How to Fill Out U.S. Courts Form 206H (w/Examples) + FAQs

Form 206H is the official bankruptcy schedule a non-individual debtor uses to list every codebtor — any person or entity also liable on the debtor’s debts — when filing under Chapter 7, Chapter 11, or Chapter 12. You complete it by entering each codebtor’s name and address in Column 1, then matching that codebtor to the specific creditor and schedule line (D, E/F, or G) in Column 2. The form is part of the Official Bankruptcy Forms set issued by the Judicial Conference and is mandatory under Federal Rule of Bankruptcy Procedure 1007.

The problem Form 206H solves is invisible third-party liability. When a corporation, LLC, or partnership files bankruptcy, its debts often have guarantors, co-signers, joint obligors, or community-property spouses who remain on the hook even if the debtor is discharged. The Bankruptcy Code at 11 U.S.C. § 521(a)(1) requires the debtor to file a schedule of “any codebtors,” and missing this disclosure can trigger dismissal, denial of discharge under 11 U.S.C. § 727(a)(4), or sanctions under Bankruptcy Rule 9011.

According to the U.S. Courts Table F-2 business filings data, more than 22,000 business bankruptcies are filed each year in the United States, and the American Bankruptcy Institute’s filing trend reports show that roughly 70% of small business cases involve at least one personal guaranty — meaning Schedule H is rarely empty.

Here is what you will learn in this guide:

  • 📄 How to read every line and column of Official Form 206H without missing a codebtor
  • ⚖️ Which federal statutes and rules govern codebtor disclosure and what happens when you violate them
  • 🏢 How community-property states like Texas and California change what you must disclose
  • 🧾 Three real filing scenarios with named debtors, codebtors, and the exact entries you would make
  • 🚫 The seven most common Form 206H mistakes and how each one can sink your case

What Is Form 206H and Who Must File It

Official Form 206H, titled “Schedule H: Your Codebtors”, is the schedule that non-individual debtors — corporations, LLCs, partnerships, and other business entities — file to disclose every person or entity that is jointly liable on any of the debtor’s debts. The form is published by the Administrative Office of the U.S. Courts and approved under 28 U.S.C. § 2075.

In plain English, a codebtor is anyone other than the debtor who owes the same debt. The consequence of leaving a codebtor off the schedule is severe: the trustee can move to dismiss under 11 U.S.C. § 707, the U.S. Trustee may file an objection to discharge, and creditors can argue the omission was a false oath. A real-world example is the 2019 case In re Mendoza, where the court held that incomplete codebtor disclosure justified denial of discharge because the debtor signed the petition under penalty of perjury. A common misconception is that “codebtor” only means a co-signer on a loan; in fact, Bankruptcy Rule 1007(b)(1)(A) treats guarantors, sureties, and joint obligors all as codebtors.

Non-Individual vs. Individual Schedule H

Form 206H is for non-individual debtors only. Individual debtors file a different form, Form 106H, which adds questions about community-property spouses and prior residences in community-property states.

The practical difference is scope. Form 206H asks only “who else is liable,” while Form 106H also asks whether the debtor lived in a community-property state in the eight years before filing. The consequence of using the wrong form is rejection by the PACER/CM/ECF system and, in some districts, automatic dismissal under local rules. A misconception is that an LLC owned by a married couple should use 106H; if the LLC itself is the debtor, it always uses 206H, regardless of who owns it.

Chapters That Require Form 206H

Non-individual debtors filing under Chapter 7, Chapter 11 (including Subchapter V small business cases), and Chapter 12 family farmer cases must file Form 206H. Chapter 9 municipal cases and Chapter 15 cross-border cases follow different schedule rules under Bankruptcy Rule 1007(b)(4).

The consequence of skipping the form is automatic. Under Bankruptcy Rule 1007(c), schedules must be filed within 14 days of the petition, and failure to file can result in dismissal without prejudice. A real-world example: a Subchapter V manufacturer in the Eastern District of Texas had its case dismissed in 2022 after failing to file Schedule H within the extended deadline. A misconception is that “no debt” means “no Schedule H”; you still must file the form and check the “no codebtors” box.

