IBBI Starts ₹500-a-Month Late Fee on Liquidation Forms, Gives Personal-Guarantor Forms Until December 31

The Insolvency and Bankruptcy Board of India (IBBI) has started charging a late fee on liquidation forms. Under Circular No. IBBI/LIQ/107/2026 dated 24 September 2026, every form due on or before 30 September 2026 that is filed after its due date must carry a fee of ₹500 plus applicable GST for each month of delay. On the same day, in a separate circular (No. IBBI/II/108/2026), IBBI gave insolvency professionals until 31 December 2026 to file the six forms used to monitor insolvency resolution of personal guarantors to corporate debtors.

Both circulars are addressed to registered insolvency professionals, insolvency professional entities and insolvency professional agencies, and are issued under section 196 of the Insolvency and Bankruptcy Code, 2016. The first ends the grace period for liquidators; the second extends it again for professionals handling personal-guarantor cases.

Which liquidation forms now attract a fee

The fee is levied under Regulation 47B of the IBBI (Liquidation Process) Regulations, 2016. An amendment notified on 2 January 2026 recast Regulation 47B(1) so that the liquidator must file the forms notified by the Board, with enclosures, on IBBI's electronic platform within the timeline set for each form.

Those forms were introduced by Circular No. IBBI/LIQ/91/2026 of 5 January 2026, which replaced the earlier liquidation forms with four new ones:

• LIQ-1 covers the period from commencement of liquidation to the public announcement, and is due by the 10th of the month after the announcement.
• LIQ-2 is the quarterly progress report form, due by the 10th of the month after the progress report is submitted to the Adjudicating Authority.
• LIQ-3 covers the period from the last progress report to the application for dissolution or closure, due by the 10th of the month after that application is filed.
• LIQ-4 covers the period from the dissolution or closure application to the Tribunal's order, and is due within 7 days of the application being disposed of.

The January circular said no penalty would be charged for late filing during January to March 2026 so that liquidators could get used to the new forms. The September circular now sets the fee in motion.

How the late fee is worked out

The fee is ₹500 per form per month of delay, with GST on top. It applies to late submission of any kind, which covers corrections and updates made after the due date as well as first filings. So a liquidator who files an LIQ-2 two months late would pay ₹1,000 plus GST for that form, and several overdue forms in the same case would each carry their own fee.

The circular's wording ties the fee to forms "due on or before 30.09.2026" and filed after their due date. It does not say in so many words whether, for a form that is already overdue, the months are counted from the original due date or only from 30 September 2026. Liquidators with a backlog should file before the end of September and check the fee computed on the platform.

IBBI took the same route for CIRP forms last year

The move mirrors what IBBI did for corporate insolvency resolution. Under Circular No. IBBI/CIRP/89/2025 of 18 December 2025, forms that were due on or before 31 December 2025 and filed after that date were charged ₹500 (excluding GST) per form. The fee ran for each calendar month of delay under Regulation 40B of the CIRP Regulations. That circular also explained that the fee is computed only after a form's final due date, so an early filing that is modified before the due date does not attract any fee.

Personal-guarantor forms get a second extension

Forms PGIRP-1 to PGIRP-6, used to monitor insolvency resolution processes of personal guarantors to corporate debtors, were mandated by Circular No. IBBI/II/92/2026 of 6 March 2026. The first deadline of 30 June 2026 was moved to 30 September 2026 by Circular No. IBBI/II/104/2026 of 9 July 2026, after professionals cited technical difficulties and the time needed to learn the electronic platform.

IBBI has now pushed the deadline to 31 December 2026 on similar representations, and says penalties for delayed submission or modification of these forms will be levied only after that date. The extension comes in a busy month for personal-guarantor insolvency. IBBI has told professionals that the interim moratorium for personal guarantors ended on 26 May 2026, including for pending applications, and its proposed safeguards for personal-guarantor insolvency are open for comments until 3 October.

What liquidators should check before 30 September

• List every LIQ form in each assignment and compare its due date with the filing date on the platform.
• File pending forms, and any corrections to forms already filed, before the due date wherever possible, since changes made later are also treated as late.
• Keep the GST component in mind when budgeting the fee as a process cost, and record the reason for any delay in the case file.
• Where a stakeholder list is being revised under the recent amendment allowing liquidators to update stakeholder lists with 30-day NCLT intimation, make sure the related forms reflect the change on time.

Technical problems with either set of forms can be reported to support.form@ibbi.gov.in, and IBBI's FAQs on the forms are on its circulars and legal framework pages.

Official source: View the official source document