IBBI has commenced the levy of a fee of ₹500 per Form for each calendar month of delay, plus applicable GST, for liquidation Forms that were due on or before 30 September 2026 and are submitted after their due date. The fee also applies where a late filing is made by way of correction, updation or otherwise.
Quick Answer: What Has IBBI Changed?
The Insolvency and Bankruptcy Board of India (IBBI) has notified the commencement of the delayed filing fee under Regulation 47B of the IBBI (Liquidation Process) Regulations, 2016. Under Circular No. IBBI/LIQ/107/2026 dated 24 September 2026, each liquidation Form that was due on or before 30 September 2026 and is submitted after its due date must be accompanied by a fee of ₹500 per Form for each calendar month of delay, with applicable GST. The circular expressly covers filings made by correction, updation or otherwise.
The important point is that the circular concerns the commencement of levy under the existing Regulation 47B framework. It is not a new filing Form or a replacement for the revised liquidation Forms introduced earlier in 2026.
At a Glance
What Is Regulation 47B?
Regulation 47B of the Liquidation Process Regulations requires the liquidator to file specified Forms and their enclosures electronically on the Board's platform within the timelines prescribed for each Form. The regulation covers LIQ-1, LIQ-2, LIQ-3 and LIQ-4.
Regulation 47B also provides that a Form filed after its due date, whether by correction, updation or otherwise, is accompanied by a fee of ₹500 per Form for each calendar month of delay after the date notified by the Board. It separately provides for regulatory action in cases including failure to file, inaccurate or incomplete information, and delay in filing.
Regulation 47B already contains a delayed-filing fee mechanism. The 24 September 2026 circular tells practitioners when the Board's fee levy will commence for the specified set of liquidation Forms.
Which Liquidation Forms Are Covered?
Regulation 47B contains four principal liquidation monitoring Forms. Their prescribed timelines are different, so the relevant due date must be determined Form-by-Form.
These Form timelines arise from Regulation 47B; the 24 September 2026 circular does not replace the individual due dates with a single 30 September deadline.
What Does the 30 September 2026 Date Mean?
The circular states that the levy applies to each Form which is due on or before 30 September 2026 and is submitted after its due date.
The 30 September 2026 date is the cut-off for Forms covered by this commencement notice. It should not be treated as a universal new due date for LIQ-1, LIQ-2, LIQ-3 and LIQ-4. Each Form continues to have its own prescribed timeline under Regulation 47B.
The 30 September 2026 date is therefore a cut-off for identifying Forms covered by this particular commencement circular; it does not replace the individual due date prescribed for LIQ-1, LIQ-2, LIQ-3 or LIQ-4 under Regulation 47B.
Accordingly, a liquidator should first determine the actual due date of the relevant Form under Regulation 47B and then check whether the Form falls within the circular's 30 September 2026 cut-off.
How Much Is the Delayed Filing Fee?
The notified fee is ₹500 per Form for each calendar month of delay, with applicable GST. The fee is therefore linked to the number of Forms and the period of delay; it is not described in the circular as a single flat charge covering all delayed Forms.
Important: ₹500 Is Plus GST
The circular expressly states that the ₹500 fee is accompanied by applicable GST. Practitioners should therefore not treat ₹500 as the final all-inclusive amount.
Does the Fee Apply to Correction or Updation?
Yes. The circular specifically states that the fee applies where a delayed Form is submitted “whether by correction, updation, or otherwise.” Therefore, filing a corrected or updated Form after the relevant due date does not by itself avoid the delayed-filing fee.
What Happens Apart From the ₹500 Fee?
The delayed-filing fee should not be confused with the Board's separate regulatory powers under Regulation 47B(4). The regulation states that the liquidator shall be liable to any action which the Board may take as deemed fit under the Code or any regulation made thereunder, including refusal to issue or renew Authorisation for Assignment, for specified non-compliances.
- failure to file a Form with the requisite information and records;
- filing inaccurate or incomplete information or records; and
- delay in filing the Form.
The regulation specifically mentions possible action including refusal to issue or renew Authorisation for Assignment. Therefore, payment of the delayed filing fee should not be understood as automatically eliminating other regulatory consequences for non-compliance.
What Is the Relationship With the 5 January 2026 Circular?
The 24 September 2026 circular is expressly issued in continuation of Circular No. IBBI/LIQ/91/2026 dated 5 January 2026, which dealt with the revised liquidation Forms.