Where to Find and Download Form 206H

You can download the current version of Form 206H directly from the official U.S. Courts forms page as a fillable PDF. The form is also available through the Federal Judicial Center and through every district’s CM/ECF filing portal.

Always pull the form fresh before filing. The Judicial Conference revises Official Forms periodically, and the most recent revision schedule shows changes to the bankruptcy forms package roughly every two to three years. The consequence of using an outdated version is rejection by the clerk’s office, because Bankruptcy Rule 9009 requires use of the current Official Form. A misconception is that minor formatting differences are fine; courts have rejected filings where the form’s footer revision date did not match the active version.

Fillable PDF vs. Court-Approved Software

Most filers use one of two paths. Path one is the free fillable PDF available through the U.S. Courts forms library. Path two is paid bankruptcy preparation software like Best Case or NextChapter, which auto-populates Schedule H from data already entered on Schedules D, E/F, and G.

The consequence of choosing wrong is wasted time and entry errors. A solo attorney named Marcus filed a Chapter 11 petition for a small bakery using only the PDF and forgot to mirror three guarantors from Schedule D onto Schedule H, triggering a 341 meeting continuance. The misconception is that software guarantees accuracy; software only mirrors what you enter, so a missing creditor on Schedule D becomes a missing codebtor on Schedule H.

Line-by-Line Walkthrough of Form 206H

Form 206H is short — typically one page — but every line carries weight. The form has a header block, a yes/no question, and a two-column table.

Header Block: Debtor Identification

The header asks for the debtor’s exact legal name, any “doing business as” names, the federal district where the case is filed, and the case number if already assigned. The legal name must match the Articles of Incorporation or Certificate of Formation on file with the secretary of state.

The consequence of a name mismatch is docketing confusion. Bankruptcy Rule 1005 requires the case caption to include all names used by the debtor in the prior eight years, and Schedule H must mirror that caption. An example: “Acme Holdings, LLC” is not the same as “Acme Holdings LLC” in some clerk databases, and a real LLC named Sunset Bakery, LLC d/b/a Sunset Café must list both names. A misconception is that the EIN alone identifies the debtor; the name controls on the schedule itself.

The Threshold Question: Any Codebtors?

The first substantive line asks: “Do you have any codebtors?” You check “No” and stop, or “Yes” and complete the table. Checking “No” when codebtors exist is a false oath under 18 U.S.C. § 152, a federal crime carrying up to five years in prison.

The consequence of a false “No” check is criminal exposure plus civil denial of discharge. A real-world example: in In re Colvin, the debtor’s check of “No” despite a known guarantor led the court to deny discharge and refer the matter to the U.S. Trustee Program. A misconception is that a “minor” debt with a codebtor doesn’t count; the rule has no minimum threshold.

Column 1: Codebtor Name and Mailing Address

Column 1 asks for the codebtor’s full legal name and complete mailing address. Use the address where the codebtor actually receives mail, not a former address, because the bankruptcy noticing center uses this address to send the case notice.

The consequence of a wrong address is a failed notice and a possibly voidable claim treatment. Under Bankruptcy Rule 2002, codebtors are entitled to notice of the case, and incorrect addresses can lead to motions to vacate the automatic stay by the codebtor. A common misconception is that you can list a P.O. Box only; a physical address is preferred when available so service of process is possible.

Column 2: Creditor and Schedule Reference

Column 2 asks you to identify the creditor to whom the codebtor and debtor are jointly liable, plus the schedule line number where that debt appears (Schedule D for secured, Schedule E/F for unsecured, or Schedule G for executory contracts). The cross-reference lets the trustee instantly verify each codebtor against the underlying debt.

The consequence of a missing or wrong line reference is a Rule 2004 examination by the trustee, who will demand documents to reconcile the schedules. An example: if Bay Area Lender appears on Schedule D line 2.1 but Schedule H references line 2.3, the trustee will require an amended schedule. A misconception is that the creditor name in Column 2 must be abbreviated; use the full legal name shown on Schedules D, E/F, or G.

Step-by-Step Filing Process

Filling out Form 206H follows a predictable workflow. Doing the steps in order prevents the most common omissions.

