CDDA transitional provisions

The Insolvent Companies (Reports on Conduct of Directors) Rules 2016, coming into effect from 6 April 2016, will mean that for appointments from 6 April 2016, the D1 and D2 forms will be replaced by an online questionnaire, to be completed and submitted within three months of appointment for creditors' voluntary liquidations and administrations.

Insolvency practitioners should also be aware of the transitional provisions for appointments before 6 April 2016 and the impact that these will have. Forms D1 and D2 can be used for appointments predating 6 April 2016 as before, but only provided that the final report is submitted before 6 October 2016, (Rule 10(2) of the Insolvent Companies (Reports on Conduct of Directors) Rules 2016).

The effect of these transitional provisions is that for administrations between 8 October 2014 and 6 April 2016 there will no longer be a full two year period within which the final D report can be submitted. The final D report for all these appointments must be submitted before 6 October 2016 and diaries for such cases should be updated accordingly to ensure ongoing compliance.

The Insolvent Companies (Reports on Conduct of Directors) Rules 2016 can be accessed on (PDF)

Caroline Clark's insolvency career started over 30 years ago and since 1994 she has specialised in insolvency compliance and regulation.

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