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Legal Chronicle

June 2026

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The Insolvency and Bankruptcy Code (Amendment) Act, 2026: Key Reforms and Implications

Dear Reader,

The Legal Department at UJA is pleased to present this edition of Legal Chronicle, aimed at keeping readers informed about recent legal developments. In this edition, Legal Chronicle examines the key reforms introduced under the Insolvency and Bankruptcy Code (Amendment) Act, 2026, and their implications for corporate restructuring, insolvency resolution, creditor rights and the broader insolvency framework in India.

We hope that this edition creates a sense of enthusiasm for our readers and successfully delivers the plethora of legal knowledge as intended. In case you have any feedback or need us to include any information to make this issue more informative, please feel free to write to us at legal@uja.in.

Introduction

The Insolvency and Bankruptcy Code (Amendment) Act, 2026 (hereinafter referred to as the “Act”), enacted in April 2026, marks an evolution in India’s corporate restructuring landscape. The amendment represents one of the most significant reforms to the insolvency framework since the enactment of the Insolvency and Bankruptcy Code (IBC) in 2016, addressing concerns relating to delays in admission and resolution, liquidation inefficiencies, creditor recoveries and introducing new mechanisms for creditor-led restructuring.

The Ministry of Corporate Affairs issued a notification under section 1(2) of the Act, bringing a substantial part of the amended framework into force on May 26th, 2026. The notification gives effect to key procedural and substantive changes, including sections 2 to 6, 8 to 33, 35 to 39, 48 to 59, and 61 to 66, as well as select clauses of sections 34, 69 and 70 (excluding sub-clause (xx) of section 70(b)). These changes streamline the revised IBC framework, help reduce litigation delays and strengthen India’s credit ecosystem.

Key Highlights of The Amendment

Corporate Insolvency Resolution Process (CIRP)

  • Mandatory Admission of Application by NCLT:
    The Act requires the Adjudicating Authority to admit or reject a financial creditor’s application to initiate the Corporate Insolvency Resolution Process (CIRP) within 14 days of receipt. Once debt and default are established and there are no disciplinary proceedings against the proposed Interim Resolution Professional (IRP), the National Company Law Tribunal (NCLT) cannot consider any other factor. For financial institutions, a record of default from an information utility is sufficient proof of default. If the Adjudicating Authority does not decide the application within 14 days, it must record written reasons for the delay.
  • Restoration of CIRP:
    The Act provides for restoration of CIRP if no resolution plan has been received within the maximum period of CIRP or a resolution plan is rejected, before passing a liquidation order. The NCLT may, after 66% approval of the Committee of Creditors (CoC), restore the CIRP in case of no resolution plan from the initial stages and in the case of rejection, from the stage of invitation of resolution plans. However, this is a one-time restoration with a maximum period of 120 days to complete the restoration process. Failure to submit a resolution plan within the extended period would trigger NCLT to pass a liquidation order.
  • Two-Stage Approval of a Resolution Plan:
    The Act allows the Adjudicating Authority to approve the implementation of a resolution plan first and, within 30 days by a separate order, approve the distribution plan. This power may be exercised only on an application made by the Resolution Professional (RP) with the approval of the CoC. Once implementation is approved, the plan becomes binding on all stakeholders, and the moratorium under section 14 continues until the distribution is finally approved and completed. The Act also requires the resolution plan to provide for a committee to oversee implementation and supervision, comprising the RP or another insolvency professional, representatives of one or more classes of creditors and the resolution applicant.
  • Dissenting Financial Creditors:
    The Act also requires that the resolution plan must provide for dissenting financial creditors to receive not less than the lower liquidation value of such a creditor or its entitlement under the resolution plan applying the liquidation waterfall. The amendment expressly clarifies that such treatment shall be deemed fair and equitable to dissenting financial creditors.
  • Withdrawal of CIRP Applications:
    The withdrawal of admitted applications is allowed only after the constitution of Committee of Creditors (CoC) with 90% approval from the CoC. Withdrawal cannot be done after the first invitation for Resolution Plan is issued. The Adjudicating Authority must dispose of the withdrawal application within 30 days and reasons to be recorded in case of delay.
  • Avoidance Transactions and Fraudulent / Wrongful Trading:
    The amendment clarifies that proceedings relating to avoidance transactions and fraudulent or wrongful trading can continue even after completion of the insolvency resolution or liquidation process. The law also allows creditors, members or partners to approach the Adjudicating Authority if such transactions are not reported by the resolution professional or liquidator.

