IBBI Circular IBBI/II/92/2026: Electronic Filing of Forms for Insolvency Resolution of Personal Guarantors – A Complete Guide

📝 BRIEF DESCRIPTION

 
Circular Reference: IBBI/II/92/2026 Issued By: Insolvency and Bankruptcy Board of India (IBBI) Date: 6th March 2026 Applicable To: All Registered Insolvency Professionals, All Recognised Insolvency Professional Entities, All Registered Insolvency Professional Agencies

The IBBI has introduced a mandatory electronic form-filing system for Resolution Professionals (RPs) handling insolvency resolution processes of personal guarantors to corporate debtors. Six forms — PGIRP1 through PGIRP6 — have been notified under Regulation 23 of the IBBI (Insolvency Resolution Process for Personal Guarantors to Corporate Debtors) Regulations, 2019. These forms replace the previous system of email-based submissions and are accessible on the IBBI portal at www.ibbi.gov.in. Filing must be authenticated via Digital Signature Certificate (DSC) or e-Sign. Penalties for delays will only be enforced after 30th June 2026, giving IPs a grace period to familiarise themselves with the new system.
 
 

🔍 DETAILED ANALYSIS

1. Background and Rationale

 
Prior to this circular, Resolution Professionals were required to submit periodic updates on personal guarantor insolvency resolution processes via email to the IBBI. This practice was:
 

• Time-consuming due to manual preparation and coordination,
• Inefficient owing to lack of standardisation, and
• Error-prone due to the absence of structured data capture.

To address these systemic inefficiencies, IBBI has developed a set of six structured electronic forms hosted on its official portal. The legal basis for notifying these forms is Regulation 23 of the IBBI (Insolvency Resolution Process for Personal Guarantors to Corporate Debtors) Regulations, 2019, which empowers the Board to prescribe forms and timelines for RPs to file information with the Board.
 
 

2. Overview of the Six New Forms

 
The circular introduces six electronic forms covering the entire lifecycle of the insolvency resolution process for personal guarantors:


📋 FORM PGIRP1 — Pre-Admission Stage

Coverage: From admission of application under Section 94/95 till filing of report under Section 99.

Key Information Captured:
 

• Date of issuance/execution of the guarantee
• Amount of debt for which the guarantee has been executed
• Date of filing of the RP's report under Section 99
• Whether the report was filed within 10 days of RP's appointment
• RP's recommendation for admission or rejection of the application
• Upload of the Section 99 report

Filing Deadline: On or before the 10th day of the subsequent month after the RP submits the report to the Adjudicating Authority (AA) under Section 99.


📋 FORM PGIRP2A — Rejection of Application

Coverage: From report under Section 99 to rejection order under Section 100.

Key Information Captured:
 

• Date of rejection order by AA under Section 100
• NCLT Bench details (auto-selected from Form 1)
• Reason(s) for rejection
• Upload of the Section 100 rejection order

Filing Deadline: On or before the 10th day of the subsequent month after the rejection order under Section 100.


📋 FORM PGIRP2B — Admission and Public Announcement

Coverage: From the Admission order by AA till public announcement.

Key Information Captured:
 

• Date of admission order under Section 100
• Amount of underlying default admitted
• Name of personal guarantor
• Date of public notice under Section 102
• Last date for submission of claims
• Upload of the public notice

Filing Deadline: On or before the 10th day of the subsequent month after issuance of public notice under Section 102.


📋 FORM PGIRP3 — Creditors and Repayment Plan Submission

Coverage: From public announcement till submission of report on repayment plan.

Key Information Captured:
 

• Whether the list of creditors was prepared within the Section 104 timeline
• Total number of creditors, total claims received, and total claims admitted
• Date of submission of the repayment plan by the personal guarantor to the RP
• Date of submission of the repayment plan to the AA under Section 106
• Details of any application under Regulation 17B (where no repayment plan was prepared)

Filing Deadline: On or before the 10th day of the subsequent month after the RP's report is submitted under Section 106 or 112, or an application is filed under Regulation 17B.


📋 FORM PGIRP4 — Order of AA on Repayment Plan

Coverage: From the report on repayment plan till the order of AA on repayment plan.

Key Information Captured:
 

• Date and nature of AA's order (approved/rejected/directed reconsideration)
• Details of modified repayment plan (if reconsideration was directed)
• Total admitted claims, realisable amount, tenure of repayment plan
• Distribution details to different categories of creditors (secured, employees, statutory dues, unsecured, etc.)
• Upload of AA's order, list of creditors, and the repayment plan

Filing Deadline: On or before the 10th day of the subsequent month after the AA's order on the repayment plan under Section 114 or on the Regulation 17B application.


📋 FORM PGIRP5 — Implementation and Discharge

Coverage: From order of approval of repayment plan till discharge of the personal guarantor.

