Amid intense speculation following the Reserve Bank of India’s (RBI) September 30 deadline for certain non-banking financial companies (NBFCs) to list, the situation surrounding Tata Sons, the holding company of the Tata Group, remains unresolved. On October 1, a day after the deadline passed, RBI Governor Sanjay Malhotra addressed the matter, stating that an entity can continue its business as long as its registration is not cancelled. This comment has been widely interpreted as an indication that the RBI is still deliberating on Tata Sons' application to avoid the listing mandate, potentially considering an extension or accepting its surrender proposal.

The RBI had classified Tata Sons as an Upper Layer NBFC (NBFC-UL) under its Scale-Based Regulation, introduced in October 2022. This classification mandated Tata Sons, alongside 14 other entities, to undertake a public listing by September 30. While most other unlisted entities on the original list have since complied, either by going public or merging with listed group companies, Tata Sons has actively resisted the directive.

To maintain its unlisted status, Tata Sons applied to surrender its Core Investment Company (CIC) registration (also referred to as its NBFC license) in August 2024. Around the same time, it reportedly repaid over ₹20,300 crore in debt. Furthermore, Tata Trusts, the umbrella entity controlling a significant portion of Tata Sons, passed a resolution on July 28, directing chairman Natarajan Chandrasekaran to ensure the holding company remains private and to engage fully with the RBI in this regard.

Governor Malhotra, while initially reluctant to comment on entity-specific matters, eventually offered his remark that "Any entity which has a registration, till it is not cancelled, will continue to do its business." This statement leaves room for interpretation, with legal experts suggesting it implies the RBI may have granted Tata Sons more time or is still weighing its options regarding the de-registration application. The RBI had previously included Tata Sons in its January 16 list of upper-layer NBFCs for FY25, noting that its inclusion was "without prejudice to the outcome of its application for de-registration, which is under examination."

A public listing for Tata Sons would impose a slew of compliance burdens, demanding more disclosures and potentially posing challenges for the highly diversified corporate grouping. However, such a move would be significantly beneficial for the Shapoorji Pallonji Group, which holds over 18 percent ownership in the conglomerate and is currently facing financial turbulence. In contrast to Tata Sons, another entity from the RBI's upper-layer NBFC list, Tata Capital, is proceeding with its initial public offering (IPO), expected to open for subscription on October 6 and list by October 13.