SEBI’s new consultation paper dated 27 October,2025, proposes to raise the High Value Debt Listed Entity (HVDLE) threshold from ₹1,000 crore to ₹5,000 crore marking a significant recalibration of India’s debt-market governance framework. Framed as a step toward ease of doing business, the proposal would exclude nearly 64% of existing HVDLEs from enhanced governance norms. This piece argues that repeated reliance on a purely quantitative trigger risks regulatory arbitrariness and uneven treatment of similarly situated issuers. Drawing comparative lessons from the U.S. Securities and Exchange Commission and the Monetary Authority of Singapore, it proposes a composite, risk-based framework that integrates quantitative and qualitative criteria to better align regulatory intensity with systemic risk, investor protection, and market stability.