Registered Valuer explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
The same registration, the same registry, the same person — and two engagements that behave almost nothing alike.
A valuer who moves between Companies Act work and insolvency work without noticing the differences will get the insolvency engagement wrong, usually on process rather than method.
One registration framework — Section 247 and the Registered Valuers Rules, administered by IBBI. But under the Companies Act a single valuer is typically engaged by the company for a defined transaction; in a CIRP, two sets of valuers — each with one per asset class and a Coordinator Valuer — are appointed by the RP, work to IVS in a standardised format, produce two statutory values against a statutory deadline, and their output is confidential from the people who most want it.
Same registration, different engagement
Registration derives from Section 247 of the Companies Act, 2013 read with the Companies (Registered Valuers and Valuation) Rules, 2017, with IBBI as the specified authority. That single framework serves both worlds. Registered valuers under the Companies Act →
What changes is everything around it.
| Companies Act engagement | CIRP engagement | |
|---|---|---|
| Who appoints | The company, usually the audit committee or Board | The resolution professional |
| How many | Typically one | Two sets, each with one valuer per asset class and a Coordinator Valuer |
| What is valued | The specific subject of the transaction | Enterprise-level fair value and liquidation value of the whole estate |
| Trigger | A transaction — further issue, buy-back, scheme, non-cash consideration | Statutory, on commencement |
| Timeline | Commercial | 7 days / 47 days, statutory |
| Standards | Any recognised basis, per scope | IVS only, since 1 April 2026 |
| Report format | At the valuer's discretion | Standardised per asset class, with a VRIN on every page |
| Physical verification | Per scope | Precondition to the estimate |
| Divergence handling | Not applicable | Third valuer where the two sets vary by more than 25% |
| Who sees it | The company, its Board and members as required | CoC only, under confidentiality |
| Scrutiny | Auditors, members, occasionally a court | Adjudicating Authority, dissenting creditors, rejected applicants |
| Cooperation | Management assists | Management is displaced and often hostile |
The four differences that matter most
1. Two sets of valuers, and what happens when they disagree. A Companies Act valuation is one professional's opinion. A CIRP valuation is a pair of enterprise-level estimates, each consolidated by a Coordinator Valuer, with a statutory mechanism for divergence — where the two vary by more than 25%, a third valuer is appointed; within the threshold, the average of the two aggregated estimates goes to the CoC. That mechanic does not exist anywhere else, and it changes how you brief valuers at the outset. Where the debtor is an MSME or has turnover up to ₹500 crore, the CoC may engage a single valuer instead. The 25% divergence rule →
2. Two values, not one. Fair value and liquidation value, both measured as on the insolvency commencement date, on different assumptions about time and compulsion. Fair value vs liquidation value →
3. Confidentiality inverted. In a transaction valuation, the parties who need the number receive it. In a CIRP, the people most eager to see it — resolution applicants — must never receive it, because a bidder who knows the floor bids at it. Confidentiality in CIRP →
4. The information environment. A transaction valuer works with cooperative management and current records. A CIRP valuer often works with displaced management, seized or missing records, blocked sites and an estate nobody has controlled for years.
What carries across
Registration and asset class. Class-specific in both — a Plant and Machinery valuer cannot value land in either context. Registered valuer under IBC →
Independence. Conflict rules apply in both, with the CIRP adding the RP-and-CoC relationship bars and the five-year statutory auditor look-back. Independence and conflicts →
Section 247 liability. Fine for contravention, rising to imprisonment where there is intent to defraud, plus refund of remuneration and damages on conviction — the same exposure in both contexts. VRN, VRIN and liability →
Reporting standards. Basis of value, justified methodology, defined scope, disclosed assumptions. Good practice under the Companies Act; in insolvency, mandatory — IVS only since 1 April 2026, a standardised format per asset class, and a VRIN from the IBBI portal in the left-hand footer of every page. IVS for IBC valuations →
Key takeaways
- One registration framework, two very different engagements.
- Two sets of valuers in a CIRP, each consolidated by a Coordinator Valuer, with a statutory divergence mechanism at 25%.
- Two values, both fixed to the commencement date, both enterprise-level.
- IVS only, a standardised format and a VRIN — none of which the Companies Act engagement demands.
- Confidentiality is inverted — bidders never see the numbers.
- Statutory deadlines replace commercial ones.
- Physical verification is a precondition, not a scope choice.
- The information environment is hostile, and the report must say what that cost.
Read next
- Registered Valuer Under IBC: Appointment, Duties and Liability
- Registered Valuer Under Companies Act 2013
- Companies (Registered Valuers and Valuation) Rules, 2017
- Valuation Under IBC: The Complete Guide
Disclaimer: Positions stated as on 5 September 2026. Verify the current Rules and Regulations before relying on any requirement.