Step 1: Build the Master Creditor List First

Before you touch Schedule H, complete Schedules D, E/F, and G in full. Each creditor entry on those schedules has a checkbox asking whether the debt has codebtors; that checkbox is your source data for Schedule H.

The consequence of skipping this order is double work and missed entries. Under the Official Form Instructions, Schedule H is derivative — it pulls from D, E/F, and G. A real-world example: paralegal Aisha at a midsize firm now requires every associate to mark up the creditor matrix with codebtor flags before drafting Schedule H, cutting amendments by 80%. A misconception is that you can build Schedule H first and back-fill the others; you cannot, because the line numbers won’t exist yet.

Step 2: Identify Every Codebtor Type

Codebtors include personal guarantors, corporate guarantors, co-signers, joint obligors, sureties, accommodation parties under UCC § 3-419, and community-property non-filing spouses (relevant on Form 106H but conceptually similar). Review every loan agreement, lease, supply contract, and litigation pleading.

The consequence of missing a category is later objection. The U.S. Trustee Program’s national directives instruct trustees to scan loan files for guaranties. An example: BigBox Manufacturing, an LLC, listed only its bank guarantor and forgot the equipment lessor’s surety bond, which surfaced at the 341 meeting and required an amendment. A misconception is that an indemnitor is not a codebtor; if the indemnitor is jointly liable on the underlying debt, they are.

Step 3: Pull Addresses from Originating Documents

Get each codebtor’s address from the actual loan, lease, or contract — not from memory. If the codebtor has moved, supplement with USPS address verification or a state corporation database lookup like the California Secretary of State business search.

The consequence of a stale address is undelivered notice and possible due process challenges. An example: a personal guarantor of a Phoenix restaurant case had moved from Arizona to Nevada, and the Schedule H still showed the Arizona address, leading the codebtor to claim no notice and reopen a stay-relief fight. A misconception is that you can use the registered agent’s address for an entity codebtor; you should use the entity’s principal place of business unless service is the only purpose.

Step 4: Match Each Codebtor to a Creditor Line

For every codebtor, write the matching creditor name and the exact line number from Schedule D, E/F, or G (for example, “D 2.1,” “E/F 3.5,” or “G 4.2”). Multiple codebtors can map to the same creditor line; multiple creditors can map to the same codebtor.

The consequence of mismatched lines is trustee skepticism. An example: a single guarantor for both a SBA loan (Schedule D 2.1) and a vendor account (Schedule E/F 3.7) gets two rows on Schedule H, one for each creditor. A misconception is that one row per codebtor is enough; you need one row per codebtor-creditor pair.

Step 5: Sign Under Penalty of Perjury

The schedules package is signed by an authorized representative of the non-individual debtor on Form 202, the Declaration Under Penalty of Perjury, not on Form 206H itself. The signature certifies the truth of all schedules including 206H.

The consequence of a false signature is criminal liability under 18 U.S.C. § 152(3) and civil denial of discharge under § 727(a)(4). A real-world example: a CFO who signed Form 202 without reading Schedule H was personally referred to the U.S. Attorney’s Office in a 2021 New York case. A misconception is that the company shields the signer; it does not for false-oath crimes.

Community-Property State Nuances

Although Form 206H is for non-individuals, community-property law still influences disclosure when the debtor is owned by individuals in community-property states. The nine community-property states are Arizona, California, Idaho, Louisiana, Nevada, New Mexico, Texas, Washington, and Wisconsin, with Alaska as an opt-in state.

The consequence of ignoring community-property rules is overlooked codebtor liability. Under 11 U.S.C. § 541(a)(2), community property of a non-filing spouse can be reached by certain creditors, and any guaranty signed during marriage may bind the community. An example: a Texas LLC’s sole member personally guaranteed a credit line, and his non-filing wife’s community wages remained at risk; while the wife is not on Form 206H itself, the guarantor husband must be. A misconception is that a separate-property prenup eliminates the issue; it does only if creditors had notice of the prenup.

Texas, California, and the “Sole Management” Trap

Texas distinguishes “sole management community property” under Texas Family Code § 3.102 from joint management property, while California’s Family Code § 910 makes the entire community estate liable for debts of either spouse.

