Mumbai, July 2 -- A week after raising hopes that Tata Sons could avoid a mandatory listing, the Reserve Bank of India (RBI) on Wednesday inserted a key definition that was absent in its updated guidelines, leaving the Tata Group holding company's listing fate dependent on the central bank's decision on its application to surrender its core investment company (CIC) licence. The central bank had earlier defined indirect receipt of public funds as "funds received not directly but through associates and group entities which have access to public funds" in a 29 April circular. This definition was not there in the central bank's 24 June circular-which is still on its website-but restored in a footnote on Wednesday's updated version, with effect from 1 July 2026. The definition is crucial for Tata Sons. Although the company has no direct access to public funds after repaying its debt in 2024, several listed Tata companies own stakes in it, making it an indirect recipient of public funds. Experts said that the sequence of amendments appears to be more in the nature of a drafting clarification than a substantive shift in regulatory policy. "The reintroduction of the explanation defining 'indirect access to public funds' in the 1 July circular indicates that the Reserve Bank of India intends to remove interpretational ambiguities and ensure consistent application of the upper layer NBFC framework," said Siddartha Karnani, partner at King Stubb & Kasiva, Advocates and Attorneys. He said that any ambiguity in the language can lead to inconsistent interpretation by regulated entities and market participants. "At the same time, multiple revisions to the same regulatory framework within a short period can create uncertainty for NBFCs, particularly those assessing their regulatory status and compliance obligations," said Karnani. Queries emailed to Tata Sons were not immediately answered. In 2022, RBI had released a list of so-called upper-layer non-banks, giving them three years to get listed. Many from that list, such as Tata Capital and HDB Financial Services, got listed in time. Tata Sons remains the only company in that list to still remain private. RBI has now defined the upper layer as non-banks with assets of Rs.1 trillion, although it had received feedback that it should raise the threshold to Rs.2.5 trillion. Tata Sons had standalone assets of Rs.1.7 trillion at end-March 2025. Tata Sons' listing now hinges on RBI accepting its application to surrender its core investment company registration, which the company has already submitted. A core investment company is a non-bank whose business is to acquire shares and securities, and hold at least 90% of its net assets in the form of investment in equity shares, preference shares, bonds, debentures, debt or loans in group companies. As per RBI's circular from 10 March, a core investment company can remain unregistered on two occasions. First, if it has an asset size below Rs.100 crore, irrespective of whether it is accessing public funds or not. Second, if it has an asset size of Rs.100 crore and above, but not accessing public funds....