Key Information Captured:
 

• Whether the RP supervised the implementation as per Section 116(1)
• Whether the repayment plan was successfully implemented
• Date of application for discharge order by RP to AA
• Whether the AA passed the discharge order and the date thereof
• Whether the repayment plan ended prematurely (with Section 118(2) report details)
• Upload of NCLT/DRT orders, Section 116(3) orders, Section 118(3) orders, discharge order, and compliance form

Filing Deadline: On or before the 10th day of the subsequent month after the AA's order under Section 118(3) or 119(1).


📋 FORM PGIRP6 — Quarterly Periodic Report

Coverage: Ongoing quarterly reporting from the date of admission till closure of the process.

Key Information Captured:
 

• Current status of the process: Ongoing / Stayed / Withdrawn
• If Stayed: Nature of stay, name of court/tribunal, order details, category of applicant, and any appeal details
• If Withdrawn: Date of withdrawal application, who filed it, and reasons
• If Ongoing: Current stage of the repayment plan, reasons for delay (if any), and latest activity completed
• Upload of stay orders (if applicable)

Filing Deadline: On or before the 10th day of the subsequent month after the end of each quarter, until closure of the process.
 
 

3. Key Features of the Electronic Platform

• Hosted on: https://www.ibbi.gov.in
• Access: Each IP is provided a unique username and password by IBBI
• Authentication: Mandatory DSC (Digital Signature Certificate) or e-Sign before submission
• Modification Utility: Available on the portal; modifications authenticated via an OTP-based process
• Responsibility: Timely filing of complete and accurate information is the sole responsibility of the IP

4. Compliance Timelines — A Summary

 
SituationDeadlineCases where order under Section 97 or 100 is passed on or after 6th March 2026 | Within prescribed timeline for each form
Cases where Section 99 report submitted but Section 100 order not passed as on 6th March 2026 | On or before 31st March 2026
Cases where Section 100 admission order passed but no Section 118(3)/119(1) order as on 6th March 2026 | On or before 30th June 2026
Concluded cases (rejection under S.100, rejection of repayment plan, premature termination, discharge, or withdrawal) prior to 6th March 2026 | On or before 30th June 2026
Penalties for delayed submission or modification | Only after 30th June 2026
 
 

5. Consequences of Non-Compliance

 
Non-compliance with this circular can attract serious consequences. The IBBI has explicitly stated that an IP shall be liable to any action deemed fit under the Code or regulations, including:
 

• Refusal to issue Authorisation for Assignment (AA)
• Refusal to renew Authorisation for Assignment

Grounds for such action include:
 

1. Failure to file a Form along with relevant information and records
2. Filing of inaccurate or incomplete information and/or records in or along with a Form

6. Practical Implications for Insolvency Professionals

• IPs handling personal guarantor assignments must immediately register/familiarise themselves with the IBBI electronic portal.
• IPs must audit their existing caseload to identify cases falling under the transitional provisions (31st March 2026 and 30th June 2026 deadlines).
• IPs must ensure their DSC is valid and functional for e-filing purposes.
• For any technical difficulties, IPs may reach out to: support.form@ibbi.gov.in
• FAQs are available on www.ibbi.gov.in for clarifications.

7. Significance and Impact

 
This circular represents a significant step in the digitisation of insolvency processes in India. Key takeaways:
 

• Transparency: Standardised forms ensure consistent and auditable data capture across all personal guarantor cases.
• Efficiency: Eliminates ad-hoc email-based reporting, reducing back-and-forth communication.
• Accountability: The IP is solely responsible for the accuracy and timeliness of filings, with clear consequences for non-compliance.
• Regulatory Oversight: IBBI gains real-time visibility into the status of all personal guarantor insolvency resolution processes nationwide.
• Ease of Compliance: The penalty-free window till 30th June 2026 gives IPs adequate time to transition without penal risk.

8. Legal Basis

 
This circular is issued in exercise of the powers under clause (aa) of sub-section (1) of Section 196 of the Insolvency and Bankruptcy Code, 2016, which empowers the IBBI to make regulations and issue directions for the smooth operation of insolvency proceedings.
 
 

✅ Key Takeaways at a Glance

 
AspectDetailsCircular No. | IBBI/II/92/2026
Date | 6th March 2026
Issued By | IBBI
Applicable Law | IBC 2016 + IBBI (IRPPG) Regulations 2019
Forms Introduced | PGIRP1, PGIRP2A, PGIRP2B, PGIRP3, PGIRP4, PGIRP5, PGIRP6
Portal | www.ibbi.gov.in
Authentication | DSC / e-Sign
Grace Period | No penalties till 30th June 2026
Support Email | support.form@ibbi.gov.in


Disclaimer: This analysis is prepared for informational purposes only and does not constitute legal advice. Readers are advised to refer to the original circular available on www.ibbi.gov.in for authoritative guidance.