Quick Answer
The Insolvency and Bankruptcy Board of India (IBBI) has further extended the deadline for filing PGIRP-1 to PGIRP-6 forms relating to insolvency resolution processes for Personal Guarantors to Corporate Debtors.
Under Circular No. IBBI/II/108/2026 dated 24 September 2026, the earlier deadline of 30 September 2026 has been extended to 31 December 2026. The circular further states that penalties for delayed submission or modification of these forms will be levied only after 31 December 2026.
Quick Reference
Background: PGIRP Form Filing Requirement
IBBI had earlier mandated the filing of electronic PGIRP-1 to PGIRP-6 forms on its e-platform for monitoring insolvency resolution processes concerning Personal Guarantors to Corporate Debtors. This requirement was introduced through Circular No. IBBI/II/92/2026 dated 6 March 2026.
The PGIRP form set comprises PGIRP-1, PGIRP-2A, PGIRP-2B, PGIRP-3, PGIRP-4, PGIRP-5 and PGIRP-6. These electronic forms are used to provide information to IBBI for monitoring insolvency resolution processes concerning Personal Guarantors to Corporate Debtors under the Insolvency and Bankruptcy Code, 2016 and the regulations made thereunder.
The Resolution Professional / Insolvency Professional handling the personal guarantor assignment is responsible for accessing the IBBI electronic platform and filing the applicable PGIRP forms with the required information and records. The forms are authenticated through DSC or e-signing.
What Changed on 24 September 2026?
Through Circular No. IBBI/II/108/2026, dated 24 September 2026, IBBI has made two important changes:
1. Filing deadline extended: The last date for submission of all applicable PGIRP forms has been further extended from 30 September 2026 to 31 December 2026.
2. Penalty date extended: Penalties for delayed submission or modification of these forms will now be levied only after 31 December 2026.
PGIRP Filing Deadline Timeline
Why Has IBBI Extended the Deadline Again?
The September 2026 circular states that IBBI received feedback from Insolvency Professionals (IPs) and Insolvency Professional Agencies (IPAs) seeking an extension for filing the forms.
The circular also refers to proposed changes and states that additional time is being provided to ensure seamless compliance. The circular does not specify the nature of those proposed changes.
Penalty / Late Filing Provision
Under the new circular, the applicable PGIRP forms can be submitted or modified during the extended period up to 31 December 2026, and penalties for delayed submission or modification will be levied only after 31 December 2026.
The 9 July 2026 IBBI circular separately directed Insolvency Professionals to ensure that information submitted through PGIRP forms is accurate, truthful, complete and consistent with the supporting documents. The September 2026 extension changes the filing deadline and penalty trigger date; it does not state that this filing-quality responsibility has been withdrawn.
Therefore, the earlier 30 September 2026 date is no longer the relevant cut-off for the penalty trigger under this extension.
Who Is Affected?
What Are PGIRP-1 to PGIRP-6 Forms?
PGIRP-1 to PGIRP-6 are electronic forms filed on IBBI's e-platform for monitoring insolvency resolution processes concerning Personal Guarantors to Corporate Debtors.
Their filing requirement was originally mandated by Circular No. IBBI/II/92/2026 dated 6 March 2026.
Note: Circular No. IBBI/II/108/2026 further extends the submission deadline for all applicable PGIRP forms to 31 December 2026. The above table summarises the form-wise stages and general filing timelines under the original PGIRP framework.
When Does the New Extension Apply?
Previous filing deadline: 30 September 2026
Revised filing deadline: 31 December 2026
Penalty trigger: Penalties for delayed submission or modification will be levied only after 31 December 2026.
Compliance Action Plan
Key Takeaways
✔ New deadline: 31 December 2026
✔ Forms covered: PGIRP-1 to PGIRP-6
✔ Previous deadline: 30 September 2026
✔ Penalty: Penalties for delayed submission or modification will be levied only after 31 December 2026
✔ Circular: IBBI/II/108/2026 dated 24 September 2026
Frequently Asked Questions
What is the new deadline for filing PGIRP forms?
The new deadline is 31 December 2026.
Which forms are covered by the extension?
The extension applies to the applicable PGIRP-1 to PGIRP-6 forms.
What was the earlier deadline?
The earlier deadline was 30 September 2026, following Circular No.
IBBI/II/104/2026 dated 9 July 2026.
Will a penalty apply to forms filed after 30 September but before 31 December 2026?
Under the September 24, 2026 circular, penalties for delayed submission or modification of the applicable
forms will be levied only after 31 December 2026.
Does this circular specify a fixed late fee amount?
No. Circular No. IBBI/II/108/2026 does not specify a new fixed rupee amount for the PGIRP penalty.
It specifies that penalties for delayed submission or modification will be levied only after
31 December 2026.
Why has IBBI extended the deadline?
IBBI states that it received feedback from Insolvency Professionals and Insolvency Professional Agencies
requesting an extension. The circular also refers to proposed changes and the need for additional time
to ensure seamless compliance.
Who is addressed by the circular?
The circular is addressed to all Registered Insolvency Professionals, all Recognised Insolvency Professional
Entities, and all Registered Insolvency Professional Agencies.
Where can technical filing problems be reported?
Technical issues or difficulties with electronic filing may be reported to
[email protected].
CorpLawUpdates Analysis
The latest IBBI circular changes both the practical filing cut-off and the penalty trigger date for the applicable PGIRP forms. The earlier 30 September 2026 date has been superseded by 31 December 2026.
Importantly, the September 24 circular should not be interpreted as introducing a new ₹500 monthly fee for PGIRP forms. The circular speaks specifically about penalties for delayed submission or modification and states when those penalties will be levied.
The separate ₹500 plus applicable GST per month delayed-filing fee relates to LIQ forms under Regulation 47B of the Liquidation Process Regulations and should be treated as a separate regulatory update.
Source Note
Primary source: IBBI Circular No. IBBI/II/108/2026 dated 24 September 2026, titled “Further extension of time for filing Forms to monitor insolvency resolution processes for Personal Guarantors to Corporate Debtors under the Insolvency and Bankruptcy Code, 2016, and the regulations made thereunder.” The circular refers to Circular No. IBBI/II/92/2026 dated 6 March 2026 and Circular No. IBBI/II/104/2026 dated 9 July 2026.
This article is for informational and educational purposes only and does not constitute legal or regulatory advice. Readers should verify the applicable primary regulatory source before taking action.
