IBBI Liquidation Form Late Fee: ₹500 + GST per Month — September 2026 Circular
Reviewed on 8 October 2026 | Corporate law and insolvency compliance | PGT & Associates
IBBI’s circular dated 24 September 2026 addresses delayed liquidation forms under Regulation 47B. For each form due on or before 30 September 2026 that is submitted late, including through correction or updating, it specifies ₹500 plus applicable GST per month for the period of delay. Liquidators should review overdue forms and retain filing evidence. This is a liquidation-form compliance requirement; it is not a general company-filing fee or an MCA deadline extension.
What the official circular says
Circular IBBI/LIQ/107/2026 continues the 5 January 2026 circular on revised liquidation forms. Its scope is forms due on or before 30 September 2026 and submitted after their due date. The stated fee is ₹500 with applicable GST per month for delayed filing. Correction, updating and other modes of submission are expressly included.
Do not treat the September date as permission to delay every form until month-end. Check the applicable form’s own due date and Regulation 47B. The short circular does not supply a worked example for counting part-months or a numerical GST rate, so this article does not invent either.
Who should review the filing position?
The circular is addressed to registered insolvency professionals, recognised insolvency professional entities and registered insolvency professional agencies. Operationally, the liquidator and filing-support team should reconcile the case file with actual portal submissions.
Directors, creditors and company finance teams may hold records needed by the liquidator. Providing complete information promptly is useful, but this article does not shift the professional’s filing obligation onto those stakeholders or suggest they can file a substitute MCA return.
A practical liquidation-form review checklist
The following is a suggested working method, not a new statutory format.
Make a form-wise register. Record the corporate debtor, form identifier, event giving rise to filing, applicable due date and the person responsible for preparation.
Match records to the portal. Preserve submission acknowledgements and timestamps; a prepared spreadsheet is not proof of submission.
Identify corrections separately. Record why a correction or update is needed, the original submission reference and the supporting material.
Flag overdue forms. Escalate the affected forms to the responsible insolvency professional and verify the fee position using the current regulation and portal workflow.
Keep a review trail. Save the approved version, acknowledgement, supporting documents and any fee evidence together so the filing history is understandable later.
A useful control is a weekly reconciliation between the case diary and the form register. For example, if an event is recorded in the case file but its corresponding filing is absent from the register, investigate the gap before assuming compliance. This is a process-control example, not a legal conclusion that a particular form is due.
Liquidation forms and personal-guarantor forms are different
IBBI issued another circular on 24 September 2026 concerning PGIRP forms for personal guarantors to corporate debtors. Circular IBBI/II/108/2026 extends their filing deadline to 31 December 2026 and provides for delayed-submission or modification penalties only after that date. That separate notice does not extend liquidation-form deadlines.
Frequently asked questions
Is ₹500 the total charge for an entire liquidation case?
No. The circular describes the fee for each affected form per month of delayed filing, plus applicable GST. Do not describe it as one flat fee for the whole case.
Are corrections and updates covered?
Yes. The circular expressly mentions correction and updating. Check the particular filing’s due date and circumstances before calculating an amount.
Does the PGIRP extension protect overdue liquidation forms?
No. The two circulars concern different processes and forms. Keep separate compliance registers.
Does this article determine the exact amount payable?
No. Verify the specific form, due date, delay period and current portal calculation with the responsible insolvency professional. The checklist helps assemble evidence; it is not a substitute for that assessment.
Related corporate-law reading
Source and review notes
This article uses the two official IBBI circulars linked above, dated 24 September 2026, and was reviewed on 8 October 2026. It does not describe them as notices issued today. Later official changes should be checked before filing. The cover image is an AI-generated editorial illustration, not an official IBBI document.
General professional information only. Case-specific legal and insolvency advice requires examination of the records and applicable law.
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