How Creditors Submit Claims in CIRP — Form B & Form C (Samples)

How Creditors Submit Claims in CIRP — Form B & Form C (Samples)

A practical guide for banks, NBFCs, suppliers, MSMEs, homebuyers and other creditors dealing with NCLT Hyderabad CIRPs

Introduction

How creditors submit claims in CIRP is the step that decides whether you sit in the Committee of Creditors, get a payout under a resolution plan, or watch the process from outside. After NCLT admits a company into Corporate Insolvency Resolution Process, the Interim Resolution Professional publishes a public announcement and calls for proofs of claim.

Operational creditors generally use Form B. Financial creditors generally use Form C. Homebuyers and other creditors in a class use Form CA. The form is not a recovery suit. It is a statutory proof of what was due on the insolvency commencement date.

This article explains which form to use, what documents to attach, the 14-day window in the public announcement, the later Regulation 12 buffer, what the IRP or RP can do with your claim, and how to challenge a rejection before NCLT Hyderabad if the corporate debtor’s registered office is in Telangana. IBBI notified refreshed CIRP formats by circular dated 2 June 2026. Download the live form from ibbi.gov.in before you file — the field labels below are a working guide, not a substitute for the official circular.

When this issue applies

You need Form B or Form C only after CIRP has started. That happens when NCLT admits an application under Section 7 (financial creditor), Section 9 (operational creditor) or Section 10 (corporate applicant). The admission order appoints an IRP and triggers a moratorium under Section 14.

Typical readers who must act quickly:

• A bank or NBFC that already filed Section 7 — you still file Form C so your voting share is computed.
• A supplier, contractor, landlord or professional with unpaid invoices — Form B.
• A homebuyer or deposit-holder in a class — Form CA, not Form C.
• A guarantor-creditor or assignee of a financial debt — usually Form C, with security and assignment papers.
• A statutory authority with tax or cess dues — usually Form B as an operational creditor, unless a later notification says otherwise. Classification disputes are fact-specific.

Pre-pack (PPIRP) for MSMEs and the 2026 creditor-initiated process (CIIRP) use different claim machinery. Do not mix those forms with a standard CIRP.

Form B vs Form C vs the other claim forms

IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016 still use the familiar form names. From 2 June 2026 the regulations say the Board will notify the format by circular, instead of locking the text only in an old Schedule. Circular IBBI/CIRP/94/2026 dated 2 June 2026 is the current reference — verify on the IBBI website before use.

Who you are	Form & regulation	How to send it
Operational creditor (not workman/employee)	Form B — Regulation 7	In person, by post, or by email / electronic means
Financial creditor (not in a class)	Form C — Regulation 8	Electronic means only
Financial creditor in a class (homebuyers, depositors)	Form CA — Regulation 8A	Through / as provided for the class; electronic in practice
Workman or employee	Form D — Regulation 9	In person, post or electronic
Authorised representative of workmen/employees	Form E — Regulation 9	As specified in the announcement
Other creditors (neither FC nor OC)	Form F — Regulation 9A	In person, post or electronic

Choosing the wrong form is a common reason for delay. A trade supplier is not a financial creditor merely because interest is printed on the invoice. A loan with time value of money is not an operational debt merely because the borrower also bought goods. If the classification is arguable, state the basis in the covering email and keep documents ready for an NCLT application under Section 60(5).

The clock: public announcement, 14 days, and the Regulation 12 buffer

What the public announcement does

Section 13 and Section 15 of the Code, read with Regulation 6, require the IRP to issue a public announcement (Form A) within three days of appointment. It is published in one English and one regional-language newspaper at the registered office and other material places, on the company website if any, and on the IBBI-designated website.

Form A names the IRP, the email for claims, and the last date. That last date is fourteen days from the date of appointment of the IRP — not fourteen days from the newspaper you happened to see.

If you miss the 14-day date

Regulation 12, as amended in recent CIRP amendment cycles, is the provision that matters. The working position to check on the date you file is this:

• First duty: file on or before the last date printed in Form A.
• If you miss that date, you may still submit the claim with proof up to the later of (a) ninety days from the insolvency commencement date, or (b) the date the request for resolution plans is issued under Regulation 36B.
• If the claim goes beyond ninety days from the insolvency commencement date, give reasons for the delay.
• Claims that arrive even later may still be verified and marked acceptable or not, up to about seven days before the CoC meeting that votes on the plan or before liquidation is initiated — see Regulation 13(1B). That is a residual, high-risk window, not a planning tool.

