Under RBI’s scale-based regulatory framework for NBFCs, an NBFC–Peer-to-Peer Lending platform (NBFC-P2

• RBI has introduced a Scale-Based Regulatory (SBR) Framework for NBFCs, classifying them into four layersbased on size, activity, and perceived riskiness: o Base Layer (NBFC-BL): Smallest and least risky NBFCs, including NBFC-P2P, NBFC-AA, and NBFCs with asset size below ₹1,000 crore. o Middle Layer (NBFC-ML): Larger NBFCs carrying moderate systemic risk (like deposit-taking NBFCs, HFCs, IFCs, IDFs). o Upper Layer (NBFC-UL): Top 10–15 NBFCs identified by RBI based on size, interconnectedness, and risk. o Top Layer (NBFC-TL): Ideally empty; reserved for NBFCs that may pose extreme risk in future. • NBFC-P2P platforms are explicitly categorized under the Base Layer and cannot migrate to higher layers regardless of size.