Infrastructure Debt Fund-NBFCs under Upper Layer regulation to follow the large exposure limits of NBFC-IFCs: RBI amends concentration risk Directions
RBI has inserted paragraph 39A in its concentration risk Directions for NBFCs. The large exposure limits that apply to Infrastructure Finance Companies (NBFC-IFC) now also apply to Infrastructure Debt Fund-NBFCs (IDF-NBFC) that are subject to Upper Layer regulations. The amendment is dated 25 August 2026 and is in force with immediate effect.
Key facts
- Published
- 25 August 2026
- Section
- FEMA & RBI
- What it is
- Rule change
- In force
- In force with immediate effect from 25 August 2026
- Who it affects
- Infrastructure Debt Fund-NBFCs that are subject to Upper Layer regulations, their sponsors, and borrowers in the infrastructure sector
In 30 seconds
- The amendment is the Reserve Bank of India (Non-Banking Financial Companies – Concentration Risk Management) Fourth Amendment Directions, 2026, RBI/2026-27/237, dated 25 August 2026.
- It inserts a new paragraph 39A in Chapter IV — Guidelines Applicable to NBFC – Upper Layer — of the 2025 Directions.
- IDF-NBFCs subject to Upper Layer regulations get the same large exposure limits as NBFC-IFCs.
- The amendment came into force with immediate effect.
- The limits themselves are not reproduced in the amendment.
हिंदी में सार
RBI ने 25 अगस्त 2026 को NBFC Concentration Risk Management Directions, 2025 में नया पैरा 39A जोड़ा है। अब जो Infrastructure Debt Fund-NBFC (IDF-NBFC) Upper Layer के नियमों के अधीन हैं, उन पर वही large exposure limits लागू होंगी जो NBFC-IFC पर लागू हैं। संशोधन तुरंत प्रभाव से लागू है; सीमाएँ संशोधन में दोबारा नहीं लिखी गई हैं।
What RBI has changed
By the Reserve Bank of India (Non-Banking Financial Companies – Concentration Risk Management) Fourth Amendment Directions, 2026, dated 25 August 2026 (RBI/2026-27/237), the Reserve Bank has revised the large exposure framework for Infrastructure Debt Fund-Non-Banking Financial Companies (IDF-NBFC) in the Upper Layer.
The amendment modifies the Reserve Bank of India (Non-Banking Financial Companies – Concentration Risk Management) Directions, 2025, dated 28 November 2025. It makes a single change: a new paragraph 39A is inserted after paragraph 39 in Chapter IV, which carries the guidelines applicable to NBFCs in the Upper Layer.
What paragraph 39A says
The large exposure limits applicable to NBFC-IFC shall also be applicable to IDF-NBFCs that are subject to Upper Layer regulations in terms of paragraph 60A of the Reserve Bank of India (Non-Banking Financial Companies – Undertaking of Financial Services) Directions, 2025, read together with paragraph 18(4)(i) of the Reserve Bank of India (Commercial Banks – Undertaking of Financial Services) Directions, 2025.
| Point | Detail |
|---|---|
| Directions amended | NBFC Concentration Risk Management Directions, 2025 (28 November 2025) |
| Change | New paragraph 39A in Chapter IV |
| Who is covered | IDF-NBFCs that are subject to Upper Layer regulations under the two paragraphs cited |
| Limits that apply | The large exposure limits applicable to NBFC-IFC |
| In force | With immediate effect — 25 August 2026 |
| Issued under | Chapter III B of the Reserve Bank of India Act, 1934 |
What the amendment does not spell out
The amendment does not reproduce the large exposure limits; it points to the limits already applicable to NBFC-IFCs in the principal Directions. It also does not name any IDF-NBFC. Whether a particular IDF-NBFC is covered depends on whether it is subject to Upper Layer regulations under the paragraphs cited above. The amendment itself contains no transition period.
What IDF-NBFCs should do
An IDF-NBFC should first confirm whether it is subject to Upper Layer regulations under paragraph 60A of the NBFC Undertaking of Financial Services Directions, 2025. If it is, its exposures are to be measured against the large exposure limits that apply to NBFC-IFCs, from 25 August 2026.
Questions and answers
What has RBI changed for IDF-NBFCs?
A new paragraph 39A has been inserted in the NBFC Concentration Risk Management Directions, 2025. It says the large exposure limits applicable to NBFC-IFC shall also apply to IDF-NBFCs that are subject to Upper Layer regulations.
From when does it apply?
The Amendment Directions are dated 25 August 2026 and came into force with immediate effect.
Does it apply to every IDF-NBFC?
No. It applies to IDF-NBFCs that are subject to Upper Layer regulations in terms of paragraph 60A of the NBFC Undertaking of Financial Services Directions, 2025 read with paragraph 18(4)(i) of the Commercial Banks Undertaking of Financial Services Directions, 2025.
What are the limits?
The amendment does not restate them. It applies the large exposure limits already applicable to NBFC-IFCs under the principal Directions.
Published 25 August 2026. Updated 4 October 2026. This report is for general information and is not professional advice. Read the source document before acting on it.