Read this before you use the checklist
This follows the structure of Official Form 425C, Monthly Operating Report for Small Business Under Chapter 11 (rev. 12/17). Small business and Subchapter V debtors use this specific form — it differs from the UST Form 11-MOR used in other Chapter 11 cases. Some districts add local requirements on top. Always confirm the current form and local rules with your bankruptcy attorney and assigned trustee. This is educational, not legal or accounting advice.
What a Monthly Operating Report is — and when it's due
A Monthly Operating Report (MOR) is a financial report required by the bankruptcy court during a Chapter 11 Subchapter V case. You file one every month, reporting your business finances for the prior calendar month. It shows the court, the U.S. Trustee or Bankruptcy Administrator, your Sub-V trustee, and your creditors that your business is operating honestly and as a going concern.
Small business and Subchapter V debtors use Official Form 425C. This checklist follows that form's actual structure: a questionnaire, a summary of cash activity, unpaid bills, money owed to you, employee counts, professional fees, a projection comparison, and a list of additional attachments.
Deadline: the 21st of every month
Your MOR is due by the 21st of the month following the reporting period, and continues every month until your case is confirmed, dismissed, or converted. Your April MOR (covering April 1–30) is due May 21. Your first MOR covers from your petition date through the end of that calendar month.
Missing the deadline is a top reason Sub-V cases get dismissed
If your case is dismissed, you lose the automatic stay — creditors can resume collection, lawsuits, and repossession immediately. A late MOR can trigger a show-cause hearing, and repeated late filings are grounds for dismissal even if every other part of your case is going well. If you know you'll be late, contact your attorney before the 21st, not after. Silence is what gets cases dismissed — not the occasional honest delay disclosed in advance.
Key deadlines in your first 90 days
Form 425C, line by line
The form is organized into 8 numbered parts. This checklist follows that exact structure so you see precisely what the form asks for — nothing invented. Six exhibits (labeled A–F by the form itself) are attached as supporting detail.
Questionnaire
The explanation trigger flips halfway through
For lines 1–9, if you answer "No" to any, attach a written explanation labeled Exhibit A. For lines 10–18, if you answer "Yes" to any, attach a written explanation labeled Exhibit B. Tap an answer below and the form will remind you when an exhibit is triggered.
Lines 1–9 — explain if you answer "No" (Exhibit A)
| # | Question | Answer |
|---|---|---|
| 1 | Did the business operate during the entire reporting period? | Attach Exhibit A |
| 2 | Do you plan to continue to operate the business next month? | Attach Exhibit A |
| 3 | Have you paid all of your bills on time? | Attach Exhibit A |
| 4 | Did you pay your employees on time? | Attach Exhibit A |
| 5 | Have you deposited all receipts into debtor-in-possession (DIP) accounts? | Attach Exhibit A |
| 6 | Have you timely filed your tax returns and paid all of your taxes? | Attach Exhibit A |
| 7 | Have you timely filed all other required government filings? | Attach Exhibit A |
| 8 | Are you current on quarterly fee payments to the U.S. Trustee or Bankruptcy Administrator? | Attach Exhibit A |
| 9 | Have you timely paid all of your insurance premiums? | Attach Exhibit A |
Lines 10–18 — explain if you answer "Yes" (Exhibit B)
| # | Question | Answer |
|---|---|---|
| 10 | Do you have any bank accounts open other than the DIP accounts? | Attach Exhibit B |
| 11 | Have you sold any assets other than inventory? | Attach Exhibit B |
| 12 | Have you sold/transferred assets or provided services to anyone related to the DIP? | Attach Exhibit B |
| 13 | Did any insurance company cancel your policy? | Attach Exhibit B |
| 14 | Did you have any unusual or significant unanticipated expenses? | Attach Exhibit B |
| 15 | Have you borrowed money, or has anyone made payments on your behalf? | Attach Exhibit B |
| 16 | Has anyone made an investment in your business? | Attach Exhibit B |
| 17 | Have you paid any bills you owed before you filed bankruptcy? | Attach Exhibit B |
| 18 | Have you allowed any pre-petition checks to clear the bank? | Attach Exhibit B |
Why lines 17 and 18 matter so much
These two exist specifically to catch pre-petition payments. "Yes" to either means money that should have stayed frozen moved anyway — you paid an old bill, or an old check cleared. Both require a court-approved explanation. If you're not sure whether a payment was pre- or post-petition, ask your attorney before answering.
