One Valuer, Two Registrations: Rule 8(2) Never Triggers

Rule 7(c) of the Companies (Registered Valuers and Valuation) Rules, 2017 bars a valuer from conducting "valuation of the assets or class(es) of assets other than for which he/it has been registered." A person registered for both Securities or Financial Assets and Land and Building has nothing left that is "other than" what they hold. Rule 8(2)'s mechanism, obtaining a disclosed input "from another registered valuer," is written around a genuinely separate person. Nothing in either provision, or anywhere else checked in the Rules, requires a dual-registered individual to treat their own second registration as though it belonged to someone else.

IBBI's own registration FAQ confirms the route directly: "Can a Registered Valuer for one asset class register for another asset class? Yes, subject to meeting the eligibility criteria specified for the said asset class for which registration is being sought," and a second class means redoing the 50-hour educational course, "since the educational course is asset class specific," on top of separately meeting Annexure IV's qualification and experience criteria and passing a second valuation examination. Securities or Financial Assets runs through ICAI, ICSI, or ICMAI membership or a finance MBA; Land and Building runs through a civil engineering, architecture, or town-planning credential. The two draw from almost entirely disjoint professional populations, which is the real reason dual registration is rare, not any restriction on what a dual-registered person can then do.

Rule 6(6) contemplates a certificate "for the relevant asset class or classes" in the singular certificate form, and IBBI's own public registry lists a single registration number against a person, with asset class as a separate, expandable field. A second registration adds to the same record. It does not create a second identity that the first one would need to formally engage.

The sharper contrast sits at the entity level, and here the Rules are explicit rather than silent. Where a partnership or company is registered as a valuer for more than one asset class through two different partners, Rule 7(h) requires the entity to "allow only the partner or director who is a registered valuer for the asset class(es) that is being valued to sign and act on behalf of it," with Rule 7(i) requiring disclosure of that specific partner's stake and Rule 7(j)/(k) tying liability to "the partner or director... who signs and acts." IBBI's entity FAQ confirms the same logic squarely: a firm cannot register for Land and Building through a partner qualified only in Plant and Machinery.

Competence has to be attributed to the specific person who actually holds it, inside a multi-class firm. No equivalent provision exists for a single individual holding both registrations personally, because there is no second person inside one person to attribute anything to.

IBBI's own newsletter data put it in numbers: as of September 2022, 4,892 individuals held active registrations, three for all three asset classes and 75 for two, the remaining 4,814 for exactly one. IBBI does not publish which two-class combinations those 75 hold. Given how little Securities or Financial Assets and Land and Building overlap as professional tracks, the genuine fact pattern this piece examines, one person licensed for both, sits inside an already small slice of an already small number.

A person who has actually cleared both asset classes can sign a single report valuing a company's land and its shares without triggering Rule 8(2) at all, no disclosed input, no attribution to a second name, no shared liability. That is not a deliberate exemption carved out anywhere. It is a case the Rules never had reason to write guidance for, since so few people ever put themselves in the position for it to matter.