IBBI Mandates Digital Filing of CIRP Forms Under Third Amendment Effective June 1 [Read Notification]
IBBI mandates digital filing of CIRP forms with defined timelines and penalties under the Third Amendment Regulations, effective June 1, 2025
IBBI – Digital Filing of CIRP Forms – Digital Filing – taxscan
IBBI – Digital Filing of CIRP Forms – Digital Filing – taxscan
The Insolvency and Bankruptcy Board of India (IBBI) has notified the 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 amendments, which come into effect from June 1, 2025, huge reform in the compliance framework for the Corporate Insolvency Resolution Process (CIRP) by mandating the structured and digital filing of specified forms on the IBBI's electronic platform.
Objective of the Amendment
The primary aim of this amendment is to improve transparency, consistency, and timeliness in reporting key developments during the CIRP. It holds Insolvency Professionals (IPs) accountable for the accurate and timely submission of information and enables the IBBI to monitor and assess the resolution process more effectively.
Key Highlights of the Amendment
1. Substitution of Regulation 40B
The amendment substitutes the existing Regulation 40B with a detailed provision that prescribes the filing of six specific forms by the Interim Resolution Professional (IRP) or the Resolution Professional (RP) at different stages of the CIRP.
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Overview of Mandatory Forms and Filing Timelines
| Form | Coverage Period & Details | To be Filed by | Deadline |
| CP-1 | From the start of CIRP to the constitution of the Committee of Creditors (CoC). Includes details such as IRP appointment, public announcement, claim verification, CoC formation, etc. | IRP | 10th of the following month after filing the CoC constitution report with AA |
| CP-2 | From CoC constitution to the issue of Request for Resolution Plan (RFRP). Covers RP details, valuation, Information Memorandum (IM), Expression of Interest (EoI), RFRP, etc. | RP | 10th of the following month after issuance of RFRP |
| CP-3A | Filing of resolution plan/liquidation/closure application with Adjudicating Authority (AA). | RP | 10th of the following month after such filing with AA |
| CP-3B | Approval of the resolution plan/liquidation/closure by the AA. | RP | Within 7 days of disposal by AA |
| CP-4 | Reporting of avoidance transactions (preferential, undervalued, fraudulent, etc.) to the AA. | RP | 10th of the month following the filing/disposal by AA |
| CP-5 | Monthly report on CIRP progress, including CoC meetings, expenses, litigation, and reasons for delay. | IRP / RP | 10th day of every month for the preceding month |
Key Compliance Provisions
Digital Filing Mandate
All forms are to be filed only through the electronic platform provided by the IBBI. The Board will provide access to these forms and reserves the right to update them periodically.
Accuracy and Completeness
The IRP/RP must ensure all forms and accompanying documents are complete and accurate. Inaccurate or incomplete submissions will be treated as non-compliance.
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Late Fee Provision
A late fee of Rs. 500 per form per calendar month will be imposed for any delay in filing, effective from a date to be notified separately by the Board.
Disciplinary Action
Non-compliance may lead to actions including, but not limited to:
- Refusal to issue or renew Authorisation for Assignment (AFA)
- Action under relevant provisions of the Insolvency and Bankruptcy Code (IBC), 2016
Grounds for action include:
- Failure to file forms
- Filing inaccurate or incomplete information
- Delay in submission
Implications for Stakeholders
This amendment provides a structured, trackable method for reporting the status and progress of CIRP, thereby improving regulatory oversight and aiding efficient resolution of stressed assets. For creditors, adjudicating authorities, and market participants, this digital regime enhances transparency and ensures more accountable resolution timelines.
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