IBBI Updates CIRP Regulations: New Form and Fees for RP Form Filings under Rule 40B [Read Notification]

The amendment mandates strict timelines, typically on or before the 10th day of the following month and imposes a penalty of ₹500 per form for each month of delay in filing.

By Navasree A.M - On May 22, 2025 2:58 pm - 3 mins read

The Insolvency and Bankruptcy Board of India ( IBBI ) has notified the IBBI (CIRP) Regulations, i.e, Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) (Third Amendment) Regulations, 2025, through a gazette notification dated 19th May 2025.

These amended regulations, effective from 1st June 2025, revise Regulation 40B of the principal 2016 regulations by introducing a comprehensive and time-bound framework for the electronic filing of forms by interim resolution professionals (IRPs) and resolution professionals (RPs).

Also read: IBBI suspends liquidator for misconduct

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As per the revised norms, forms CP-1 to CP-5 are to be filed on IBBI’s electronic platform within specified deadlines corresponding to key stages of the Corporate Insolvency Resolution Process (CIRP). These include commencement of CIRP, constitution of Committee of Creditors (CoC), submission and approval of resolution plans, reporting avoidance transactions, and monthly progress updates.

The amendment mandates strict timelines, typically on or before the 10th day of the following month and imposes a penalty of ₹500 per form for each month of delay in filing. Moreover, IRPs and RPs are now held accountable for accuracy and completeness, with the Board empowered to initiate disciplinary action, including refusal to grant or renew Authorization for Assignment, in case of non-compliance, delay, or incorrect information in the filings.

Also read: Delhi HC reduces Suspension Period Imposed by IBBI Disciplinary Committee on Insolvency Professional

Form	Period covered and scope	To be filed by	Timeline
CP-1	From commencement of CIRP till constitution of CoC: This includes details of IRP, CD, and the Applicant, admission of application by AA (Adjudicating Authority), public announcement, details of Authorised Representatives, taking over management of the CD, receipt and verification of claims, constitution of CoC, etc.	IRP	On or before the 10th day of the subsequent month, after filing the report constitution of CoC to AA
CP-2	From constitution of CoC till issue of RFRP: This includes details of RP, details of registered valuers, details in IM, expression of interest, RFRP and modification thereof, etc.	RP	On or before the 10th day of the subsequent month, after issuance of RFRP
CP-3A	Details of resolution plan / liquidation / closure application filed with AA: This includes details of the resolution applicants, details of approval or rejection of resolution plans by CoC, details of application filed with AA for approval of resolution plan, details of initiation of liquidation (if applicable), etc.	RP	On or before the 10th day of the subsequent month, after filing application with AA
CP-3B	Approval of resolution plan / liquidation / closure by AA: This includes details of the resolution plan approved by the AA or liquidation order or closure order, etc.	RP	Within 7 days of disposal Of application by AA
CP-4	Avoidance transactions reported to AA: This includes details of the avoidance transactions (preferential, undervalued, extortionate credit, fraudulent), underlying amounts, date of reporting to AA, order of AA on the application (if any), etc.	RP	On or before the 10th day of the subsequent month, after filing of application(s) with AA or disposal of application(s) by AA
CP-5	Monthly: This includes updates on the status of CIRP, details of CoC meetings held, updates on litigations, details of expenses incurred, reasons for delay (if any), etc.	IRP/RP	On or before the 10th of every month for the preceding month.

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It has stated that :

The Board shall make available the Forms referred in sub-regulation (1) on the electronic platform and may modify them from time to time.
The interim resolution professional or resolution professional, as the case may be, shall ensure that the Forms and its enclosures filed under this regulation are accurate and complete.
The filing of a Form under this regulation after the due date of submission, whether by correction, updation or otherwise, shall be accompanied by a fee of five hundred rupees per Form for each calendar month of delay from a date to be notified through circular by the Board in this regard.
The interim resolution professional or resolution professional, as the case may be, shall be liable to any action which the Board may take as deemed fit under the Code or any regulation made thereunder, including refusal to issue or renew Authorisation for Assignment, for-

(i) failure to file a Form along with requisite information and records;

(ii) inaccurate or incomplete information or records filed in or along with a Form;

(iii) delay in filing the Form.”

Also read: Outgoing Liquidator Entitled to Minimum Fee of Rs. 2 Lakh as Per IBBI Regulations: NCLT

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