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The Insolvency and Bankruptcy Board of India (IBBI) has issued a series of important circulars in September 2026 that significantly impact insolvency professionals, lenders, liquidators, and personal guarantors. While one compliance deadline has been extended, another has become more stringent with the introduction of late filing fees. At the same time, landmark legal clarifications have reshaped the position of personal guarantors, and enhanced scrutiny has been mandated to prevent misuse of the IBC framework. Let’s decode the practical implications of Circulars 105, 106, 107, and 108.
Three major developments now define the regulatory landscape PGIRP filing deadline extended to 31 December 2026, Late fee introduced for delayed liquidation forms, Interim moratorium no longer protects personal guarantors to corporate debtors and Stricter due diligence required to identify misuse of the IBC process.
The IBBI’s September 2026 circulars bring a mixed compliance message: more time for PGIRP filings, stricter penalties for liquidation reporting, withdrawal of interim moratorium protection for personal guarantors, and enhanced scrutiny of potential misuse of the IBC framework. For Insolvency Professionals (IPs), liquidators, lenders, and personal guarantors, these changes require immediate attention.
For Insolvency Professionals (IPs), these changes require immediate review of ongoing assignments and compliance calendars.
Circular IBBI/II/106/2026 : Date: 21 September 2026 One of the most significant developments stems from the Insolvency and Bankruptcy Code (Amendment) Act, 2026, which inserted sub-sections (4) into Sections 96 and 124 of the IBC. With effect from 26 May 2026, the interim moratorium under Sections 96 and 124 no longer applies to personal guarantors of corporate debtors. This means that merely filing an application under Section 95 no longer prevents creditors from pursuing recovery actions against personal guarantors.
For professionals handling personal guarantor insolvency matters: Immediate Actions
Many creditors may have delayed recovery actions assuming the interim moratorium remained operative. This circular clarifies that such protection ceased from 26 May 2026 itself.
Circular IBBI/II/108/2026 ; Date: 24 September 2026 : The IBBI has granted further relief regarding electronic filing of Personal Guarantor Insolvency Resolution Process forms. Timeline of Extensions
What This Means
IBBI Circular IBBI/LIQ/107/2026: Date: 24 September 2026 While PGIRP filings received an extension, liquidation filings did not. Instead, the Board has activated the late filing fee mechanism under Regulation 47B of the Liquidation Process Regulations. The following are the new fee structures mentioned below:
| Particulars | Details |
| Late Filing Fee | INR 500 + GST per month |
| Applicable On | Delayed filing, correction, updation |
| Applies To | Forms due on or before 30 September 2026 |
| Effective Status | Already in force |
Every liquidation form filed late, Corrected after the due date, and Updated after the due date, will attract a fee of INR 500 plus applicable GST for each month of delay. Liquidators should review all pending filings immediately, Clear backlog submissions without delay, Budget for inevitable corrections and Maintain a filing tracker to avoid recurring costs. Unlike PGIRP compliance, there is no extension available here. Every additional month increases the compliance cost.
Circular IBBI/CIRP/105/2026 : Date: 9 September 2026 : IBBI has expressed concern that insolvency proceedings may occasionally be used for purposes unrelated to genuine insolvency resolution. Examples cited include Reduction of tax liabilities, Avoidance of regulatory scrutiny, Shielding assets, Circumventing investigations and Strategic mergers or closures
If an IP concludes, based on reasonable grounds, that a CIRP or liquidation process may be serving a fraudulent or malicious purpose, the IP must Conduct further examination, Document findings, Present evidence and Approach the Adjudicating Authority for appropriate directions. The responsibility is no longer passive observation. Active assessment is now expected.
| Date | Event | Status |
| 26 May 2026 | Interim moratorium ceases for personal guarantors | Effective |
| 9 September 2026 | Misuse-screening circular applicable | Effective |
| 30 September 2026 | Liquidation forms due | Late fee applicable thereafter |
| 31 December 2026 | PGIRP filing deadline | Extended |
Final Thoughts
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