Under Regulation 27 of the IBBI CIRP Regulations 2016 (as amended May 20, 2026), a Resolution Professional must appoint two sets of IBBI-registered valuers within 7 days of their own appointment — and no later than the 47th day from the insolvency commencement date. Each valuer must independently determine both fair value and liquidation value. For MSME corporate debtors, one set of valuers now suffices by default under the 2026 amendment.
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Appointing the wrong registered valuer or missing the appointment window is one of the most common procedural errors documented by IBBI in its guidance circulars. A wrong valuation can liquidate an otherwise viable corporate debtor, cause resolution plans to be challenged at NCLT, or expose the Resolution Professional to regulatory scrutiny.
This guide covers everything a Resolution Professional, legal counsel, or financial creditor needs to know about correctly appointing an IBBI registered valuer for CIRP including the fresh changes from the May 2026 IBBI amendment.
Why Getting the Valuer Appointment Right Is Critical
In CIRP, the valuation report is not an administrative formality — it is the anchor for every major economic decision in the resolution process:
- The liquidation value sets the floor below which no resolution plan can be approved by the CoC.
- The fair value guides resolution applicants in structuring competitive bids.
- Both values form the basis of the Information Memorandum shared with prospective resolution applicants.
- The NCLT uses these values when adjudicating plan approvals or challenges.
IBBI’s own guidance circular notes that some RPs have appointed valuers who are “the choice of a stakeholder” or professionals without proper IBBI registration — compromising independence and exposing the CD to avoidable costs and legal challenge. This guide ensures you don’t make those mistakes.
The Legal Framework: Regulation 27 and 35 Explaineding element
Two regulations govern the valuer appointment process in CIRP:
| Regulation | What It Governs | Key Requirement (Post May 2026) |
|---|---|---|
| Regulation 27 | Appointment of registered valuers | Two sets of valuers within 7 days of RP appointment, not later than day 47 from ICD. One set for MSMEs (by default). |
| Regulation 35 | Conduct of valuation and submission of report | Valuers independently determine fair value and liquidation value. Reports submitted to RP. Third valuer if estimates differ by ≥25%. |
IVS compliance from April 1, 2026: IBBI Circular IBBI/RV/93/2026 mandates that every valuation report submitted in any IBC proceeding from April 1, 2026 must explicitly state the basis of value (fair value or liquidation value) and confirm adherence to International Valuation Standards (IVS). Valuers who submit reports without this declaration are in breach of IBBI regulations.
Step-by-Step: How to Appoint an IBBI Registered Valuer for CIRP
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DAY 0 — RP APPOINTMENTIdentify the asset classes involved in the CIRPBefore searching for valuers, identify which IBBI asset classes are relevant to the corporate debtor’s assets: Class I (Securities or Financial Assets), Class II (Land and Buildings), and/or Class III (Plant and Machinery). Complex corporate debtors often have assets across all three classes, requiring valuers registered in each.
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WITHIN DAY 1–2 — SHORTLISTINGSearch and verify IBBI registration on ibbi.gov.inVisit ibbi.gov.in → Registered Valuers section. Verify: (a) valid IBBI registration certificate, (b) correct asset class registration, (c) no pending disciplinary proceedings, (d) registered valuer organisation (RVO) affiliation. Shortlist at least 3–4 candidates to choose two independent firms from.
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DAY 2–3 — INDEPENDENCE CHECKConduct a formal conflict-of-interest checkThis is the step most RPs underweight. Each valuer must declare in writing that they have no relationship with: the corporate debtor, any financial creditor in the CoC, the resolution applicants, or the other appointed valuer. Obtain a signed independence declaration before issuing any engagement. IBBI has flagged conflict-compromised appointments in multiple inspection reports.
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DAY 3–5 — APPOINTMENTIssue formal appointment letters and engagement termsIssue separate appointment letters to each valuer specifying: (a) scope of assets to be valued, (b) applicable regulations, (c) IVS compliance requirement, (d) fee terms, (e) submission deadline (45 days from appointment, within the outer 47-day limit from ICD), and (f) confidentiality obligations. Both valuers must be appointed independently — they must not share working papers or methodology during the valuation process.
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DAY 5–7 — REGULATORY FILINGRecord the appointment in CIRP Form CP-2 on IBBI’s e-platformUnder the revised CIRP Forms (effective June 2025), registered valuer details must be disclosed in CIRP Form CP-2 — which covers the phase from CoC constitution until issuance of the RFRP. Ensure the valuer’s IBBI registration number, asset class, and appointment date are correctly recorded. Non-disclosure is a compliance gap that will be flagged in IBBI inspections.