To be verified before you rely on a late filing: the exact current text of Regulation 12 and 13 after the June 2026 CIRP amendments, and whether a resolution plan has already been approved by the CoC. Once a plan is approved by NCLT, late claims are usually shut out because an approved plan binds all creditors, including those who did not file — the principle associated with Ghanashyam Mishra & Sons (Supreme Court, 2021).

What date is the claim valued on?

Claims are proved as on the insolvency commencement date — the date of the admission order. Interest after that date is generally not added into the CIRP claim for voting or plan purposes unless the plan itself provides for it. Foreign-currency claims are converted at the official RBI reference rate on the insolvency commencement date.

Step-by-step: how to file Form B or Form C

1. Read the NCLT admission order and the Form A public announcement. Note the insolvency commencement date, IRP name, registration number, and the claim email.
2. Decide the correct category. Financial debt goes in Form C (or Form CA if you are in a class). Operational debt for goods, services, employment-linked vendor work or statutory operational dues goes in Form B.
3. Download the latest Form B or Form C from the IBBI circular page (Circular IBBI/CIRP/94/2026 or any later replacing circular). Do not reuse an old Word copy from a previous CIRP.
4. Compute principal plus contractual or statutory interest only up to the insolvency commencement date. Show the working on a spreadsheet annexure.
5. Attach proof. Information-utility records help. If there is no IU filing, attach the contract, invoices, bank statements, sanction letters, drawdown proofs, security documents and any court or arbitral award.
6. Disclose disputes, arbitration, set-off, retention-of-title and security. Hiding a pending dispute is a gift to the IRP who later slashes the claim.
7. Get the form signed and verified. For a company, a director, manager, company secretary or other authorised officer signs. Attach the board resolution or letter of authority.
8. Financial creditors send Form C only by electronic means to the email in Form A. Operational creditors may use email, post or personal delivery. Keep the sent-mail header, PDF hash and courier receipt.
9. Watch for the list of creditors. The IRP or RP must verify claims, generally within seven days from the relevant last date, and maintain the list. Ask for the admitted amount in writing.
10. If the claim is rejected or under-admitted, write a short reasoned email first. If that fails, file an interlocutory application under Section 60(5) before the same NCLT bench that is hearing the CIRP.

Documents that actually move the needle

Form B — operational creditor

• Purchase order, work order, GST tax invoice and e-way bill where goods moved.
• Ledger extract, Form 26AS or GST portal trail showing the supply.
• Emails accepting the goods or certifying the running-account bill.
• Any Section 8 demand notice and reply, if a Section 9 case was filed.
• Decree, arbitral award or MSME council order, if any.
• Proof of how the debt arose and the date it became due.
• Details of mutual dealings and proposed set-off. Form B itself asks for mutual credit. NCLAT has treated that column as meaningful — you must still show a genuine mutual account, not a wish-list.
• Bank account details for any plan payout.

Form C — financial creditor

• Facility agreement, sanction letter, master facility agreement and all addenda.
• Drawdown requests, disbursement advice and bank statements.
• Security: mortgage deed, charge on MCA-21, hypothecation, pledge, guarantee and corporate guarantee invocation letter if already issued.
• Information-utility record of default, if registered.
• Assignment deed if you are an ARC or assignee; NCLT and IBBI papers for the assignment.
• Statement of account with interest working up to the insolvency commencement date.
• Related-party declaration. A related financial creditor does not vote in the CoC even if the claim is admitted.
• Board resolution authorising the signatory and the email from which Form C is sent.

A financial creditor can often file a claim even where a corporate guarantee has not yet been invoked, because “claim” under Section 3(6) is wider than an immediately payable default. That line of authority is fact-sensitive. Flag it for counsel before you under-claim a guarantee exposure.

Sample structure — Form B (illustrative only)

This is a teaching sample of the fields an operational creditor typically completes. It is not the official IBBI text. Copy the live circular form, then fill it in this style.