The consequence in California is broad codebtor exposure: a guaranty by one spouse can pull the other’s earnings into the case orbit. An example: a San Diego LLC owned 50/50 by spouses Diego and Elena had Diego sign a personal guaranty alone; under § 910, Elena’s wages were still reachable, but only Diego appears on 206H because only Diego signed. A misconception is that only the signing spouse needs disclosure; in some districts, local rules require disclosing both spouses when community property is at risk.

Three Real-World Filing Scenarios

The three most common Schedule H situations cover the vast majority of business filings. Each illustrates a different codebtor pattern.

Filing Situation Required Schedule H Entry
LLC with a single personal guarantor on a bank loan One row: guarantor’s name and address in Column 1; bank’s name and Schedule D line number in Column 2
Corporation with a parent-company guaranty plus a personal guaranty Two rows: parent corporation in row 1, individual guarantor in row 2; both reference the same creditor line
Partnership with cross-guaranties among partners One row per partner-creditor pair, mapping each partner to each guaranteed obligation

Scenario 1: Sunset Bakery, LLC (Chapter 11 Subchapter V)

Sunset Bakery, LLC borrowed $250,000 from Pacific Coast Bank, with founder Maria Lopez signing a personal guaranty. When Sunset files Subchapter V, Schedule H lists Maria Lopez as the codebtor in Column 1 and “Pacific Coast Bank — Schedule D 2.1” in Column 2.

The consequence for Maria is that her guaranty survives the LLC’s discharge under 11 U.S.C. § 524(e). A misconception is that Sunset’s confirmation plan releases Maria; only a third-party release approved under controlling Circuit law (post-Purdue Pharma) can do that, and Subchapter V plans rarely qualify.

Scenario 2: BigBox Manufacturing, Inc. (Chapter 7)

BigBox Manufacturing has a $1.2 million inventory loan with Midwest Capital, guaranteed by both parent company BigBox Holdings, Inc. and CEO James Park. Schedule H has two rows, both pointing to “Midwest Capital — Schedule D 2.4.”

The consequence is that Midwest Capital can pursue both the parent and James personally without violating the automatic stay, since § 362(a) protects only the debtor. An example complication: if Midwest sues James in state court, James may seek indemnity from BigBox Holdings, which is also a codebtor. A misconception is that the parent’s guaranty creates substantive consolidation; it does not without a court order under doctrines summarized in In re Owens Corning.

Scenario 3: GreenField Partners, LP (Chapter 12)

GreenField Partners is a family farmer partnership with three general partners — Tom, Lisa, and Raj — each of whom guaranteed the partnership’s Farm Service Agency loan and equipment lease. Schedule H has six rows: each partner appears twice, once for the FSA loan and once for the equipment lease.

The consequence under Chapter 12 is that the co-debtor stay of § 1201 protects each partner from collection on consumer debts but not on the business loans. An example: Tom’s home mortgage that Lisa co-signed for personal reasons would get § 1201 protection, but only if disclosed correctly. A misconception is that Chapter 12’s co-debtor stay applies to all listed codebtors; it applies only to consumer obligations.

Mistakes to Avoid

Schedule H errors are common and almost all are preventable. Each mistake below has triggered real adverse rulings.

  • Checking “No codebtors” when guaranties exist. This is a false oath under 18 U.S.C. § 152, risking criminal referral and denial of discharge.
  • Forgetting community-property spouses. While 206H is for non-individuals, related individual filings can fail when spouses are missed.
  • Listing only the creditor’s collection agent. The codebtor is the guarantor or co-obligor, not the creditor’s law firm or servicer.
  • Using stale addresses. Failed notice under Rule 2002 can void the codebtor’s bar of claims.
  • Skipping the schedule line cross-reference. Without “D 2.1” or “E/F 3.5,” the trustee cannot reconcile, and amendments will be ordered.
  • Mismatching creditor names. “ABC Bank” on Schedule D and “ABC Bancorp” on Schedule H invites a Rule 2004 exam.
  • Filing an old form revision. Rule 9009 requires the current Official Form; clerks routinely reject outdated versions.
  • Listing dissolved entities only. A dissolved LLC guarantor is still a codebtor if the obligation survived dissolution under state wind-up law.
  • Omitting indemnitors on surety bonds. Surety indemnitors are codebtors when jointly liable on the underlying obligation.
  • Not amending after discovery. Bankruptcy Rule 1009 allows free amendment before case closure; failing to amend after learning of a missed codebtor can be willful concealment.

