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CIRP Valuation Timeline: Regulation 27 and 35 Step by Step

The valuation clock in a CIRP starts before the resolution professional has the records, before the CoC is properly constituted, and often before anybody has been allowed inside...

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IBC Insolvency
Published
September 5, 2026
Last updated
Sep 28, 2026
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Last updated: September 2026Verified against: Government sources

The valuation clock in a CIRP starts before the resolution professional has the records, before the CoC is properly constituted, and often before anybody has been allowed inside the factory.

That is the central practical problem. The deadlines are measured from a fixed statutory event; the information needed to meet them arrives when it arrives.

Here is the sequence, and where it actually breaks.

The two clocks

Regulation 27 sets the appointment obligation, and it is expressed as two limits at once:

  • within seven days of the resolution professional's appointment; and
  • not later than the forty-seventh day from the insolvency commencement date.

They are not alternatives. The seven-day limit runs from your appointment; the 47-day limit runs from commencement. Where an RP is confirmed quickly, seven days binds. Where an IRP is replaced late in the process, the 47-day outer limit is what matters — and the incoming RP may have very little of it left.

Everything is anchored to the insolvency commencement date. That is also the date at which fair value and liquidation value are measured, so the anchor is doing double duty: it sets the deadline and the valuation date. Why the valuation date matters →

The sequence

Day 0 — Insolvency commencement. The Adjudicating Authority admits the application. The clock starts for everything, including the 47-day valuation limit and the overall CIRP timeline. The CIRP timeline →

Days 1–7 — Identify the asset classes. Before appointing anyone, work out which of the three classes the corporate debtor actually engages: Land and Building, Plant and Machinery, Securities or Financial Assets. Getting this wrong early is expensive — a brand-led business whose only real asset is intangible still needs a Securities and Financial Assets valuer, even though the balance sheet shows almost nothing.

Days 5–30 — Run the selection. Prospective valuers are typically asked to present to the CoC: proposed methodology, scope, timelines, fees. Three asset classes with several candidates each can mean twenty-plus presentations. Run them in parallel, not sequentially.

Before appointing — clear the independence checks. No relative of the RP or any CoC member. Nobody who was statutory auditor in the preceding five financial years. No financial interest in the outcome. Verify the VRN is current and covers the right asset class. Independence bars →

By day 47 at the latest — appoint the two sets. Each set holds one valuer per asset class, with one designated the Coordinator Valuer. Where the debtor is an MSME or has turnover up to ₹500 crore, the CoC may instead engage a single valuer — record the basis for that choice. Record the appointment, the disclosures made and the reasons for the selection in the file.

Then, before work begins in earnest — the methodology meeting. The RP convenes a meeting between the registered valuers and the CoC at which each valuer explains the methodology and key assumptions they propose to adopt. This is where divergence is actually prevented, and it is easy to skip under time pressure. If the deadline is going to be missed because records were seized or the site is inaccessible, document the reason contemporaneously. A dated explanation written on the day is worth a great deal more than a reconstruction offered nine months later at a hearing.

Days 30–75 — Physical verification and fieldwork. The estimates must be computed after physical verification of the inventory and fixed assets. This is where remote sites, workforce blockades and seized records actually consume the calendar. When workers block access →

Estimates submitted. Each valuer submits fair value and liquidation value for their asset class, computed in accordance with internationally accepted valuation standards.

Each set is consolidated. The Coordinator Valuer in each set combines the three asset-class reports into a single enterprise value, capturing synergies and going-concern items that fall outside any one class. The coordinator valuer →

If the two sets diverge by more than 25% — appoint a third valuer. Within the threshold, the average of the two aggregated estimates is taken. The 25% divergence rule →

To the CoC — electronically, under confidentiality. Fair value and liquidation value are provided to the CoC in electronic form, after the confidentiality undertaking the Code requires. Not to resolution applicants, at any stage. Confidentiality in CIRP →

Where the timeline actually breaks

Four recurring causes, none of which the Regulation makes allowance for:

Records seized by an enforcement agency. Where the ED or another agency holds the company's records, access can take months even though the RP is legally entitled to them, because the agency runs its own verification before releasing anything. Valuing when records are seized →

A shut-down debtor with no management continuity. Where the business stopped years before commencement, there is nobody to ask, no current forecast, and possibly no accessible books. Data has to be reconstructed from historical filings, regulatory submissions and creditor records.

Physical access denied. Workforce blockades pending resolution of employment dues are common in manufacturing cases, and cannot be resolved by correspondence. The RP has to settle the access problem before the valuers can start.

Remote assets. Mining operations, power plants and industrial sites in inaccessible locations need real travel and logistics. That cost is unavoidable — it cannot be substituted with a desk assessment. Why physical inspection is mandatory →

What to do about it. You cannot extend a statutory limit by wishing. What you can do is create a defensible record: minute the obstruction, the steps taken, the dates, the correspondence with the agency or the union, and the revised plan. An RP who missed day 47 with a documented reason is in a very different position from one who simply missed it.

The parallel obligations you should not sequence

Valuation is not a phase that starts when something else finishes. Three things have to run alongside it:

  • Custody documentation. Photographs, videos and site reports of all assets at the time of taking custody protect both the RP and the valuer from later allegations of asset diversion or misrepresentation. Take them at the start, not when a dispute arises.
  • Encumbrance searches. The corporate debtor's own disclosure is not a reliable inventory of charges. Independent searches — including RERA data for real estate — belong in the fieldwork, not after it.
  • Claims collation. Statutory dues and ring-fenced amounts affect both numbers, and they surface through the claims process. Statutory liabilities in valuation →

Key takeaways

  • Two clocks — 7 days from appointment, 47 days from commencement. Whichever binds first.
  • The insolvency commencement date is both the deadline anchor and the valuation date.
  • Identify asset classes before selecting valuers, or you will appoint the wrong ones.
  • Run CoC presentations in parallel — twenty is not unusual.
  • Physical verification precedes the estimate. It is not a later step.
  • Divergence brings a third valuer, and the outlier is discarded, not averaged in.
  • Document obstruction on the day it happens. That record is the defence.

Read next

Disclaimer: Positions stated as on 5 September 2026. The CIRP Regulations are amended frequently — verify the current text on ibbi.gov.in before relying on any timeline.

Quick recapKey facts & short answers

Key Facts About CIRP Valuation Timeline

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

When must valuers be appointed in a CIRP?

Within seven days of the resolution professional's appointment, and in any event not later than the forty-seventh day from the insolvency commencement date.

Does the 47-day limit restart if the IRP is replaced by an RP?

No. It runs from the insolvency commencement date, so a late replacement inherits whatever remains of it.

CIRP Valuation Timeline: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

Within seven days of the resolution professional's appointment, and in any event not later than the forty-seventh day from the insolvency commencement date.

No. It runs from the insolvency commencement date, so a late replacement inherits whatever remains of it.

No. The estimates are required to be computed after physical verification of the inventory and fixed assets. Where access is obstructed, the obstruction and the steps taken must be documented.

The obligation does not disappear. Appoint as soon as possible and maintain contemporaneous documentation of why the delay occurred — that record is what the Adjudicating Authority will look at.

After the estimates are finalised, provided electronically and subject to the confidentiality undertaking. Resolution applicants never receive them.

No. Both are measured as on the insolvency commencement date.