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Regulation 27: Appointing Registered Valuers in a CIRP

The RP's appointment obligation under Regulation 27 - two sets of valuers with a coordinator in each, the 7-day and 47-day limits, the MSME relief, and the...

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IBC Insolvency
Published
September 5, 2026
Last updated
Sep 29, 2026
Reading time
6 min
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Last updated: September 2026Verified against: Government sources

Regulation 27 is short, and almost every word in it is a deadline or a constraint.

It is also the provision an RP is most likely to breach in their first month — not through carelessness, but because the clock runs from an event that happened before they had the company's records.

What the Regulation requires

The resolution professional appoints registered valuers to determine the fair value and the liquidation value of the corporate debtor in accordance with Regulation 35 —

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

Since the February 2026 reforms, the structure is two sets. Each set holds one valuer for each asset class, and within each set one of the three is designated the Coordinator Valuer, who consolidates that set into a single enterprise value.

Who appointsThe resolution professional
StructureTwo sets, each with one valuer per asset class
Asset classesLand and Building; Plant and Machinery; Securities or Financial Assets
Within each setOne designated Coordinator Valuer
Small debtorsMSME or turnover up to ₹500 crore — CoC may use a single valuer
Inner limit7 days from the RP's appointment
Outer limit47 days from the insolvency commencement date
PurposeDetermine fair value and liquidation value under Regulation 35

The two sets produce two aggregated fair values, which the RP averages into the single figure placed before the CoC. How the coordinator role works →

Why two limits, and which one bites

The two clocks start at different events, and that is deliberate.

Seven days from the RP's appointment stops an RP sitting on the obligation. Forty-seven days from commencement stops the obligation being deferred indefinitely by delays in confirming the RP.

Where the CoC confirms the RP quickly, the seven-day limit is the operative one. Where an IRP is replaced late, the incoming RP inherits whatever remains of the 47 days — sometimes very little. That is the scenario worth planning for, because the new RP is simultaneously taking custody, collating claims and constituting the CoC.

Everything is anchored to the insolvency commencement date, which is also the date at which both values are measured. The full timeline →

Getting the asset classes right first

Before appointing anyone, decide which classes the corporate debtor actually engages. This sounds mechanical and is where real errors originate.

  • A manufacturer with owned premises engages all three — land, plant, and receivables or investments.
  • A services business with leased offices may engage Plant and Machinery (furniture, IT equipment) and Securities or Financial Assets, and no Land and Building at all.
  • A brand-led business whose balance sheet shows almost nothing still needs a Securities or Financial Assets valuer, because intangibles live in that class. Skipping it because "there are no assets" is how brand value goes unvalued. Intangibles under IBC →

A valuer registered for one class cannot value another. Registration is class-specific, and a report outside the registered class has no legal footing. Registered valuer under IBC →

The disqualifications to clear before you appoint

Run these checks and record that you ran them:

  • Not a relative of the resolution professional or of any CoC member.
  • Not the statutory auditor of the corporate debtor in any of the preceding five financial years.
  • Not a partner or director of the entity the RP is associated with.
  • No direct or indirect financial interest in the outcome of the process.
  • VRN current, and covering the correct asset class.

The five-year auditor bar is the one most often missed, because it requires looking back beyond the current engagement. Independence and conflicts →

The selection process nobody writes into the calendar

In practice, valuers are not simply appointed. Candidates present to the CoC — proposed methodology, scope, timelines and fees — before selection.

Three asset classes with three or four candidates each means twenty or more presentations, all inside the same window in which the RP is also taking custody of assets, publishing the public announcement, collating claims and constituting the CoC.

The only way this fits is to run the classes in parallel rather than sequentially, and to start compiling the candidate list in the first days rather than after the CoC's first meeting.

When the deadline genuinely cannot be met

Sometimes it cannot. Records seized by an enforcement agency, a factory under a workforce blockade, a debtor that stopped trading years ago with no management continuity — none of these are curable inside 47 days.

The Regulation makes no allowance for it. What protects the RP is contemporaneous documentation:

  • what was attempted, and on which dates;
  • the correspondence with the agency, the union or the promoter;
  • the reason each step could not be completed;
  • the revised plan and the date it was executed.

An RP who missed the deadline with a dated, reasoned record is in a very different position from one who produces an explanation months later at a hearing. Write it on the day. Valuing when records are seized →

Key takeaways

  • Two sets, each with one valuer per class — six appointments, with a coordinator in each set.
  • MSME or turnover up to ₹500 crore — the CoC may use a single valuer.
  • Both limits apply. Whichever expires first is the one that binds.
  • A late-appointed RP inherits the remainder of the 47 days, not a fresh clock.
  • Decide asset classes before selecting valuers.
  • A brand-led debtor still needs a Securities and Financial Assets valuer.
  • The five-year auditor bar is the independence check most often missed.
  • Document obstruction on the day it happens.

Read next

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

Quick recapKey facts & short answers

Key Facts About Regulation 27

  • 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.

How many valuers must be appointed in a CIRP?

Two sets, each containing one valuer per asset class engaged — so six where all three classes apply. Where the debtor is an MSME or has turnover up to ₹500 crore, the CoC may engage a single valuer instead.

What are the Regulation 27 deadlines?

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.

Regulation 27: 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.

Two sets, each containing one valuer per asset class engaged — so six where all three classes apply. Where the debtor is an MSME or has turnover up to ₹500 crore, the CoC may engage a single valuer instead.

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 replacement RP inherits what remains of it.

Only if separately registered for each. Registration is class-specific.

A relative of the RP or a CoC member, the corporate debtor's statutory auditor in the preceding five financial years, a partner or director of the RP's entity, or anyone with a financial interest in the outcome.

Appoint as soon as possible and maintain contemporaneous documentation of why the delay occurred. The obligation itself does not lapse.