By S&S Co. Advocates & Solicitors · Published 29 September 2026 · Informational content, not legal advice: see our disclaimer
Overview
A guide for a practising or aspiring insolvency professional explaining the regulatory role of Insolvency Professional Agencies under the IBC, the compliance and reporting obligations IPs owe to their IPA and the IBBI, and the disciplinary framework that applies to lapses.
What You Need to Know
- Every insolvency professional must be enrolled with a registered Insolvency Professional Agency (IPA) and separately registered with the Insolvency and Bankruptcy Board of India (IBBI). The IPA functions as a self-regulatory front-line body responsible for professional development, monitoring and grievance redressal of its enrolled members.
- IPAs are required to maintain a Code of Conduct for their members, covering matters such as independence, conflict of interest, confidentiality and professional competence, and to monitor compliance through periodic inspections, review of CIRP filings, and examination of complaints received against an insolvency professional.
- An insolvency professional owes ongoing reporting obligations independent of any specific creditor's satisfaction with their conduct, including timely filing of CIRP progress reports, disclosure of relationships that may give rise to a conflict of interest, and maintenance of records supporting claims verification and the resolution plan process.
- Disciplinary proceedings for non-compliance may be initiated either by the IPA's own Disciplinary Committee or by the IBBI directly, and can result in a range of outcomes from a written warning, through suspension of registration for a defined period, to cancellation of registration in serious or repeated cases.
- Insolvency professionals should treat their IPA's Code of Conduct and reporting calendar as a distinct compliance track running parallel to their duties toward the Committee of Creditors and the adjudicating authority. Satisfying one does not automatically satisfy the other, and lapses in regulatory reporting carry independent disciplinary exposure.
Frequently Asked Questions
What is the role of an Insolvency Professional Agency?
An IPA is a self-regulatory body registered with the IBBI that enrols, monitors and disciplines insolvency professionals, maintains a Code of Conduct for its members, and handles complaints and grievances relating to their conduct.
Can an insolvency professional be disciplined even if the Committee of Creditors has no complaint against them?
Yes: an insolvency professional's regulatory reporting and compliance obligations to the IPA and IBBI are independent of the CoC's satisfaction with their overall conduct of the CIRP, and lapses can attract disciplinary action on that separate basis.
What outcomes can result from an IPA disciplinary proceeding?
Outcomes can range from a written warning to suspension of registration for a defined period, up to cancellation of registration in serious or repeated cases of non-compliance.
References & Further Reading
This guide references the following statutes, rules and sources, cross-checked at the time of writing.
- Dual enrolment/registration structure (IPA and IBBI) and the IPA's self-regulatory monitoring role: well-settled regulatory framework, confirmed via IBBI regulations and IPA Model Bye-Laws commentary at research time
- Independent nature of IP reporting obligations and the disciplinary outcomes available: confirmed via our companion Legal News coverage of an IPA disciplinary order and IBBI regulatory commentary at research time
- See also our IBC & Insolvency Notable Judgments and Legal Updates: IBC & Insolvency archive.