Regulation 35 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.
Regulation 27 says who values. Regulation 35 says how the number is arrived at — and that mechanism was substantially rebuilt in February 2026.
If your understanding of it is "two valuers per asset class, three figures to the CoC, average the two closest if they disagree", it is out of date.
Two sets of registered valuers, each with one valuer per asset class and one designated Coordinator Valuer who consolidates the set into a single enterprise value. Estimates are computed to IVS, after physical verification. The RP averages the two aggregated values and gives the CoC one number. A third valuer comes in where the variance between the sets exceeds 25%.
The determination, step by step
1. Two sets are appointed. Each set contains a Land and Building valuer, a Plant and Machinery valuer, and a Securities or Financial Assets valuer. Regulation 27 appointment →
2. Each valuer values their class, computing estimates in accordance with International Valuation Standards — mandatory since 1 April 2026 — and after physical verification of the inventory and fixed assets. IVS for IBC valuations →
3. The Coordinator Valuer consolidates. Within each set, the designated coordinator combines the three asset-class reports into one comprehensive enterprise value, capturing intangible synergies and going-concern items that fall outside any individual class — carry-forward losses, customer relationships, self-generated brand value.
4. The RP averages the two. Two sets produce two aggregated fair values. The RP averages them and places a single figure before the CoC, rather than three asset-class numbers.
5. Third valuer if the variance exceeds 25%. Where the two sets' fair value and liquidation value estimates differ by more than 25%, a third valuer is appointed. Within the threshold, the average of the two aggregated estimates stands. The 25% rule →
6. Delivery to the CoC — electronically, on the confidentiality undertaking. Never to resolution applicants. Confidentiality in CIRP →
What "fair value" now means here
The definition carries an explanation requiring the total estimated realisable value of all the assets of the corporate debtor, expressly including tangible and intangible assets together with their underlying synergies.
That is what makes the coordinator role necessary. Sum-of-the-parts arithmetic cannot produce a number that includes synergies, because synergies do not live in any asset class. Synergies in fair value →
Liquidation value remains the realisable value on a distressed, piecemeal basis as on the insolvency commencement date. Both values remain fixed to that date. Fair value vs liquidation value →
The two conditions on every estimate
"After physical verification." A precondition, not a preference. Mandatory for Land and Building and Plant and Machinery valuers, and for Securities and Financial Assets valuers wherever inventory forms part of the scope of work. An SFA valuer with no inventory in scope retains flexibility to work without a site visit. Why desk valuation fails →
"International Valuation Standards." Since 1 April 2026, IVS only. The earlier latitude to adopt any internationally accepted methodology, or a standard issued by a particular RVO, has been removed — because two valuers each correctly following a different recognised standard could honestly reach materially different answers.
The methodology meeting
A procedural safeguard that sits ahead of all of this and is easy to overlook.
The RP must convene a meeting between the registered valuers and the CoC before valuation work begins in earnest, at which each valuer explains the methodology and key assumptions they propose to adopt.
Where the CoC perceives a material difference in approach between valuers at that stage, it can raise and discuss it before the numbers are finalised. The premise is straightforward: estimates diverge far less once methodologies are aligned up front.
For the CoC this cuts both ways — it is an opportunity, and it is also an expectation that members engage with the valuation process more substantively than simply receiving a figure at the end. CoC commercial wisdom →
What the CoC should receive with the number
One aggregated figure is more usable than three, but only if the build-up is visible. Alongside the value:
- how the enterprise number was built from the three asset-class reports;
- the methodology adopted for each class and why;
- assumptions, particularly where data was unavailable;
- discounts and premia applied, with reasoning;
- sensitivity analysis showing how the value moves;
- ESG factors considered;
- treatment of encumbrances, statutory dues and ring-fenced assets.
Most of that is now required by the standardised reporting format rather than left to the valuer's discretion. Assumptions and sensitivity →
Key takeaways
- Two sets, not two valuers per class.
- A Coordinator Valuer in each set produces one enterprise value.
- The RP averages the two aggregated values — the CoC gets one number.
- Third valuer where variance between the sets exceeds 25%.
- IVS is mandatory since 1 April 2026.
- Physical verification extends to SFA valuers where inventory is in scope.
- The pre-valuation methodology meeting is where divergence is actually prevented.
Read next
- Regulation 27: Appointing the Valuers in a CIRP
- The Coordinator Valuer and Aggregated Fair Value
- The 25% Divergence Rule and the Third Valuation
- Valuation Under IBC: The Complete Guide
Disclaimer: Positions stated as on 5 September 2026 and reflect the February 2026 amendments to the CIRP and Liquidation Process Regulations. Verify the current text on ibbi.gov.in.