Summary of cash activity for all accounts
Post-petition transactions only
Your MOR covers money received and paid after your filing date only. Pre-petition income and expenses belong in your bankruptcy schedules. If you filed on March 15, your March MOR covers only March 15–31.
Clearing accounts & month-end timing
For card processors and payment platforms, the safer, more consistent practice is to report a receipt in the month it actually lands in a DIP account, and note the timing gap. A card swipe on March 31 that settles April 1 is best reported on the April MOR. Confirm this treatment with your accountant and stay consistent month to month — the form's own instruction language is broader than this and your trustee may have a preference.
Unpaid bills
Post-petition only — do not pay pre-petition debts without court approval
This part covers only debts incurred since your filing date that you haven't yet paid. Pre-petition debts are addressed in your schedules, not here. Paying old debts without court approval violates bankruptcy law and can jeopardize your case.
Money owed to you
Pre- and post-petition receivables are combined here
Unlike payables (post-petition only), line 25 asks for a single combined total of amounts owed to you, before and after filing. Keep your own records split for tracking and trustee questions, but the face of the form is one number.
Employees
This part asks only for headcounts — not payroll dollars. If you have zero employees, report 0 for both lines; the part still must be completed.
Professional fees
Court-approval reminder
Most case-related professional fees (your attorney, a case accountant) require court approval before being paid from estate funds. Report what was actually paid — if a payment was made without approval, flag it to your attorney immediately, don't omit it.
Projections
Required every month — not a one-time event
One of the most overlooked parts. Each month you (1) compare what you projected last month to what actually happened, and (2) project next month's receipts, disbursements, and net cash flow. This is separate from the longer-range projection in your Plan of Reorganization — it's a rolling, one-month-ahead projection required on the MOR itself, every month.
Compare last month's projection to this month's actuals — Column A (Projected) vs. Column B (Actual) vs. Column C (Difference):
Then project forward to next month:
How to build a reasonable projection
The form doesn't prescribe a method. A common starting approach is a trailing 1–3 month average of actual receipts and disbursements, adjusted for known upcoming changes (a new contract, a one-time expense, a seasonal pattern). Document your assumptions so you can explain variances next month. Confirm with your attorney or accountant whether your district expects a specific method.
Additional information
Attachments "if available" — not standalone required schedules
Check the box and attach only if the document is available. A full P&L or balance sheet isn't separately mandated the way the cash schedule (Part 2) is — but most debtors prepare them anyway, and trustees commonly expect to see them. If you maintain these records, check the box and attach them; trustees view their consistent presence favorably.
Signature block
Signed under penalty of perjury
The responsible party signs declaring, under 28 U.S.C. § 1746, that the report and attachments are true, correct, and complete. False statements in bankruptcy filings are a federal crime.
Final reminders before filing
- Miss the deadline and your case can be dismissed. File on time, every time.
- Line 23 (ending cash) becomes line 19 (opening balance) next month — the numbers must link with no gaps.
- Check the explanation-trigger direction: lines 1–9 explain on "No" (Exhibit A); lines 10–18 explain on "Yes" (Exhibit B).
- Don't substitute bank statements for Exhibits C and D — the form requires itemized listings.
- Complete Part 7 (Projections) every month — easy to overlook, but required.
- Your attorney should review the MOR before it's filed.
- File through PACER/CM-ECF by the 21st, then save the filed MOR, all exhibits, and the confirmation receipt.