IBBI Introduces CP Form Modification Utility and Late Fee for Delayed Filings

Circular No. IBBI/CIRP/89/2025; Dated: 18.12.2025

1. Regulatory Background

The Insolvency and Bankruptcy Board of India (IBBI) has introduced important procedural changes relating to filing of forms under Regulation 40B of the IBBI (Corporate Insolvency Resolution Process) Regulations.

The changes include:

• Introduction of a modification utility for CP Forms filed on the IBBI portal, and
• Commencement of levy of fees for delayed filing of forms.

These measures aim to improve data accuracy, regulatory compliance, and timeliness of disclosures by Insolvency Professionals (IPs).

2. Introduction of Modification Utility in CP Forms

To address errors or omissions in filings, IBBI has enabled a modification utility on the portal.

2.1 Key Feature

Where an Insolvency Professional identifies any deficiency in a form already submitted, the IP may:

• Access the modification utility, and
• Make the necessary corrections or updates to the filed CP Form.

2.2 Regulatory Significance

• Eliminates the need for informal correspondence or re-filing
• Ensures accuracy and completeness of insolvency process data
• Facilitates better regulatory monitoring and analytics

3. Levy of Fee for Delayed Filing of Forms

IBBI has also operationalised the fee mechanism for delayed filing as provided under Regulation 40B of the CIRP Regulations.

3.1 Applicability

• Applies to all forms that were due on or before 31 December 2025
• Where such forms are submitted after 31 December 2025, a fee becomes payable

3.2 Fee Structure

• ₹500 per form
• For each calendar month of delay
• Fee is calculated form-wise, not consolidated

This introduces a recurring financial consequence for prolonged delays.

4. Effective Date

• The fee requirement applies to all eligible delayed forms filed after 31 December 2025
• The modification utility is available immediately on the portal

5. Regulatory Intent

The measures are intended to:

• Improve timeliness and discipline in statutory filings
• Encourage self-correction through the modification utility
• Reduce regulatory follow-ups on inaccurate or incomplete submissions
• Ensure reliable insolvency ecosystem data for supervision and policymaking

6. Compliance Takeaways for Insolvency Professionals

IPs should:

• Review all pending and past-due CP Forms immediately
• File delayed forms at the earliest to minimise monthly fee exposure
• Use the modification utility promptly upon identifying any error
• Strengthen internal filing calendars and documentation checks
• Budget for potential late fees where delays are unavoidable

Failure to comply may result in:

• Accumulation of monthly fees
• Regulatory scrutiny during inspections or disciplinary proceedings

7. Key Takeaway

From 1 January 2026 onwards, delayed filing of CP Forms under Regulation 40B carries a financial cost, while the newly introduced modification utility provides a structured mechanism for correcting deficiencies in filings.

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