Liquidation

The Act has clarified that an RP appointed during the CIRP shall not automatically switch into the role of liquidator. Instead, the appointment of the liquidator is undertaken through a controlled mechanism involving the CoC, the Adjudicating Authority and the Insolvency and Bankruptcy Board of India (IBBI). While the CoC preserves a vital role in proposing and, wherever necessary, replacing the liquidator with 66% voting, the final appointment is dependent upon the confirmation and recommendation involving the IBBI. The Act provides that the NCLT must pass a liquidation order within 30 days of application or intimation. It also states that liquidation proceedings must be completed within 180 days, with an extension of up to 90 days.

The Code permits a company to voluntarily initiate liquidation, subject to compliance with the prescribed requirements. The Act requires such proceedings to be completed within one year and appeals before the NCLAT to be decided within three months.

Introduction Of Creditor-Initiated Insolvency Resolution Process (CIIRP)

The Act also introduced a new creditor-led insolvency resolution process. It allows creditors to initiate insolvency directly, subject to specified approval thresholds and procedural safeguards. This adds flexibility, reduces reliance on formal admission stages and makes the process more responsive. Some of the key features are:

  • It is available for corporate debtors that meet notified thresholds of assets or income or belong to the notified class of creditors. If a default occurs, a financial creditor from the notified class may, with the approval of 51% of that class of creditors, notify the corporate debtor of its intention to appoint a resolution professional.
  • The corporate debtor may submit a representation within 30 days. After considering the response, the financial creditor may appoint the resolution professional, subject to approval by 51% of the notified class of creditors, within 30 days of receiving the response.
  • The corporate debtor may challenge the commencement of CIIRP. The NCLT may declare the process void if no default has occurred or convert it into a CIRP if a default is established.
  • Fraudulent management of the affairs of the corporate debtor during CIIRP may make the officers of the corporate debtor liable for a penalty of up to INR 1 Crore.
  • CIIRP must be completed within 150 days. The NCLT may extend this period by up to 45 days upon approval by 66% of the CoC by value.
  • If no resolution plan is received within 150 days, if a plan is rejected, or if the corporate debtor’s directors or personnel fail to cooperate with the RP, the NCLT shall order conversion of the CIIRP into a CIRP, along with any consequential directions.
  • The CoC may also decide at any stage to seek an NCLT order converting the CIIRP into a CIRP. A resolution plan needs to be approved by 66% by value of the CoC and then the NCLT.

Group Insolvency

  • The Act authorizes the central government to prescribe rules for insolvency proceedings against two or more corporate debtors that form part of a group in respect of which insolvency processes have been commenced. The rules may provide for a common bench for all such corporate debtors, coordination between such proceedings, common insolvency professional and a common CoC.

    It is pertinent to note that the amendment presently contains only enabling provisions and does not itself establish a comprehensive group insolvency framework. The detailed procedural and operational aspects remain subject to future rules and notifications issued by the Central Government.

Cross-Border Insolvency

The Act has also introduced an enabling provision for cross-border insolvency, vesting the Central Government with the power to prescribe rules for administering and conducting cross border insolvency proceedings including for recognition of insolvency proceedings of companies registered outside India. The proposal also includes designation of special benches to deal with cross-border insolvency cases. While this marks a significant step towards addressing multinational insolvency situations, the amendment does not presently establish a comprehensive cross-border insolvency regime and instead creates an enabling framework under which detailed rules may be notified in the future.

Implications

The amendments are expected to have significant implications for stakeholders across the insolvency ecosystem:

  1. Financial creditors may benefit from faster commencement of insolvency proceedings owing to the stricter timelines prescribed for admission of applications and the introduction of the Creditor-Initiated Insolvency Resolution Process (CIIRP).
  2. Corporate debtors may face increased pressure to engage with creditors at an earlier stage, given the enhanced creditor-led mechanisms introduced under the Act.
  3. Resolution applicants may benefit from greater certainty and continuity in the implementation of approved resolution plans through the introduction of the two-stage approval framework.
  4. The strengthened role of the Committee of Creditors during liquidation is expected to enhance accountability and oversight throughout the insolvency process.
  5. The enabling provisions relating to group insolvency and cross-border insolvency signal the Government’s intent to align India’s insolvency framework with evolving international restructuring practices.

Conclusion

The IBC (Amendment) Act, 2026 marks the next phase in the evolution of India’s insolvency framework. While the practical impact of several reforms will become clearer through implementation and judicial interpretation, the amendment reflects the legislature’s continued effort to refine and modernize the insolvency regime in response to emerging commercial realities.

Disclaimer

This document is intended to provide general information and is not intended to be substituted for any legal or professional advice. This document is meant exclusively for informational purposes and not for advertising or solicitation. UJA has made significant efforts to ensure that the information contained in this document is accurate and reliable. However, the information herein is provided “as is” without warranty of any kind. UJA hereby disclaims all responsibility and liability, whether stated or implied, for the accuracy, validity, adequacy, reliability or completeness of any information provided under this document. In no event shall UJA be held liable for any losses or damages whatsoever incurred as a result of using this document.

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