Corporate Restructuring, Valuation and Insolvency · Insolvency

Insolvency Professionals under the Insolvency and Bankruptcy Code

Updated 11 October 2026 · Fact-checked

An insolvency professional (IP) is a person enrolled as a member of an insolvency professional agency and registered with the Board (IBBI). Only such a person may render services as an IP under the Code. IPs run insolvency, liquidation and bankruptcy processes, and must follow the code of conduct in section 208(2).

Understand Insolvency Professionals under the Code

The IBC does not let anyone run an insolvency process. It creates a regulated profession. The person who manages the debtor's affairs during a process must be trained, supervised and answerable to a regulator. That person is the insolvency professional.

The structure has three layers. The Board (the Insolvency and Bankruptcy Board of India) is the regulator. Insolvency professional agencies (IPAs) are registered by the Board and enrol IPs as members. The insolvency professional is enrolled with an IPA and then registered with the Board.

Section 206 states the core rule: no person shall render services as an insolvency professional under the Code without being enrolled as a member of an insolvency professional agency and registered with the Board. Both steps are needed. Enrolment alone is not enough. Registration alone is not possible, because section 207(1) says registration with the Board comes after obtaining membership of an IPA.

What does an IP do? Under section 208(1), once a process has been initiated, it is the IP's function to take the necessary actions in the fresh start process, individual insolvency resolution process, corporate insolvency resolution process (CIRP), pre-packaged insolvency resolution process, individual bankruptcy process and liquidation of a corporate debtor firm. The title changes with the role: interim resolution professional, resolution professional, liquidator or bankruptcy trustee. Each of these is an insolvency professional acting in a particular role.

That answers a common question. Insolvency professional is the status or qualification. Resolution professional is a role an IP holds in a particular CIRP. Every resolution professional must be an IP. Not every IP is a resolution professional at a given time.

Key rules to remember

Section 206: bar on unregistered persons: IP services allowed only if: enrolled with an IPA AND registered with the Board; Both conditions are cumulative. Missing either one means the person cannot act as an IP under the Code.
Section 207(1): order of steps: Membership of an IPA first, then registration with the Board; Registration is within the time, manner and fee specified by regulations.
Section 207(2): categories: Board may specify categories of professionals with qualifications and experience in finance, law, management, insolvency or other fields it deems fit; Detailed eligibility (education, experience, examination, fit and proper) is in the Board's regulations. Do not quote section numbers for those unless sure.
Section 196(1)(a): Board registers IPAs, IPs and information utilities; can renew, withdraw, suspend or cancel registration; The Board also specifies minimum eligibility requirements under clause (b).
Section 199: IPAs: No person may act as an IPA and enrol IPs except under a certificate of registration from the Board; The registration of IPAs follows the principles in section 200.
Section 208(2): code of conduct: (a) reasonable care and diligence; (b) comply with IPA bye-laws; (c) allow IPA to inspect records; (d) submit copy of records of every proceeding before the Adjudicating Authority to the Board and the IPA; (e) perform functions as specified; Five duties. Learn them as a list.
Section 208(1): processes covered: Fresh start; IRP (individuals); CIRP; pre-packaged IRP; individual bankruptcy; liquidation of corporate debtor firm; Pre-pack was added as clause (ca), and section 208(1A) covers pre-initiation functions of the proposed resolution professional.

How to solve Insolvency Professionals under the Code questions

Most questions on this topic are short case problems. A person acts as an IP, or a body claims to enrol IPs, and you must say whether it is valid. Use this method.

1Identify the person and the role: is the question about an individual acting as IP, an agency, or the Board?
2Test the status. Ask: is the person enrolled as a member of an IPA, and registered with the Board? Cite section 206.
3Check the order. Membership of the IPA comes first, then registration with the Board (section 207(1)).
4If an agency is involved, check for a certificate of registration from the Board (section 199) and the principles in section 200.
5Identify the process (CIRP, liquidation, pre-pack, individual process) and the IP's function in it under section 208(1).
6Test the conduct against the five points of section 208(2).
7Name the Board's powers if action is needed: inspection, investigation, directions, cancellation or suspension of registration (section 196(1)).
8Write a clear conclusion in one or two lines, tied to the facts.

Quickest way: Two-gate test plus conduct checklist

When to use it: Use when the question asks whether a person can act as an IP or whether an IP has breached duties, and time is short.

Gate 1: enrolled with an IPA? Gate 2: registered with the Board? Both yes means valid (section 206).
If the facts are about an agency, ask only one thing: does it hold a Board certificate (section 199)?
For conduct, run through: care and diligence, IPA bye-laws, IPA inspection, records to Board and IPA, specified manner.
Match the breach to the limb it violates and state it by name.
Close with the consequence: the Board may inspect, direct, suspend or cancel registration (section 196).

