The renewal of the Authorisation for Assignment (AFA) is a critical requirement for Insolvency Professionals (IPs) to continue accepting and undertaking assignments under the Insolvency and Bankruptcy Code (IBC). With the amendments to the IIIPI Byelaws effective from January 29, 2025, the AFA renewal framework has been streamlined, introducing fixed renewal cycles and greater predictability. However, these changes also place greater responsibility on members to apply well in advance and maintain ongoing regulatory compliance.
Revised AFA Validity Cycle: Two Common Expiry Dates
Pursuant to Clause 12A of the IIIPI Byelaws, in accordance with the amended IBBI Regulations, the validity of all AFAs is now aligned with only two common expiry dates: 30 June or 31 December. This uniformity has simplified administration and created a structured renewal mechanism across the insolvency profession.
To facilitate timely renewals, members may submit their AFA renewal applications 90 days prior to the applicable expiry date. Accordingly, for AFAs expiring on 31 December 2026, the application window opens on 1 October 2026.
Processing Timeline and Its Practical Implications
The revised framework also provides IIIPI with a period of 90 days from the date of application to process renewal requests. While this timeline helps ensure thorough scrutiny and verification of compliance requirements, it also underscores the importance of early application by members.
The significance of timely renewal becomes even more pronounced when viewed alongside the half-yearly empanelment process for the NCLT Panel, where application deadlines generally fall during the last week of June or December. A delay in obtaining a renewed AFA may inadvertently affect a member’s eligibility to apply for or continue on the NCLT panel.
Lessons from the Previous Renewal Cycle
During the AFA renewal cycle ending 31 December 2025, a substantial number of renewal applications were submitted very close to the expiry date. This resulted in operational challenges in processing and approving applications before AFA maturity date; and The deadlines associated with NCLT empanelment.
Such last-minute filings can lead to avoidable delays, increased correspondence, and uncertainty regarding eligibility for assignments and panel appointments.
Why Members Should Apply Between 1 October and 10 October 2026
To avoid bottlenecks and ensure smooth processing, members whose AFAs are expiring on 31 December 2026 are strongly encouraged to submit their renewal applications within the first 7 to 10 days of the application window, preferably between:
1 October 2026 and 10 October 2026
Early submission offers several advantages:
- Adequate Processing Time: IIIPI receives sufficient time to verify compliances and process applications.
- Reduced Risk of Delays: Any deficiencies, clarification requests, or document-related issues can be addressed well before the expiry date.
- Timely NCLT Empanelment: Members can renew their AFA and participate in the NCLT empanelment process without uncertainty.
- Business Continuity: Ensures uninterrupted eligibility to accept assignments under the IBC framework.
Members should note that applications filed significantly after the recommended period may result in processing extending beyond the expected or required timelines.
Compliance Readiness: Key Checks Before Applying for AFA Renewal
One of the primary reasons for delays in AFA processing is the need for repeated correspondence arising from incomplete compliances. Since compliance status is assessed as on the date of application, members should ensure they meet all regulatory requirements before submitting their renewal request. The following indicative checklist may assist members: Eligibility Requirements
- The member is not in employment.
- Member has not attained the age of 70 years.
- The member has completed the minimum Continuing Professional Education (CPE) hours required up to the previous calendar year as prescribed under the IBBI CPE Guidelines.
It is advisable that members also complete the CPE requirements for the current calendar year well before 31 December 2026, as these will be examined in the subsequent renewal cycle.
- Regulatory Compliance Requirements
- Members should ensure compliance regarding:
A. Statutory Fees and Filings
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- Payment of dues payable to IIIPI and IBBI.
- Filing of applicable forms, including:
- Form E
- Form EA
- Form G
- Form H
- Relevant IPE compliance filings
B. Assignment-Related Filings and Disclosures
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- Completion of all disclosures and filings required under applicable regulations, circulars, and directions issued by IBBI and IIIPI.
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- Verification of completeness and correctness of compliance forms relating to:
- Corporate Insolvency Resolution Process (CIRP)
- Liquidation
- Voluntary Liquidation (VL)
- Personal Guarantor to Corporate Debtor (PG to CD) assignments
C. Important IBBI Circulars to Review
- Members should verify compliance with requirements specified in important circulars, including:
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- 6 March 2026 Circular on PG to CD compliance forms, as amended on 9 July 2026.
- 26 May 2025 Circular relating to CIRP compliance forms.
- 28 June 2024 Circular on Liquidation compliance forms, revised on 5 January 2026.
- 28 June 2024 Circular on Voluntary Liquidation compliance forms.
- 12 June 2018 Circular on disclosure of fees and costs during CIRP.
D. Relevant FAQs Issued by IBBI
- Members should also review the FAQs issued by IBBI for practical guidance, including:
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- 26 May 2025 FAQs on CIRP compliance forms.
- 10 January 2025 FAQs on Liquidation and Voluntary Liquidation compliance forms.
- 6 March 2026 FAQs on PG to CD compliance forms, subsequently amended on 8 June 2026.
Conclusion
- The revised AFA renewal framework aims to bring uniformity, transparency, and efficiency to the authorisation process. However, its success depends significantly on proactive participation by members.
- For AFAs expiring on 31 December 2026, members should treat 1 October 2026 as the effective start of their renewal exercise and ideally complete the application process by 10 October 2026. Equally important is ensuring that all regulatory filings, disclosures, fee payments, and CPE obligations have been fulfilled before applying.
- Timely action today can prevent procedural delays tomorrow, safeguard eligibility for assignments, and facilitate seamless participation in the forthcoming NCLT empanelment cycle. Early compliance is not merely an administrative convenience; it is an essential professional responsibility for every Insolvency Professional.