Major Changes Introduced on Revised CIRP Form issued by IBBI

Major Changes Introduced on Revised CIRP Forms”  issued by IBBI

In a significant step toward streamlining insolvency compliance and promoting digital governance, the Insolvency and Bankruptcy Board of India has announced major amendments to the Corporate Insolvency Resolution Process under the IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016. These changes, notified on May 19, 2025, and formalized through Circular No. IBBI/CIRP/85/2025 dated May 26, 2025, will come into effect from June 1, 2025. FAQs on Revised CIRP Forms” (as on 26.05.2025) issued by the Insolvency and Bankruptcy Board of India (IBBI), here is a summary of key changes and requirements under the Revised CIRP Forms Framework, effective from June 1, 2025:

Major Changes Introduced By IBBI IN IP (IRP or RP) Form

The revised framework consolidates the existing nine forms (IP-1 and CIRP Forms 1 to 8) into five new standardized forms — CP-1 to CP-5. The objective is to reduce redundancy, align filings with key CIRP milestones, and introduce automated data population via IBBI’s digital platform. This marks a major leap toward a more efficient, technology-enabled insolvency ecosystem.

Overview of New CIRP Forms

Consolidation of Revised CIRP Forms : The 9 earlier CIRP Forms (IP-1 and CIRP-1 to CIRP-8) are replaced with 5 consolidated CIRP Forms. Each new form is designed to correspond with a specific stage of the resolution process:

• • CP-1: From CIRP commencement to CoC constitution. Covers CIRP initiation through CoC constitution, including IRP details, claim collation, public announcement, and formation of the Committee of Creditors.
    To be filed by IRP by the 10th of the month following CoC constitution report submission to AA.
  • CP-2: From CoC constitution to issuance of RFRP. Applies from CoC constitution to issuance of the Request for Resolution Plan (RFRP), including the Information Memorandum, EOIs, and valuer details. To be filed by RP by the 10th of the month after RFRP issuance.

1. • CP-3A: Contains data on resolution plans or liquidation/closure applications filed with the Adjudicating Authority (AA). To be filed by RP by the 10th of the month after application submission.
   • CP-3B: For resolution/liquidation applications and their disposal. Captures the outcome — approval or rejection — of resolution/liquidation applications by the AA. To be filed within 7 days of disposal of application by AA.
   • CP-4: For avoidance transactions. Deals with avoidance transaction applications and orders thereon. To be filed by RP by the 10th of the month following filing/disposal with the AA.
   • CP-5: Monthly updates (new standard format). Provides comprehensive monthly updates on CIRP progress, CoC meetings, litigations, expenses, delays, and other developments. To be filed by IRP/RP by the 10th of every month for the preceding month (starting July 10, 2025, for the month of June 2025).
2. Standardized Monthly CIRP Forms  Reporting: CP-5 must be submitted by the 10th of every month for the preceding month (first due: July 10, 2025 for June 2025 data).
3. Auto-population & e-Platform Integration: CIRP Forms will be filed through IBBI’s online platform using DSC or e-sign.

Key Timelines & Transitional Provisions

Scenario	Filing Requirement
CIRPs admitted on or after June 1, 2025	Use new CP forms as per specified timelines
CIRPs closed on or before May 31, 2025, but pending forms	Submit equivalent CP forms by Sept 30, 2025

Digital Filing Process:

All forms must be filed electronically on IBBI’s designated platform using the credentials issued to insolvency professionals. Each submission must be authenticated via digital signature certificate (DSC) or e-sign. The circular includes indicative templates to aid compliance.

Ongoing CIRPs as of June 1, 2025: IP (IRP or RP) :

• No need to refile CP-1 or CP-2 if CIRP-1 to 4 already submitted.
• IP (IRP or RP) must file CP-3A, CP-3B, CP-4 as applicable.
• IP (IRP or RP) must file monthly CP-5 starting July 10, 2025.

The IP (IRP or RP) in office as on the last day of the preceding month shall file the form.

What is IP (IRP or RP) Form required to submission deadlines?

• CP-1: By 10th of the month after filing CoC constitution report to AA.
• CP-2: By 10th of the month after issuance of RFRP.
• CP-3A: By 10th of the month after filing resolution/liquidation application.
• CP-3B: Within 7 days of order disposal by AA.
• CP-4: By 10th of the month after filing/disposal of avoidance applications.
• CP-5: Monthly, by 10th of every month for prior month.

Initial Grace Period :

• To facilitate smooth transition, no penalties shall be levied for delayed filing of revised forms during the initial quarter (July to September 2025).
• Other compliances: Filing Form A (Public Announcement), Form G (RFRP), claim filings, etc., remain unchanged.

Insolvency and Bankruptcy Board of India hereby issued the following Amendments.

This is to apprise that IBBI in exercise of the powers conferred by sections 196, 207 and 208 read with section 240 of the Insolvency and Bankruptcy Code, 2016 (31 of 2016), the Insolvency and Bankruptcy Board of India hereby issued the following Amendments.

• Amendments to Regulation: IBBI (Insolvency Resolution Process for Corporate Persons) (Sixth Amendment) Regulations, 2025 dated 14th October 2025.
• Amendments to Regulation: IBBI (Liquidation Process) (Second Amendment) Regulations, 2025 dated 14th October 2025.
• Copy of the Amendment is given as link below for your reference and compliance:
  • IBBI (Insolvency Resolution Process for Corporate Persons) (Sixth Amendment) Regulations, 2025 – https://ibbi.gov.in/uploads/legalframwork/f006fdcfd9cc35f461e320375809cbf3.pdf
  • IBBI (Liquidation Process) (Second Amendment) Regulations, 2025 – https://ibbi.gov.in/uploads/legalframwork/85d48cede86251c9446cf712d1812308.pdf

Conclusion:

This comprehensive overhaul by the Insolvency and Bankruptcy Board of India underscores its commitment to creating a digitally robust, transparent, and compliance-friendly insolvency regime. By mapping disclosures to procedural milestones and enabling seamless electronic submissions, the revised CIRP forms aim to reduce administrative friction and enhance the effectiveness of resolution professionals in navigating the insolvency process. In case any issue in filling Revised CIRP Forms we can use Insolvency and Bankruptcy Board of India’s technical support team for handling the CIRP Form filling Issues in filing, IP may contact via email i.e support.form@ibbi.gov.in.