These rules are about how the company is run, not about your loan.
Does the upper layer NBFC list change your loan?
No. Your loan carries on under the terms you signed.
| What changes | What does not change for you |
|---|---|
| Stricter governance and board rules for the lender | Your interest rate and EMI |
| Mandatory listing within three years of identification | Your tenure, charges and repayment schedule |
| Disclosures on the same lines as a listed company | Your rights as a borrower, which are the same at any NBFC |
| Stricter rules last at least five years | The prepayment and foreclosure terms in your loan documents |
What rights do you have with any NBFC?
Whether your lender is in the base, middle or upper layer, the same core protections apply. The Reserve Bank of India’s Fair Practices Code for NBFCs says:
- Your sanctioned amount, terms and annualised interest rate must be given to you in writing, in a language you understand.
- Changes in interest rates and charges can only apply prospectively.
- Recovery agents must not harass you, including by bothering you at odd hours.
- Securities must be released once all dues are repaid, unless the lender has a legitimate lien or claim.
The RBI’s pre-payment charges directions also say lenders, including NBFCs, cannot charge a pre-payment fee on floating rate loans taken by individuals for non-business purposes. This applies to loans sanctioned or renewed on or after 1 January 2026. Fixed rate loans and older loans follow the terms in your agreement, so read the charges before you prepay. BillCut explains the trade-offs in early loan prepayment, pros, cons and charges.
Since your existing terms stay the same, a loan that was expensive before this news is still expensive now. If you are paying a high rate on an NBFC personal loan or carrying card dues alongside it, refinancing into one lower cost EMI may help, but only if the total cost after fees is lower. Check your options with BillCut.
What should you do if your lender is on the upper layer NBFC list?
- Keep paying your EMIs on time. Nothing in the list changes your due dates.
- Find your sanction letter and loan agreement and note your rate, whether it is fixed or floating, and the prepayment terms.
- Verify any message claiming your terms changed because of the RBI list through your lender’s official app or branch.
- If your rate feels high, ask your lender for a lower rate, and read what to do when your personal loan interest is too high.
- If a complaint is not resolved by the lender, you can escalate it. See BillCut’s guide to filing an RBI ombudsman complaint.
How BillCut can help
BillCut is a balance transfer and debt reduction platform. It works with lending partners to help eligible borrowers move high interest dues, such as credit card balances and personal loan EMIs, into one structured EMI. BillCut earns from helping borrowers refinance, so it has an interest in this option. Approval and terms depend on the partner lender, and a switch only makes sense if the total cost after fees is lower.
Frequently asked questions
What is the upper layer NBFC list?
It is a yearly list from the Reserve Bank of India of large NBFCs that must follow stricter regulation. The 2026-27 list has 19 names.
Which NBFCs are in the upper layer in 2026 ₹
It includes Bajaj Finance, Shriram Finance, Tata Capital, Muthoot Finance, LIC Housing Finance, HDB Financial Services and others, 19 names in all. The full list is in the RBI press release of 6 August 2026.
Will my EMI change if my lender is an upper layer NBFC?
No. The classification changes how the company is regulated, not the rate, EMI or terms of your existing loan.
Is an upper layer NBFC safer than other NBFCs?
The list is based on size and the need for stricter rules. It is not a rating, so it does not tell you whether one lender is safer or riskier than another.
Do upper layer NBFCs have to list on the stock market?
Yes. RBI rules say an upper layer NBFC must be listed within three years of being identified, except those fully owned and controlled by the government.
Are my rights different with an upper layer NBFC?
No. Protections such as the Fair Practices Code and the pre-payment charge rules apply to NBFCs in every layer.
Can I prepay a loan from an upper layer NBFC?
Usually, yes. Floating rate loans taken by individuals for non-business purposes and sanctioned or renewed on or after 1 January 2026 carry no pre-payment charge, while other loans follow your agreement.
This article is for general information only and is not financial advice. Rules and lender policies change. Check your loan documents and speak to your lender or a qualified professional before making decisions.
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