IBBI Notifies E-Forms for Personal Guarantor Insolvency Process

The Insolvency and Bankruptcy Board of India (IBBI), vide Circular no. IBBI/II/92/2026 dated March 6, 2026, has introduced a framework for filing electronic forms to monitor insolvency resolution processes of personal guarantors to corporate debtors under the Insolvency and Bankruptcy Code, 2016 (IBC). Issued under Regulation 23 of the IBBI (Insolvency Resolution Process for Personal Guarantors to Corporate Debtors) Regulations, 2019, the Circular operationalises a stage-wise filing mechanism through a series of standardised electronic forms to be submitted by Resolution Professionals (“RPs”) during the lifecycle of the resolution process.

The Circular represents a significant step toward strengthening regulatory oversight and transparency in personal guarantor insolvency proceedings by transitioning from email-based reporting to a structured digital compliance framework.

Prior to this clarification, although Regulation 23 required periodic submission of information to the IBBI, reporting was largely undertaken through email communication, resulting in delays, inefficiencies and lack of standardisation in monitoring process-level developments.

To address these challenges, the Circular introduces six electronic forms (PGIRP-1 to PGIRP-6) designed to capture stage-specific information across the insolvency resolution timeline.

Collectively, these forms track the progression of proceedings from the admission stage to the implementation of the repayment plan and eventual discharge of the personal guarantor. Broadly, the reporting framework covers:

1. Submission of RPs reports under Sections 99 and 100 of the IBC;
2. Issuance of public notice and collation of creditor claims;
3. Submission and consideration of repayment plans;
4. Orders passed by the Adjudicatory Authority;
5. Implementation status of approved repayment plans; and
6. Quarterly progress updates until closure of the process.

The Circular further operationalises an electronic filing interface hosted on the IBBI portal through which RPs are required to upload forms using authenticated login credentials and digital signatures. Each form corresponds to a defined procedural stage, including:

1. PGIRP-1: From admission of application under Sections 94/95 till filing of report under Section 99.
2. PGIRP-2A: From submission of report under Section 99 till passing of an order under Section 100.
3. PGIRP-2B: Covering outcomes of admission proceedings till public announcement stages under section 100 and section 102.
4. PGIRP-3: From public announcement till submission of report on the repayment plan;
5. PGIRP-4: From submission of report on repayment plan till adjudication order passed by the Adjudicating Authority.
6. PGIRP-5: From the approval of repayment plan till discharge of personal guarantor; and
7. PGIRP-6: Quarterly status reports capturing progress, delays and key developments.

Each form is required to be filed on or before the 10th day of the subsequent month following the relevant event or stage in the process.

The Circular also prescribes procedural requirements of electronic submission inlcuding:

1. uploading forms along with supporting records through the online platform;
2. authentication through digital signature or e-sign; and
3. use of a modification utility for any subsequent changes, authenticated through OTP verification

Specific timelines have been prescribed for applicability across ongoing and concluded matters:

1. where orders under Sections 97 or 100 are passed on or after the date of the Circular, filings must be made within the prescribed timelines;
2. where reports under Section 99 have been submitted but orders under Section 100 are pending, forms must be filed on or before March 31, 2026;
3. where admission orders under Section 100 have been passed but orders under Sections 118(3) or 119(1) are pending, filings must be completed on or before June 30, 2026; and
4. for concluded processes, forms are required to be filed on or before June 30, 2026.

Further, the Circular clarifies that penalties for delayed submission or modification will be enforced only after June 30, 2026, providing a transition period for compliance.

Importantly, failure to submit forms or furnishing incomplete or inaccurate information may attract action under the IBC and applicable regulations, including refusal to issue or renew Authorisation for Assignment.

Overall, the Circular introduces a comprehensive, technology-driven reporting framework for monitoring insolvency resolution processes involving personal guarantors. By replacing e-mail based reporting with a structured milestone-linked filing framework, the IBBI has strengthened transparency, accountability and regulatory oversight across the resolution lifestyle reinforcing effectiveness of the personal guarantor insolvency regime.