Amendments to IP Eligibility Period and Form H under CIRP Regulations

Notification/Circular Nos.:

  • F. No. IBBI/2025-26/GN/REG123
  • F. No. IBBI/2025-26/GN/REG124

 

Document Date: April 3, 2025

Applicable Act/Rule: Insolvency and Bankruptcy Code, 2016

Applicable Section/Rule:

  • Regulation 5(a) of the IBBI (Insolvency Professionals) Regulations, 2016
  • Schedule-I, Form H of the IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016

 

Background and Rationale

The Insolvency and Bankruptcy Board of India (IBBI) has issued two important amendments. The first extends the required period of practical experience for registration as an Insolvency Professional (IP) from 12 to 24 months, ensuring higher professional maturity. The second replaces the existing Form H, a key compliance document under the CIRP Regulations, with an updated format to improve reporting accuracy and administrative clarity. Both updates reflect the Board’s effort to raise professional standards and enhance transparency in the insolvency ecosystem.

Detailed Comparison of Provisions


1. Regulation 5(a) – Experience Criteria for IPs

  • Earlier Provision: Minimum 12 months of relevant experience required for registration as an IP.
  • Amended Provision: This period is now extended to 24 months, indicating a move toward higher competence and readiness among insolvency professionals.

2. Schedule I, Form H – CIRP Compliance Certificate

  • Earlier Form: The existing version of Form H was used to certify compliance with the CIRP process as per Regulation 40A.
  • Amended Form: A newly substituted Form H enhances disclosure, improves tracking of procedural compliance, and provides a structured template for Resolution Professionals to report closure-related details.

 

Amendments and Their Implementation

  • What Changed:
    • Regulation 5(a) now mandates 24 months of experience instead of 12.
    • Form H under CIRP regulations has been fully replaced with a new format.
  • Implementation: Both amendments are effective from April 3, 2025.
  • Who Must Comply:
    • Professionals applying for registration post-April 3 must meet the new 24-month threshold.
    • Resolution Professionals filing Form H after this date must use the updated format.


Implications and Future Prospects

A higher bar for entry into the IP profession is likely to ensure better case handling and fewer procedural lapses. The new Form H may also serve as a precursor to similar template improvements across other compliance forms. IBBI may introduce further refinements based on feedback and stakeholder input.

Conclusion

Through these amendments, IBBI reaffirms its focus on capability-building and transparency. Raising the IP eligibility period promotes quality in insolvency practice, while the new Form H introduces consistency in CIRP closure reporting.

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