IBBI action against RVO for admitting ineligible valuer on “provisional” basis: Key findings and implications

The text reproduced in the source is a full judicial/authority order passed by the Insolvency and Bankruptcy Board of India (IBBI) acting as the “Authority” under the Companies (Registered Valuers and Valuation) Rules, 2017. Accordingly, this write‑up provides a structured summary of the key facts, reasoning and directions, rather than a paragraph‑by‑paragraph rewrite.

Background of the case

On 22.01.2026, the Insolvency and Bankruptcy Board of India, acting as the delegated Authority under notification no. GSR 1316(E) dated 18.10.2017 issued under Section 458 of the Companies Act, 2013, passed an order in respect of M/s. Assessors and Registered Valuers Foundation (AaRVF), a recognised Registered Valuer Organisation (RVO) bearing Recognition No. IBBI/RVO/2021/016 dated 15.04.2021.

The proceedings were initiated on the basis of:

  • A grievance filed by Mr. Manish Bohra alleging that AaRVF:
    • admitted him as a member in the Securities or Financial Assets (SFA) asset class despite his ineligibility,
    • collected membership and course fees,
    • allowed him to attend the mandatory 50-hour valuation course and appear for the valuation examination, and
    • forwarded his application to IBBI for registration as a valuer, even though he did not satisfy the educational qualification norms prescribed under the Companies (Registered Valuers and Valuation) Rules, 2017 (Valuation Rules).

After preliminary examination, IBBI formed a prima facie view that AaRVF had violated Rule 3 and Rule 4 read with Annexure-IV of the Valuation Rules. Consequently, a Show Cause Notice (SCN) dated 01.07.2025 (No. COMP-11015/85/2024-IBBI/984) was issued under Rule 17 of the Valuation Rules, proposing action including suspension of recognition.

AaRVF filed a written response and was also given a personal hearing (virtual) on 03.10.2025 before the Whole Time Member designated as the “authorised officer” under Rule 17. Additional submissions were furnished by AaRVF on 10.10.2025 and 16.01.2026.

Core allegation: enrolment and recommendation of an ineligible applicant

Facts relating to the applicant

  • The concerned individual, Mr. Manish Bohra, is a CFA (USA) charter holder (a foreign professional qualification).
  • AaRVF:
    • enrolled him as a valuer member in the SFA category;
    • collected membership and course fees;
    • allowed him to complete the 50-hour mandatory educational course in SFA;
    • later forwarded his application (Form A) to IBBI on 02.01.2024 for registration as a Registered Valuer.
  • IBBI returned the application on 09.02.2024, with the specific remark that his “qualification is not as per the Rules”.

In his grievance, Mr. Bohra alleged that the RVO misled him into believing he was eligible, effectively cheated him by granting membership, permitting him to complete the course and attempt the valuation exam, and then left him stranded when the registration was not possible.

Eligibility under Rule 4 and Annexure-IV

The Authority extensively referred to:

  • Rule 4 of the Companies (Registered Valuers and Valuation) Rules, 2017, which stipulates the minimum educational qualifications and experience required to be eligible for registration as a valuer.

For the SFA asset class, as per Annexure-IV, eligible qualifications include:

  • Membership of:
    • Institute of Chartered Accountants of India,
    • Institute of Company Secretaries of India,
    • Institute of Cost Accountants of India; or
  • Master of Business Administration / Post Graduate Diploma in Business Management with specialisation in finance; or
  • Post Graduate in Finance.

The order emphasises that:

CFA (USA) is not listed as an eligible qualification for SFA under Rule 4 read with Annexure-IV.

Further, Explanation III to Rule 4 clarifies that “equivalent” refers only to professional and technical qualifications recognised by the Ministry of Human Resource Development as equivalent to professional/technical degrees.

Requirement under Rule 14(c)

Rule 14(c) of the Valuation Rules, which sets out conditions for recognition of an RVO, clearly provides that:

The RVO shall **admit only those individuals as members who possess educational qualifications and experience as per Rule 4 and as specified in its recognition certificate.

The Authority held that: