CIRP Timelines Under IBC
180 days, one 90-day extension, 330 days outer limit, and a day count for every step in between.
The Code gives a CIRP 180 days from the insolvency commencement date, one extension of up to 90 days, and an outer limit of 330 days that includes time spent in litigation (section 12). Inside that window, the CIRP Regulations set a day count for almost every step, measured from the date the interim resolution professional is appointed.
These numbers decide a large share of case-study questions. The table below is the law as at the exam cut-off of 4 February 2025, with the one model-timeline figure IBBI has since changed marked against it.
You save ₹600
- Full 65-question mocks
- Case-study practice
- Area-wise practice
One payment, no subscription · Valid for 2 months
CIRP Day Counts
T is the insolvency commencement date, on which the IRP is appointed (s. 16(1)). Regulation 40A sets these out as a model timeline.
NCLT ascertains default and admits or rejects
Time limit
14 days from receipt of the application
Source
ss. 7(4), 9(5), 10(4)
Model day
Before T
Applicant rectifies a defect
Time limit
7 days from the NCLT's notice
Source
Provisos to ss. 7(5), 9(5), 10(4)
Model day
Before T
Public announcement
Time limit
Within 3 days of IRP appointment
Source
Reg. 6(1)
Model day
T+3
Last date for claims
Time limit
14 days from IRP appointment
Source
Reg. 6(2)(c), 12(1)
Model day
T+14
Verification of claims
Time limit
7 days from the last date for claims
Source
Reg. 13(1)
Model day
T+21
Report certifying constitution of CoC
Time limit
2 days from verification
Source
Reg. 17(1)
Model day
T+23
First CoC meeting
Time limit
7 days from filing that report
Source
Reg. 17(2), s. 22(1)
Model day
T+30
IRP acts as RP if no RP yet
Time limit
From day 40
Source
Reg. 17(3)
Model day
T+40
Appointment of registered valuers
Time limit
7 days from RP appointment, no later than day 47
Source
Reg. 27
Model day
T+47
Invitation for expression of interest
Time limit
No later than day 60
Source
Reg. 36A(1)
Model day
T+60
RP's opinion on avoidance transactions
Time limit
Within 75 days
Source
Reg. 35A
Model day
T+75
Information memorandum to CoC
Time limit
Within 95 days
Source
Reg. 36(1)
Model day
T+95
Submission of CoC-approved plan to NCLT
Time limit
Model timeline
Source
Reg. 40A
Model day
T+165 at cut-off; T+150 from 2 June 2026
Approval of plan by NCLT
Time limit
Model timeline
Source
Reg. 40A, s. 31(1)
Model day
T+180
| Activity | Time limit | Source | Model day |
|---|---|---|---|
| NCLT ascertains default and admits or rejects | 14 days from receipt of the application | ss. 7(4), 9(5), 10(4) | Before T |
| Applicant rectifies a defect | 7 days from the NCLT's notice | Provisos to ss. 7(5), 9(5), 10(4) | Before T |
| Public announcement | Within 3 days of IRP appointment | Reg. 6(1) | T+3 |
| Last date for claims | 14 days from IRP appointment | Reg. 6(2)(c), 12(1) | T+14 |
| Verification of claims | 7 days from the last date for claims | Reg. 13(1) | T+21 |
| Report certifying constitution of CoC | 2 days from verification | Reg. 17(1) | T+23 |
| First CoC meeting | 7 days from filing that report | Reg. 17(2), s. 22(1) | T+30 |
| IRP acts as RP if no RP yet | From day 40 | Reg. 17(3) | T+40 |
| Appointment of registered valuers | 7 days from RP appointment, no later than day 47 | Reg. 27 | T+47 |
| Invitation for expression of interest | No later than day 60 | Reg. 36A(1) | T+60 |
| RP's opinion on avoidance transactions | Within 75 days | Reg. 35A | T+75 |
| Information memorandum to CoC | Within 95 days | Reg. 36(1) | T+95 |
| Submission of CoC-approved plan to NCLT | Model timeline | Reg. 40A | T+165 at cut-off; T+150 from 2 June 2026 |
| Approval of plan by NCLT | Model timeline | Reg. 40A, s. 31(1) | T+180 |
The Three Outer Limits in Section 12
- 180 days
- The basic CIRP period, counted from the insolvency commencement date (s. 12(1)). The public announcement must state the 180th day as the closing date (s. 15(1)(f)).