Common mistakes in Insolvency Professionals under the Code

Treating an insolvency professional and a resolution professional as the same thing.
Both terms appear together in CIRP questions and are used loosely.
Fix: Say that IP is the registered status, and RP, IRP, liquidator or trustee are roles held by an IP in a process.
Saying registration with the Board alone is enough.
Students remember the Board as the regulator and forget the IPA step.
Fix: Always state both: enrolment as a member of an IPA and registration with the Board (section 206).
Reversing the order of steps.
Registration sounds like the first step.
Fix: Section 207(1): registration is after obtaining membership of an IPA.
Confusing the Board's functions with the IPA's.
Both supervise IPs, so their powers blur.
Fix: The Board registers IPAs and IPs, makes regulations and can cancel registration. The IPA enrols members, applies its bye-laws, inspects records and runs disciplinary proceedings under model bye-laws.
Listing fewer than five duties in the code of conduct, or adding duties not in the section.
Students recall it from memory, not as a fixed list.
Fix: Memorise section 208(2)(a) to (e) in order: care, bye-laws, inspection, records, specified manner.
Quoting section numbers for eligibility details such as education and experience.
Students assume these sit in the Code itself.
Fix: The Code (section 207(2)) lets the Board specify categories. Say the Board's regulations set detailed eligibility, and avoid guessing numbers.

Worked examples

Example 1

Mr. Arvind Menon, a chartered accountant, is enrolled as a member of an insolvency professional agency. He has not registered with the Board. A creditor asks him to act as resolution professional in a CIRP of Kaveri Textiles Ltd. Can he act?

Show the solution

Provision: section 206 bars any person from rendering services as an insolvency professional unless enrolled as a member of an IPA and registered with the Board.
Facts: Mr. Menon satisfies the first condition (IPA membership) but not the second (Board registration).
Section 207(1) requires every IP, after obtaining IPA membership, to register with the Board within the time and manner specified by regulations.
Analysis: the two conditions are cumulative. Enrolment alone does not authorise him to act. A resolution professional must be an IP.

Answer: No. Mr. Menon cannot act as resolution professional until he registers with the Board, because section 206 requires both IPA enrolment and Board registration.

Example 2

An IP appointed in the CIRP of Sagar Components Ltd. refuses to let his IPA inspect his records and does not send the Board a copy of the records of the proceedings before the Adjudicating Authority. Examine his position.

Show the solution

Provision: section 208(2) sets the code of conduct for every IP.
Clause (c) requires the IP to allow the IPA of which he is a member to inspect his records. Refusal breaches this.
Clause (d) requires him to submit a copy of the records of every proceeding before the Adjudicating Authority to both the Board and his IPA. Not sending the Board a copy breaches this.
Consequence: the Board can monitor and inspect under section 196(1)(f) and (g), call for records under clause (h), and deal with complaints under clause (q). It can also suspend or cancel registration under clause (a). The IPA can act under its bye-laws, which under section 196(2) cover disciplinary proceedings and penalties.

Answer: The IP has breached section 208(2)(c) and (d). He is exposed to action by the Board, including suspension or cancellation of registration, and to disciplinary action by his IPA under its bye-laws.

Exam tips

Open every answer with the two-condition rule of section 206. It scores quickly and sets up the analysis.
Write section 208(2) as five numbered points. Examiners look for the complete list.
Show the three-layer structure (Board, IPA, IP) in one line if a question asks about the regulatory framework.
In case problems, follow provision, facts, conclusion. Keep the conclusion to the point asked.
Cite a section only when you are sure. For detailed eligibility, say the Board's regulations specify it.

Practice questions from Insolvency

Insolvency Professionals under the Code in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

CMA FinalIBC 2016 Overview, Definitions and Authorities

Insolvency Professionals under the Code: frequently asked questions

Who is an insolvency professional under the IBC?

An insolvency professional is a person enrolled as a member of an insolvency professional agency and registered with the Board. Without both, a person cannot render services as an IP under the Code, as section 206 provides.

What is the difference between an insolvency professional and a resolution professional?

Insolvency professional is the registered status of the person. Resolution professional is a role an IP performs in a particular CIRP. An IP can also act as interim resolution professional, liquidator or bankruptcy trustee.

How does a person register as an insolvency professional?

The person first obtains membership of an insolvency professional agency. Then he registers with the Board within the time, in the manner and on payment of the fee specified by regulations (section 207(1)). The Board may specify categories of eligible persons with qualifications and experience in finance, law, management or insolvency.

What is the role of an insolvency professional in CIRP?

Once a process is initiated, section 208(1)(c) makes it the IP's function to take the actions necessary in the CIRP. In practice this covers the roles of interim resolution professional and resolution professional, which you should study in their own topics.