It’s simply any class that’s not a nested class. If your file is Foo.java, and your class is Foo, then it’s a top level class.
// in Foo.java:
public class Foo { // top level class
public static class NestedBar { // nested class
}
}
I had always thought this was an informal term, but it turns out it’s actually defined in the JLS:
A top level class is a class that is not a nested class.
A nested class is any class whose declaration occurs within the body of another class or interface.