Field (Form B)	Sample entry — vendor / MSME
Addressee	The Interim Resolution Professional, [Name], IP Regn. No. [IBBI/IPA-…], email as per Form A
Claimant	Sri Venkateswara Packing Pvt. Ltd., CIN U21000TG2014PTC000000, GSTIN 36AAAAA0000A1Z5, Hyderabad
ID proofs attached	CIN master data, PAN, GST registration, board resolution dated 12.08.2026
Total claim as on ICD	₹48,60,000 (principal invoices ₹44,00,000 + contractual overdue interest ₹4,60,000 up to ICD 01.08.2026)
How and when debt incurred	Supply of corrugated boxes under PO dated 03.01.2026; invoices 14.02.2026, 28.03.2026 and 11.05.2026; payment terms 45 days
Documents substantiating debt	PO, tax invoices, e-way bills, GRNs, ledger, bank statement showing nil receipt after 11.05.2026
Dispute / arbitration	Quality debit note of ₹80,000 raised by CD on 20.06.2026; claimant disputes it; no arbitration pending
Mutual dealings / set-off	Nil, other than the disputed debit note of ₹80,000 disclosed above
Security / retention of title	None. Goods already consumed in the CD’s factory at Jeedimetla
Payout account	Current A/c No. [●], HDFC Bank, Banjara Hills, IFSC HDFC0000XXX

Close Form B with the declaration that the debt is due, the documents are genuine, and the claim has not been satisfied except as stated; then the verification that nothing material is concealed. A director or authorised officer signs, with place and date. Attach a scanned ID and the authority document.

Sample structure — Form C (illustrative only)

Again, use the official circular form. The table below shows how a Hyderabad term-loan desk typically populates Form C.

Field (Form C)	Sample entry — scheduled bank
Addressee	IRP / RP as named in Form A, electronic submission only
Financial creditor	State Bank of India, Stressed Assets Management Branch, Hyderabad; IFSC / branch code as applicable
Nature of claim	Financial debt under Section 5(8) — cash credit and term loan. Creditor is not in a class.
Amount as on ICD	₹18,42,00,000 (principal ₹16,10,00,000 + interest and overdue interest ₹2,32,00,000 up to ICD). Penal charges shown separately in the annexure.
Security interest	First charge on plant at Genome Valley; equitable mortgage of land at Survey No. [●], Medchal; personal guarantee of Managing Director; corporate guarantee of holding company. Charge ID on MCA-[●].
How debt incurred	Sanction letter 18.04.2022; facility agreement 02.05.2022; last drawdown 14.11.2024; account classified NPA on 29.09.2025.
Guarantee / beneficiary items	If any claim is under Section 5(8)(h) or (i) (counter-indemnity, derivatives, etc.), state amount and beneficiary in the dedicated rows of the live form.
Set-off	Credit balance of ₹6,40,000 in a current account of the CD with the same bank as on ICD — disclosed for netting as the RP may admit.
Related-party status	Not a related party of the corporate debtor under Section 5(24) / 5(24A).
Undertaking to update	Claimant will update the claim if any recovery is received after ICD (Regulation 12A).

Form C is signed by the authorised officer of the bank or NBFC. Attach the power of attorney or office order that IBBI and the RP can verify. Send the PDF from an official domain mailbox, not a personal Gmail address.

What the IRP / RP does after your claim arrives

The resolution professional is a facilitator, not a civil court. That is the Swiss Ribbons line. The IRP or RP verifies documents, admits or rejects in whole or in part, and puts the name and amount on the list of creditors. A financial creditor whose claim is admitted (and who is not a related party) enters the CoC. Voting share is proportional to the admitted financial debt.

Operational creditors do not vote, except in the narrow situation where the company has no unrelated financial debt and the committee is formed from operational creditors. They still need an admitted claim to be counted in the plan’s operational-creditor pool and to receive notice of CoC meetings when their aggregate dues cross the statutory threshold (ten per cent of debt).

If part of your claim is locked in arbitration or a writ, the RP may admit the undisputed slice and keep the rest contingent. Ask for written reasons. Silence is not admission.

Forum, challenge and timelines — Hyderabad practice

For a corporate debtor with its registered office in Telangana, the CIRP sits before NCLT Hyderabad (Hyderabad-1 or Hyderabad-2, as assigned). Andhra Pradesh registered offices go to NCLT Amaravati. Appeals from both benches ordinarily go to NCLAT. A further appeal on a question of law lies to the Supreme Court under Section 62.