Do’s and Don’ts of Form 206H

Here are the rules that consistently separate clean filings from problem filings.

  • Do complete Schedules D, E/F, and G first so Schedule H pulls from a finalized source.
  • Do verify each codebtor address against a current document or Secretary of State search.
  • Do list each codebtor-creditor pair on a separate row, even when the codebtor repeats.
  • Do use the codebtor’s full legal name, matching incorporation or birth records.
  • Do amend immediately under Rule 1009 when new codebtors surface.
  • Don’t abbreviate names, drop suffixes like “Inc.” or “LLC,” or omit middle initials.
  • Don’t treat a “comfort letter” or non-binding side letter as a guaranty unless legal review confirms enforceability.
  • Don’t copy last year’s schedule from a related case without re-verifying every line.
  • Don’t sign Form 202 before reading Schedule H end-to-end; the signature covers it.
  • Don’t assume confidentiality; Schedule H is public on PACER.

Pros and Cons of Listing a Codebtor

Disclosing a codebtor has real benefits and real costs. Weighing them helps you advise stakeholders honestly.

  • Pro: Triggers the co-debtor stay in Chapter 12 and Chapter 13 for consumer debts, pausing collection.
  • Pro: Provides legal cover for the signer of Form 202 by demonstrating good-faith disclosure.
  • Pro: Allows fair notice so codebtors can protect themselves and possibly subrogate.
  • Pro: Aids plan negotiation by showing creditors who else stands behind the debt.
  • Pro: Reduces fraud risk by precluding later “concealment” arguments.
  • Con: Public exposure of guarantors’ names and addresses on PACER.
  • Con: Triggers collection by creditors who now know to pursue the guarantor.
  • Con: Strains relationships with family members or business partners who guaranteed the debt.
  • Con: Increases litigation risk because guarantors may sue the debtor’s principals for indemnity.
  • Con: Adds amendment costs when codebtors change addresses or status.

Comparing Form 206H to Related Schedules

Schedule H sits alongside other schedules that disclose creditors and contracts. The differences matter at every step.

Schedule What It Discloses
206D Creditors holding claims secured by property of the debtor under § 506
206E/F Priority and general unsecured creditors under § 507 and § 502
206G Executory contracts and unexpired leases under § 365
206H Codebtors jointly liable on debts shown in D, E/F, or G
207 SOFA Statement of Financial Affairs disclosing transfers, payments, and prior litigation

The consequence of confusing these is filing rejection or, worse, missed disclosures. An example: a guarantor on a real estate lease belongs on Schedule H tied to Schedule G, not on Schedule D. A misconception is that 206H replaces a creditor matrix entry; the codebtor still must be added to the creditor matrix so they receive notice.

Filing Logistics, Deadlines, and Amendments

Schedule H is filed with the petition or within 14 days under Bankruptcy Rule 1007(c). Extensions are possible “for cause” but require a motion.

The consequence of missing the deadline is dismissal. An example: a Chapter 7 corporate debtor in the Northern District of Illinois had its case dismissed in 2023 after failing to file Schedules D through H within 14 days. A misconception is that filing only the petition preserves the case indefinitely; it does not.

Amending Form 206H Under Rule 1009

Rule 1009(a) lets the debtor amend any schedule “as a matter of course” until the case is closed. There is no court approval needed for the amendment itself, but local rules often require notice to affected parties.

The consequence of not amending after learning of an omission is willful concealment, which can support denial of discharge. An example: when paralegal Aisha discovered an unlisted guarantor mid-case, she filed an amended Schedule H within 48 hours along with a Notice of Amended Schedules and avoided any sanction. A misconception is that amendments require a fee in every district; many districts charge an amendment fee under the Bankruptcy Court Miscellaneous Fee Schedule, but only when adding creditors, not always when adding codebtors.

