Proxy advisory firm InGovern Research Services has urged the Reserve Bank of India (RBI) to reject Tata Sons' March 2024 application to surrender its Certificate of Registration as a Systemically Important Core Investment Company. According to reports from The Hindu BusinessLine, the proxy-adviser's three-point prescription includes a public rejection of the deregistration bid, a mandatory listing directive, and immediate adoption of a ₹1 lakh crore asset threshold for Upper Layer classification. The firm emphasized that the RBI must issue a definitive, public order rejecting the March 2024 application for de-registration of Tata Sons.
Recent developments have significantly strengthened InGovern's position, with the RBI's April 2026 amendment directions and April 29 clarification undercutting Tata Sons' attempt to distance itself from public funds. As reported by Mint, the central bank's clarification stated that due to leverage, multiple layers, and fungibility of money, it was difficult to establish with reasonable assurance whether equity infusions by group entities were from their own funds. This position undermines Tata Sons' standalone deleveraging defence and reinforces the company's systemic importance, with experts confirming that the holding company would be deemed to have indirect access to public funds and therefore ineligible to surrender the licence.
According to InGovern reports, Tata Sons' cross-holdings — roughly 13-14% held by listed Tata group companies such as Tata Steel, Tata Motors and Tata Power — created a permanent 'look-through' link to public funds. The firm contrasted Tata Sons' approach with precedents such as L&T Finance, Piramal and Tata Motors Finance, where entities either merged into listed vehicles or restructured to comply with SBR norms before deregistration was accepted. Mint reports that the RBI's cancellations of NBFC licences of companies such as Piramal Enterprises in December 2025 and Tata Motors Finance in October 2025 show the regulator only accepts surrenders in cases of corporate dissolution or merger into compliant, listed frameworks.
InGovern has called for a clear directive to Tata Sons to begin the listing process as an upper-layer NBFC in accordance with the RBI's latest master directions. The proxy-adviser noted that transitioning to a listed entity would trigger the Securities and Exchange Board of India's (Sebi's) disclosure norms, which are vital for transparent governance of related-party transactions. According to Mint, the holding company managing ₹1.75 trillion in assets — including giants such as TCS, Tata Motors, and Tata Power — would be subject to these mandatory disclosures. In 2022, RBI had released a list of upper-layer non-banks with three years to get listed, and Tata Sons remains the only company on that list to remain private.