If the IRP or RP rejects or under-admits your Form B or Form C:

• Write a representation with missing proofs within days, not weeks.
• File an interlocutory application under Section 60(5) in the same company petition. Attach the Form A extract, the claim PDF, the rejection email and a short calculation.
• There is no separate “Form B appeal fee schedule” in the Code. NCLT filing follows the NCLT Rules and the current fee notification — confirm the live fee before e-filing on efiling.nclt.gov.in.
• Do not file a city civil suit for the same admission dispute. Sections 63 and 231, read with Section 238, keep CIRP claim fights inside the Code.
• A writ to the Telangana High Court is exceptional. Use it only where the NCLT remedy is illusory or a pure jurisdictional failure is made out.

Liquidation is a different track. If the company moves from CIRP to liquidation, claims follow the Liquidation Process Regulations and Section 42 (14-day challenge to the liquidator’s decision). Do not assume a CIRP Form C travels automatically without checking the current liquidation regulations on deemed submission of already-collated CIRP claims.

Common mistakes that kill or shrink a claim

• Filing Form C by courier when Regulation 8 requires electronic submission.
• Claiming interest up to the date of filing the form instead of the insolvency commencement date.
• Using an old 2017–2023 Word template after the June 2026 circular refreshed the formats.
• Homebuyers filing individual Form C instead of Form CA through the class process.
• Omitting security particulars, then arguing later for a secured ranking in the plan.
• Hiding a related-party link. The CoC vote can be challenged and the plan delayed.
• Waiting for the plan to be approved and then waking up. That is usually too late.
• Treating the RP’s email as a final decree and missing the Section 60(5) window while evidence is still fresh.
• Not updating the claim after a part-recovery, in breach of Regulation 12A.
• Sending the form from an employee who has no board authority. The RP is entitled to ignore it until authority is proved.

When to consult an advocate

• The RP has classified you as operational when you believe you are financial, or the other way around.
• Your claim is above a size where CoC composition will change if you are admitted.
• There is a disputed set-off, a running account, or goods subject to retention of title.
• You are a guarantor, assignee, or beneficiary of a disputed security interest.
• The 14-day and 90-day windows have lapsed and a plan is being voted.
• You need an urgent stay on implementation of a plan that ignored a timely claim.

Counsel who already appears in the same CIRP at NCLT Hyderabad can often file a focused IA faster than a fresh civil brief. Carry the admission order, Form A, the claim PDF, proof bundle and every email with the IRP.

Bullet-point checklist

• Admission order and insolvency commencement date noted.
• Form A last date and IRP email diary-entered.
• Correct form chosen: B / C / CA / D / E / F.
• Latest IBBI circular form downloaded (June 2026 or later replacement).
• Amount computed only up to ICD, with a working paper.
• IU record or contract-plus-invoice / sanction-plus-disbursement bundle attached.
• Disputes, set-off, security and related-party status disclosed.
• Signatory authority attached.
• Form C sent only by electronic means; sent-mail proof saved.
• Follow-up for list of creditors within the verification week.
• Section 60(5) IA ready if the admitted figure is wrong.
• Regulation 12A update sent if any money arrives after ICD.

Conclusion

How creditors submit claims in CIRP is a short, unforgiving procedure. Pick Form B or Form C correctly, value the debt as on the insolvency commencement date, attach proof the RP can verify in a week, and hit the Form A deadline. The June 2026 IBBI circular is the live stationery. The NCLT Hyderabad IA under Section 60(5) is the live remedy if the list of creditors is wrong.

Treat the public announcement as a limitation notice, not as newspaper colour. Creditors who wait for the resolution plan to be floated usually discover that the plan has already decided their fate.

Short disclaimer

This article is for general information. It is not legal advice, is not a solicitation, and does not create an advocate-client relationship. IBC regulations, IBBI circulars and NCLT practice notes change. Form B and Form C must be taken from the latest IBBI notification. Facts, limitation, related-party status and plan timelines decide outcomes. Consult an advocate with the admission order and claim papers before you act.

Related reading

• Section 7 vs Section 9 IBC: Who Can File, Documents and Timeline
• Pre-Pack Insolvency (PPIRP) for MSMEs: Eligibility, Steps & Benefits
• Protecting Guarantor Property from SARFAESI Action — Practical Steps
• One Time Settlement (OTS) 2026: How to Negotiate with Banks — Checklist
• Restitution After Illegal SARFAESI Auction — Remedies, Limitation & Procedure

Has the IRP under-admitted your claim, or has the 14-day window already closed? Share the admission order, Form A and your draft Form B or Form C. We can review classification, proof gaps and whether a Section 60(5) application before NCLT Hyderabad is still open.