Registered Valuers 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.
Valuation is not a single exercise under the Code. Six different processes require it, each with its own regulation, its own number of valuers and its own definition of the value to be found.
The six processes
| Process | Provision |
|---|---|
| Corporate Insolvency Resolution Process | Regulations 27 and 35 |
| Pre-packaged Insolvency Resolution Process | Regulations 38 and 39 |
| Compulsory liquidation | Regulation 35 |
| Fast Track CIRP | Regulations 26 and 34 |
| Voluntary liquidation | Section 59(3)(b)(ii) |
| Individual bankruptcy | Regulation 30 |
The differences between them are not cosmetic. A CIRP requires two registered valuers and produces fair value and liquidation value; a fast track CIRP requires one; a liquidation may reuse the CIRP figures or commission a fresh estimate of realisable value; and an individual bankruptcy asks only for realisable value with a second valuer at the trustee's discretion.
The three asset classes
The IBBI has established classifications for registered valuers based on asset type, and each carries its own qualification and experience requirement.
| Asset class | Qualifications | Experience |
|---|---|---|
| Land and Building | Graduate in Civil Engineering, Architecture or Town Planning; or postgraduate in a related field | 5 years for graduates, 3 years for postgraduates |
| Plant and Machinery | Graduate in a relevant engineering field or a degree in Valuation of Plant and Machinery; or postgraduate in a related field | 5 years for graduates, 3 years for postgraduates |
| Securities or Financial Assets | Member of ICAI, ICSI or ICMAI; or MBA / postgraduate in Finance | 3 years in relevant fields |
A person is not a registered valuer at large. Registration is for a particular asset class, which means the resolution professional's appointment decision is really a mapping exercise: what does the corporate debtor own, and which classes does that span?
A manufacturing company with freehold land, a plant and a portfolio of subsidiary shareholdings spans all three classes. Appointing "two registered valuers" without checking the classes they hold produces a valuation that is unsupported for part of the estate — and a fair value and liquidation value the committee cannot safely rely on.
Why the differences between processes exist
- A CIRP produces a plan that creditors vote on, so it needs both the going-concern reference point (fair value) and the downside (liquidation value), each corroborated by two independent registered valuers.
- A fast track CIRP deals with smaller and simpler debtors, so one valuer suffices and the cost is proportionate.
- A PPIRP compresses the timeline — valuers are appointed within three days rather than seven — because the whole process is designed to move quickly.
- A liquidation is concerned with what the assets will actually fetch, so the enquiry is realisable value of the assets or businesses.
- A voluntary liquidation is of a solvent company, so a single valuation report of the assets accompanies the declaration.
- An individual bankruptcy deals with a person's estate, so a single valuer suffices unless the trustee thinks otherwise.
The disqualifications are common to the processes
Across a CIRP, a PPIRP and a fast track CIRP the same four persons cannot be appointed as registered valuers:
- a relative of the resolution professional;
- a related party of the corporate debtor;
- an auditor of the corporate debtor at any time during the five years preceding the insolvency commencement date; or
- a partner or director of the insolvency professional entity of which the resolution professional is a partner or director.
The third is the one most often overlooked, and it has the longest reach. A firm that audited the corporate debtor four years ago is disqualified, however unconnected the valuation team may be from the audit engagement.
Practical points
- Map the estate to asset classes before shortlisting registered valuers.
- Run the four-limb disqualification check, including the five-year audit history.
- Diarise the appointment deadline for the process you are in — it differs between a CIRP, a PPIRP and a liquidation.
- Record why each valuer was chosen; the appointment is as reviewable as the valuation.
Common mistakes
- Treating registration as general rather than class-specific.
- Applying the CIRP requirement of two valuers to a fast track process, or the reverse.
- Missing the auditor disqualification because the audit was some years ago.
- Commissioning fair value in a liquidation, where the enquiry is realisable value.