In January 2026, IBBI introduced the revised liquidation Forms and their electronic filing framework. The September circular now addresses the commencement of the delayed-filing fee contemplated by Regulation 47B.
Therefore, the two circulars should be read together rather than treating the September circular as a replacement for the January circular.
What Should Liquidators Do Now?
Example: How the New Rule Works
Suppose a liquidation Form falls within the Forms covered by the 30 September 2026 cut-off and its prescribed due date has already passed. If the Form is subsequently submitted after that due date, the filing must be accompanied by the prescribed delayed-filing fee under the circular. The same treatment applies where the delayed submission is made through correction or updation.
The exact fee calculation should be checked against the filing circumstances and the Board's electronic filing mechanism because Regulation 47B refers specifically to a fee for each calendar month of delay
Is This a New Penalty?
The ₹500 amount is described in Regulation 47B and the 24 September 2026 circular as a fee for delayed filing, rather than the only regulatory consequence of delay. Regulation 47B separately empowers the Board to take appropriate action in specified cases of non-compliance.
Does This Circular Apply to Every IBC Process?
No. The circular is specifically addressed to Forms under Regulation 47B of the Liquidation Process Regulations. It should not automatically be treated as a delayed-filing fee notification for CIRP, pre-packaged insolvency resolution, voluntary liquidation, personal guarantor or other IBC processes, which operate under their respective regulatory frameworks.
Frequently Asked Questions
1. What is the IBBI delayed filing fee under Regulation 47B?
The fee is ₹500 per Form for each calendar month of delay, with applicable GST, for the Forms covered by the 24 September 2026 commencement circular.
2. Which Forms are covered by Regulation 47B?
Regulation 47B covers LIQ-1, LIQ-2, LIQ-3 and LIQ-4, each with its own prescribed timeline.
3. What is the 30 September 2026 cut-off?
The circular applies to each Form that was due on or before 30 September 2026 and is submitted after its due date.
4. Does the fee apply to correction of a Form?
Yes. The circular expressly covers submission by correction, updation or otherwise after the due date.
5. Is GST payable on the ₹500 fee?
Yes. The circular states that the ₹500 fee is accompanied by applicable GST.
6. Does payment of the fee remove other consequences of delayed filing?
Not necessarily. Regulation 47B separately provides for action by the Board in cases including failure, inaccurate or incomplete filing and delay, with the regulation mentioning possible refusal to issue or renew Authorisation for Assignment.
7. Does the September 2026 circular replace the January 2026 liquidation Forms circular?
No such replacement is stated. The 24 September 2026 circular is issued in continuation of Circular No. IBBI/LIQ/91/2026 dated 5 January 2026.
8. Is 30 September 2026 the due date for all liquidation Forms?
No. LIQ-1 to LIQ-4 have different event-based timelines under Regulation 47B. The 30 September 2026 date is the cut-off stated in the commencement circular for Forms covered by the levy.
CorpLawUpdates Analysis
The immediate compliance issue is not simply the ₹500 amount. Liquidators should reconcile every outstanding liquidation Form with its underlying event date, determine the prescribed due date under Regulation 47B, and identify which Forms fall within the on-or-before 30 September 2026 cut-off.
The circular also makes clear that delayed correction and updation are within scope. This matters for practitioners who may have submitted a Form earlier but still need to make a post-due-date modification.
Because the regulation separately provides for regulatory action in cases of delayed, inaccurate or incomplete filings, the operational objective should be to ensure that Forms are not only filed, but filed accurately and completely within the prescribed timeline.
For liquidation processes, review all LIQ-1 to LIQ-4 Forms that were due on or before 30 September 2026. Any filing already beyond its due date should be checked for the applicable delayed-filing fee, including GST, and for any separate regulatory implications under Regulation 47B.
Source Note
Document: IBBI Circular No. IBBI/LIQ/107/2026
Issuing authority: Insolvency and Bankruptcy Board of India (IBBI)
Date: 24 September 2026
Subject: Commencement of levy of fee for delayed filing of Forms under Regulation 47B of the Liquidation Process Regulations
Signatory: Sanjay Manocha, General Manager
Legal basis: Regulation 47B of the IBBI (Liquidation Process) Regulations, 2016 and Section 196 of the Insolvency and Bankruptcy Code, 2016.
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.