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DAY 7–52 — VALUATION CONDUCTFacilitate site access, data sharing, and management cooperationOne of the most common valuation delays is uncooperative management or restricted site access. As RP, you have a duty to facilitate: physical inspection of all assets, access to audited financial statements (at least 3 years), asset registers, inventory records, and pending litigation disclosures. Management non-cooperation must be formally documented.
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DAY 45–47 — REPORT RECEIPTReceive, review, and present valuation reports to CoCReceive independent reports from both valuers. Check: IVS compliance declaration, basis of value stated, methodology documented. Calculate averages. Present both reports to the CoC at least 15 days before the voting date. If estimates differ by 25% or more, trigger the third-valuer appointment process immediately — do not present the reports to CoC until resolved.
The May 2026 IBBI Amendment: What Changed for Valuer Appointments
The IBBI (CIRP) Second Amendment Regulations, 2026 (effective May 20, 2026) made two significant changes that every RP must know:
Change 1: MSME Single-Valuer Exception
For corporate debtors classified as MSMEs under the MSME Development Act, 2006, the default requirement is now one set of registered valuers instead of two. The CoC may pass a written resolution with documented reasons to appoint two sets — but it is no longer the automatic default for MSMEs. This change directly addresses the cost sensitivity of smaller insolvency estates where dual-valuer fees were disproportionate.
Change 2: 47-Day Outer Deadline from Insolvency Commencement Date
The amended Regulation 27(1) now specifies that the RP must appoint valuers within 7 days of their own appointment, but not later than the 47th day from the insolvency commencement date. This creates a fixed outer boundary — regardless of when the RP was appointed — to prevent valuation appointments being delayed in contested CIRPs where RP appointment itself is delayed.
The 25% Rule: What Happens When Valuers Disagree
This is the scenario most RPs are unprepared for. Under the 2026 IBBI CIRP Amendment Regulations, if the fair value or liquidation value estimates from the two independent valuers differ by 25% or more, the RP must appoint a third set of registered valuers.
The CoC also has enhanced authority under the 2026 amendment to propose appointment of additional valuers with documented reasons — even before the 25% threshold is triggered — if they believe a valuation is inadequately supported.
Checklist: What to Verify Before Appointing a Registered Valuer
- Valid IBBI registration certificate — check registration number and asset class on ibbi.gov.in. Certificate must be current.
- Asset class match — valuer is registered for the specific asset class (I, II, or III) relevant to the CD’s primary assets.
- No pending IBBI disciplinary proceedings — verify on the IBBI orders/circulars section for any recent show-cause notices.
- Independence from CD and creditors — no directorship, shareholding, or prior advisory engagement with the CD or any CoC member in the past 3 years.
- Independence from the second valuer — the two appointed valuers must not be from the same firm, entity, or network.
- IVS compliance capability — confirm the valuer’s reports include IVS basis-of-value declaration (mandatory from April 1, 2026).
- Capacity to complete within 45 days — the valuer must confirm they can complete site visits, analysis, and report submission within the regulatory window.
- Signed independence declaration obtained before issuing appointment letter.
6 Common Mistakes RPs Make When Appointing Valuers
Frequently Asked Questions
1. How does a Resolution Professional appoint an IBBI registered valuer for CIRP?
2. Can an MSME CIRP appoint only one registered valuer?
3. What happens if two valuers give significantly different CIRP values?
4. How do I verify a valuer’s IBBI registration?
5. What is the difference between fair value and liquidation value in CIRP?
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About the author:
Sahil Narula
Sahil Narula is the Managing Partner at RNC Valuecon LLP and a Registered Valuer with IBBI. He brings over a decade of experience in Valuation Services, Corporate Finance, and Advisory, having led numerous complex assignments under the Insolvency & Bankruptcy Code, 2016, Mergers & Acquisitions, Insurance, and Financial Reporting.
He is a regular speaker at national forums (ASSOCHAM, CII, ICAI, IBBI, Legal Era) and currently serves as Co-Chairman of ASSOCHAM’s National Council on Insolvency & Valuations and a member of CII’s Task Force on Insolvency & Bankruptcy.
🤝Connect with Sahil on LinkedIn.