IBBI Mandates Disclosure of Beneficial Ownership in Resolution Plan through Seventh Amendment to CIRP Regulations [Read Notification]
As per the newly inserted sub-regulation (3A) under Regulation 38, resolution applicants are required to furnish a structured disclosure of all natural persons who ultimately own or control the applicant entity.
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An important compliance requirement for resolution applicants by a recent notification has been introduced by the Insolvency and Bankruptcy Board of Indiain the Seventh Amendment to the Insolvency Resolution Process for Corporate Persons Regulations, 2016.
Every resolution plan submitted under theCorporate Insolvency Resolution Process (CIRP) has to include an elaborated statement of beneficial ownership and an affidavit to show eligibility under Section 32A of the Insolvency and Bankruptcy Code, 2016 from 22 December 2025’
As per the newly inserted sub-regulation (3A) under Regulation 38, resolution applicants are required to furnish a structured disclosure of all natural persons who ultimately own or control the applicant entity.
This includes the shareholding structure and jurisdictional details of each intermediate entity in the ownership chain. The format for this disclosure will be specified by the Board through a circular.
Additionally, the resolution applicants are to submit an affidavit confirming whether they are eligible for the benefit under Section 32A. The affidavit must follow a format prescribed by the Board.
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The Seventh Amendment follows the Sixth Amendment notified in October 2025 and continues the Board’s trend of tightening procedural safeguards under the CIRP framework. The notification was published in the Gazette of India, Extraordinary, Part III, Section 4, and comes into force from the date of publication.


