IBBI Rolls Out Revised CIRP Forms to Simplify and Digitize Compliance

In a move to simplify regulations and promote digital standardization, the Insolvency and Bankruptcy Board of India (IBBI), through notification dated May 19, 2025 and via circular bearing reference no. IBBI/CIRP/85/2025 dated May 26, 2025, has announced major amendments to the Corporate Insolvency Resolution Process (CIRP) under the IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016, effective from June 1, 2025.

The changes consolidate the previous nine forms IP-1 and CIRP Forms 1 to 8, into five new forms, CP-1 to CP-5, thereby reducing redundancy, aligning disclosures with CIRP milestones, and enabling data auto-population via IBBI’s electronic platform. This overhaul is expected to ease the compliance burden and offer insolvency professionals (IP) a more streamlined and user-friendly filing process.

Overview of New Forms

Each of the five forms corresponds to a specific phase of the CIRP:

1. CP-1: Covers initiation of CIRP up to constitution of the Committee of Creditors (CoC), including details of the IRP, claims, public announcement, and CoC formation. Filed by the Insolvency Resolution Professional (IRP) by the 10th of the following month after filing the report of CoC constitution.
2. CP-2: Pertains to the phase from CoC constitution until issuance of the Request for Resolution Plan (RFRP), capturing Information Memorandum, Expressions of Interest, and registered valuer details. Filed by the RP by the 10th of the month after RFRP issuance.
3. CP-3A: Contains details of the resolution plan or liquidation/closure application filed before the Adjudicating Authority (AA). To be filed by the RP by the 10th of the month after the filing application with AA.
4. CP-3B: Captures approval of resolution plan or liquidation/closure by AA. Must be filed by RP within 7 days of the disposal of the application by AA.
5. CP-4: Relates to avoidance transactions and associated applications and orders. Filed by RP by the 10th of the month after filing/disposal by AA.
6. CP-5: Captures the overall CIRP status, CoC meetings, litigations, expenses, and delays. Filed by IRP/RP by the 10th of every month for the preceding month.
7. All forms are to be submitted digitally using IBBI’s platform with login credentials issued to IRPs/RPs and authenticated by digital signature or e-sign. Indicative templates are provided in the circular annexure.

Transition guidelines:

1. For CIRPs admitted on or after 1st June 2025, revised forms are mandatory.
2. Ongoing CIRPs:
   1. CP-1 and CP-2 are required only if earlier versions are not filed.
   2. CP-3A, CP-3B, and CP-4 are to be filed in all cases.
   3. CP-5 filings commence on 10th July 2025 (for June 2025) and continue monthly.
3. CIRPs closed on or before 31st May 2025: Any pending forms to be submitted in the new format by 30th September 2025.
4. Filing responsibility lies with the IP who holds office as of the last day of the preceding month. Penalties for delayed filings are waived during the transition quarter (July–September 2025).

IBBI’s revised CIRP form structure reflects its commitment to a more efficient and digitally streamlined insolvency regime. By aligning disclosure obligations with procedural stages and enabling platform-driven compliance, the initiative is expected to enhance transparency, reduce administrative friction, and facilitate smoother execution for professionals engaged in CIRP proceedings.