IBBI Circular: Insolvency Notices at Every Real Estate Project Within Seven Days

Picture a Bengaluru buyer visiting a half-built tower on a Saturday to check progress, unaware that the developer company is already in insolvency proceedings. Under a circular dated 30 October 2026, that should become harder to miss. The Insolvency and Bankruptcy Board of India now requires the insolvency professional running such a case to put up a conspicuous signboard at the main entrance or another prominent location of each real estate project within seven days of appointment, saying the company is undergoing insolvency and naming who to contact.

The IBBI circular No. IBBI/CIRP/110/2026, signed by General Manager Sanjay Manocha and issued under Section 196 of the Insolvency and Bankruptcy Code, was reported by LiveLaw on 2 November 2026. This guide explains what it requires and how Bengaluru buyers can use it. It is buyer guidance on a regulatory circular, not legal advice on any insolvency.

The short answer. In the corporate insolvency resolution process of a company with real estate projects, the interim resolution professional or resolution professional must now ensure compliance with the RERA Act, display signboards at every project site and notice boards at the company's offices within seven days of appointment, keep them up until the process ends, and obtain project data such as registration, sanctioned plans and allottee records from the RERA portal where available. The resolution professional may also invite RERA's written views on resolution plans. The trade-off: a visible notice protects new buyers and helps existing ones file claims on time, but it also signals trouble that can slow a project further, so existing buyers should act on it quickly rather than wait.

What does the IBBI circular require?

Four things. The circular applies in the CIRP of a corporate debtor having one or more real estate projects. First, the IRP or RP "shall ensure compliance with the applicable provisions of the RERA Act and the rules and regulations made thereunder during CIRP." Second, the RP may invite the concerned RERA to submit its views in writing on the regulatory compliance, feasibility and implementation aspects of resolution plans before the Committee of Creditors. Third, the start of the process must be disclosed at project and office sites. Fourth, the IRP or RP must obtain project information from the RERA portal, if available.

Where and when must the insolvency notice appear?

At every project and every office, within seven days. The circular says the commencement of CIRP must be prominently disclosed, within seven days of the professional's appointment, through conspicuous signboards at the main entrance or another prominent location at the site of each real estate project, and through notice boards at the registered office, corporate office, site office, sales office and any other office accessible to stakeholders.

The signboards and notice boards must say that the company is undergoing CIRP and give the name and contact details of the IRP or RP. They must stay up until the CIRP concludes and be updated forthwith on any change of IRP or RP. The circular also allows the professional to display further particulars appropriate to the project.

Who does the circular bind?

Insolvency professionals, not developers directly. The circular is addressed to all registered insolvency professionals, all recognised insolvency professional entities and all registered insolvency professional agencies, and it was sent by mail to registered email addresses and placed on the IBBI website. Its duties fall on the interim resolution professional, who runs the process at the start, and on the resolution professional who takes over, "as the case may be".

That distinction matters for a buyer. If a project site carries no signboard weeks after an insolvency has begun, the person responsible under this circular is the professional appointed in the case, not the company's old management. The circular states that it is issued in exercise of the powers conferred under Section 196 of the Code. A buyer who notices a missing or out-of-date signboard can raise it with the named professional first, and keep a dated photograph of the site.

What RERA information must the insolvency professional collect?

Seven categories, wherever available on the RERA portal. The circular lists project registration details; sanctioned plans and approved project configurations; status of project registration and extensions; allottee records available with the authority; status of the separate bank account maintained under the RERA Act; approvals, permissions and compliances relating to the project; and any other information relevant to duties under the Code.

The professional may use this to prepare the information memorandum, verify claims and assess project status. Where the company's own records are incomplete, unavailable or inconsistent, the circular says the professional may rely on RERA records as an important source of information, subject to due verification and reconciliation. That matters to buyers whose payments or allotments are missing from a developer's books.

Why does IBBI say this is needed?

Because information was missing on both sides. The circular says information on project registration, sanctioned plans, statutory approvals, designated bank accounts and construction progress is available on the RERA portal but is often not readily available to the insolvency professional from the company's records, or is incomplete or inconsistent. It also says stakeholders visiting project sites and offices may often not be aware that the company is undergoing CIRP, and that prominent disclosure puts everyone dealing with it on notice, facilitates timely submission of claims, helps preserve value and promotes transparency.

LiveLaw reports that the circular comes alongside a fifth amendment to the CIRP regulations, which it says introduces project-wise mechanisms for real estate insolvency, including separate bank accounts for individual projects, independent project assessments and greater representation for homebuyers. We have not read that amendment for this article, so we do not describe its terms.

What should an existing Bengaluru buyer do on seeing a notice?

File a claim and verify your record. The signboard gives the name and contact details of the IRP or RP, which is the person to approach. Because the circular lets the professional rely on RERA's allottee records where company records are incomplete, it is worth checking that your allotment appears on the K-RERA portal for the project and keeping your agreement and receipts ready for the claim.

Insolvency adds a forum beyond RERA. Our report on a Supreme Court ruling on proving default under Section 7 of the Code explains one aspect of how these cases begin. For a reminder of how much depends on knowing which entity is liable to you, see our report on the Karnataka tribunal's reconstituted firm ruling.

What should a new buyer check before booking?

Look for the notice, then look further. At the site and the sales office, check for any signboard or notice board stating that the company is undergoing CIRP. The circular requires them, but a buyer should not rely on signage alone: also ask the developer in writing whether any insolvency proceeding is pending against the company, and check the project's status, extensions and approvals on the K-RERA portal. If the answers are unclear, pause before paying.

Remember too that a notice tells you a process has started, not how it will end. Whether a project is completed, taken over or wound up depends on the resolution process, which can take time. A new buyer weighing a project that carries such a notice is entering a different kind of transaction, and should take legal advice before committing money.

A seven-point checklist on developer insolvency

1. Look for a CIRP signboard at the project entrance and notice boards at the sales office.
2. Note the name and contact details of the IRP or RP shown on the notice.
3. Check that your allotment appears in the project's records on the K-RERA portal.
4. Gather your agreement, receipts and correspondence before filing a claim.
5. File your claim with the IRP or RP within the timelines they announce.
6. Confirm, on each visit, that the signboard names the current professional.
7. Ask the RP whether K-RERA's views were invited on any resolution plan for your project.

Frequently asked questions

What does IBBI's circular of 30 October 2026 require?

In the insolvency of a company with real estate projects, the IRP or RP must ensure RERA compliance, display signboards at each project and notice boards at company offices within seven days of appointment, obtain project data from the RERA portal where available, and may invite RERA's written views on resolution plans.

What must the insolvency signboard say?

The circular says the signboard and notice board must indicate that the company is undergoing CIRP and give the name and contact details of the IRP or RP. They must remain displayed until the process concludes and be updated forthwith on any change in the professional.

Which RERA records will the insolvency professional use?

Project registration details, sanctioned plans and configurations, registration and extension status, allottee records, status of the separate RERA bank account, approvals and compliances, and other relevant information, wherever available on the RERA portal. Where company records are incomplete, RERA records may be relied on after verification.

What should a buyer do on seeing a CIRP notice at a project?

Note the IRP or RP contact details on the notice, check that your allotment appears in the project's K-RERA records, gather your agreement and receipts, and file your claim with the professional. New buyers should ask about pending insolvency in writing before paying anything.

Last updated 2026-11-04. PropNewz Team.