- Up to 90 more days
- The RP applies for an extension if the CoC so resolves by 66% of voting share. The NCLT may grant up to 90 days, and only once (s. 12(2), (3)).
- 330 days
- The outer limit including the extension and time taken in legal proceedings, added in 2019 (second proviso to s. 12(3)). In Essar Steel (2019) the Supreme Court struck down the word "mandatorily": 330 days is ordinarily the limit, but the NCLT or NCLAT may allow more where only a short period remains and the delay is not the litigants' fault.
Late Claims
A creditor who misses the last date may still file, with proof, up to the date the request for resolution plans is issued or 90 days from commencement, whichever is later, giving reasons for any delay beyond 90 days (proviso to reg. 12(1)). The older standalone 90-day row was removed from the model timeline in September 2024, before the exam cut-off.
Quick practice on company law. No signup.
New Time Limits From 26 May 2026
All added by the IBC (Amendment) Act, 2026. None of them is in the exam's cut-off law. In each case, the tribunal must record reasons in writing if it misses the deadline.
Admission of a s. 7 application
New limit
NCLT shall admit within 14 days if default is established and the application is complete; no other ground to reject
Section
s. 7(5) (substituted)
Order on a s. 12A withdrawal
New limit
Within 30 days of the application
Section
s. 12A(3)
Order on a resolution plan
New limit
Within 30 days of receiving it
Section
s. 31(2A)
Liquidation order
New limit
Within 30 days of the intimation or application
Section
s. 33(2A)
Restored CIRP
New limit
Up to 120 days, allowed only once
Section
s. 33(1A), (1B)
NCLAT appeal
New limit
Disposed of within 3 months of receipt
Section
s. 61(6)
| Event | New limit | Section |
|---|---|---|
| Admission of a s. 7 application | NCLT shall admit within 14 days if default is established and the application is complete; no other ground to reject | s. 7(5) (substituted) |
| Order on a s. 12A withdrawal | Within 30 days of the application | s. 12A(3) |
| Order on a resolution plan | Within 30 days of receiving it | s. 31(2A) |
| Liquidation order | Within 30 days of the intimation or application | s. 33(2A) |
| Restored CIRP | Up to 120 days, allowed only once | s. 33(1A), (1B) |
| NCLAT appeal | Disposed of within 3 months of receipt | s. 61(6) |
How the Limited Insolvency Examination Tests This
Timeline questions give dates, not day numbers. A case study might say the NCLT admitted the application on 3 March and the IRP published the announcement on 9 March: you must count, and see that the 3-day limit was missed. Anchor every count to the right start point, which is IRP appointment for the regulation steps and the insolvency commencement date for section 12.
The usual trap is treating the model timeline in regulation 40A as binding throughout. Some rows simply restate a binding limit set elsewhere (announcement, claims, verification, CoC report). The plan-submission and approval rows are a model. Equally, do not treat 330 days as absolute after Essar Steel.
FAQs
What is the CIRP timeline under IBC?expand_more
180 days from the insolvency commencement date, extendable once by up to 90 days on a 66% CoC vote, within an outer limit of 330 days that includes time spent in litigation (section 12).
Is the 330-day limit mandatory?expand_more
Ordinarily yes, but not absolutely. In Essar Steel the Supreme Court struck down the word "mandatorily" and allowed the tribunals to extend time in exceptional cases where the delay is not the litigants' fault.
Within how many days must the IRP make the public announcement?expand_more
Within 3 days of appointment (regulation 6(1)). The last date for claims is 14 days from the IRP's appointment.
Did the 2026 amendment change the 180 and 330 day limits?expand_more
No. Section 12 was not amended. The 2026 Act added deadlines for the NCLT and NCLAT and a one-time restoration of up to 120 days, in force from 26 May 2026.
Next steps
- CIRP Stepsarrow_forward
- Committee of Creditorsarrow_forward
- Essar Steel casearrow_forward
- IBC Amendment 2026arrow_forward
65 questions, case-study format, negative marking.