Notice Obligations to Listed Codebtors

Once Schedule H is filed, the Bankruptcy Noticing Center sends each codebtor a copy of the Notice of Bankruptcy Case Filing. Codebtors get standing to appear, file proofs of claim for indemnity, and seek stay relief.

The consequence of failed notice is delay and possibly voided rulings. An example: a guarantor not properly noticed in a Chapter 11 confirmation hearing successfully moved to vacate the confirmation order in a 2020 Delaware case. A misconception is that an attorney’s email serves as official notice; only the BNC mailing satisfies Rule 2002 unless a party has consented to electronic notice.

Key Court Rulings Shaping Schedule H Practice

Several rulings have refined how courts read Schedule H disclosures. Each adds a practical lesson.

In In re Mendoza, the bankruptcy court denied discharge under § 727(a)(4) because the debtor knowingly omitted a guarantor — establishing that “knowing” omissions of codebtors are false oaths. In In re Colvin, the court held a “No codebtors” check was a material misstatement when even one guarantor existed. The Supreme Court’s 2024 decision in Harrington v. Purdue Pharma tightened third-party releases, indirectly raising the stakes of accurate Schedule H listing because non-debtor codebtors generally cannot be released without their consent.

The consequence of these rulings combined is straightforward: list every codebtor, use exact names and addresses, and amend at the first sign of error. A misconception is that Purdue Pharma changed Schedule H itself; it did not, but it removed a once-popular workaround for guarantor liability.

Key Entities You Should Know

Several institutions and roles touch every Schedule H filing. Knowing each saves time during the case.

The consequence of not knowing these players is procedural friction. An example: filer Marcus once tried to email a corrected Schedule H to the chambers of a bankruptcy judge; the chambers returned it with instructions to use CM/ECF. A misconception is that the U.S. Trustee and the case trustee are the same; they are not — the case trustee is appointed per case, while the U.S. Trustee is a national supervisory office.

Frequently Asked Questions

Is Form 206H required for every non-individual bankruptcy?

Yes. Every non-individual debtor under Chapters 7, 11, and 12 must file Form 206H, even if the answer is “no codebtors,” per Bankruptcy Rule 1007(b)(1).

Can I leave Form 206H blank if my company has no guarantors?

No. You must still file the form and check the “No” box on the threshold question; leaving it entirely blank violates Rule 9009 and can delay docketing.

Do I list a creditor’s law firm as a codebtor on Form 206H?

No. Codebtors are parties jointly liable for the debt, not collection counsel; listing a law firm misstates the liability under 11 U.S.C. § 521.

Should I include a non-filing spouse on Form 206H?

No. Form 206H is for non-individual debtors and does not include spousal disclosures; spouses appear on individual Form 106H instead.

Can I amend Form 206H after filing?

Yes. Bankruptcy Rule 1009 allows amendment as a matter of course any time before the case closes, with notice to affected parties.

Will my codebtors be notified of the bankruptcy?

Yes. The Bankruptcy Noticing Center mails a notice to every codebtor listed on Schedule H under Rule 2002.

Does discharging the debtor also discharge the codebtor?

No. Under 11 U.S.C. § 524(e), a debtor’s discharge does not affect the liability of any other entity on the same debt, except in narrow approved third-party releases.

Is there a co-debtor stay in Chapter 11 like in Chapter 13?

No. Chapter 11 has no codebtor stay; only Chapter 12’s § 1201 and Chapter 13’s § 1301 include one, and only for consumer debts.

Can omitting a codebtor lead to denial of discharge?

Yes. Under 11 U.S.C. § 727(a)(4), knowingly omitting a codebtor is a false oath and grounds for denial of discharge in Chapter 7 and similar relief in other chapters.

Is Form 206H public?

Yes. Schedule H is filed on PACER and is publicly accessible, so guarantor names and addresses become part of the public record.

Do I need to list dissolved entity guarantors on Form 206H?

Yes. If the dissolved entity remains liable on the debt under state wind-up law, list it on Schedule H with its last known address and any successor in interest.

Does Form 206H apply in a Chapter 15 cross-border case?

No. Chapter 15 cases follow § 1515 recognition rules and do not require U.S. Schedule H, though courts may request analogous disclosures.