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Chapter 13

What Happens After a Chapter 13 Case Closes

After the last plan payment, the Chapter 13 trustee files a final report and account, the court reviews whether the discharge requirements are met, and a discharge order is entered. Closing is a separate, later step: under 11 U.S.C. § 350(a), the court closes the case after the estate is fully administered and the trustee is discharged.

Key points

  • Finishing plan payments, receiving a discharge, and having the case closed are three separate events that happen in that order.
  • Under 11 U.S.C. § 1328(a), a Chapter 13 discharge comes as soon as practicable after the debtor completes all plan payments, and after certifying any required domestic support obligation payments.
  • Some courts require a financial management course certificate and a domestic support certification on file before a discharge is entered.
  • A discharge relieves personal liability on debts provided for by the plan, but 11 U.S.C. § 1328(a) lists categories that are excepted from it.
  • Under 11 U.S.C. § 350(b), a closed case can be reopened to administer assets, to accord relief to the debtor, or for other cause.

You made the final payment. Now you are waiting, and it is not obvious what you are waiting for. The paperwork that arrives next uses words like "final report," "discharge," and "final decree," and they do not mean the same thing. This page walks through what generally happens between your last payment and the day the case file is closed, and what carries on afterward.

How does the end of a Chapter 13 case actually work?

Three distinct things happen, usually in this order. First, you finish the payments your confirmed plan required. Court flowcharts commonly place that at month 36 to 60 of the case; the Minnesota bankruptcy court's Chapter 13 flowchart describes plan length as typically three to five years. Second, the discharge is entered. Under 11 U.S.C. § 1328(a), the court grants the discharge as soon as practicable after you complete all payments under the plan, and, where a judicial or administrative order or statute requires you to pay a domestic support obligation, after you certify that amounts due on or before the certification date have been paid. Third, the case is closed. Under 11 U.S.C. § 350(a), the court closes the case after the estate is fully administered and the trustee has been discharged. Closing is administrative housekeeping, not the moment your debts are addressed.

  • Final plan payment — you have done your part
  • Trustee's final report and account — the trustee accounts for what was collected and paid out
  • Discharge order — the court order addressing personal liability on covered debts
  • Case closed — the file is administratively shut under 11 U.S.C. § 350(a)

What changes the answer for your case?

Several things move the timeline or the outcome. Whether you filed a required certification about a personal financial management course matters: the Central District of Illinois practice guide states that generally no discharge will be entered for an individual debtor unless, among other things, the debtor has received and filed that certificate of completion unless the court has waived or excused it. Whether you owe a domestic support obligation matters, because 11 U.S.C. § 1328(a) conditions the discharge on that certification. Whether the plan was actually completed matters: 11 U.S.C. § 1328(b) allows a court, after notice and a hearing, to grant a discharge to a debtor who has not completed payments only on the narrow conditions listed there. And whether anyone objected to the trustee's final report matters, because that objection window is what allows the case to be presumed fully administered.

Three endings that are often confused
EventWhat it addressesAuthority in this packet
DischargePersonal liability on debts provided for by the plan, with exceptions11 U.S.C. § 1328
Case closedThe court's administrative file after full administration11 U.S.C. § 350(a)
Case reopenedLater relief, asset administration, or other cause11 U.S.C. § 350(b)

What does federal law say about closing and discharge?

Two provisions carry most of the weight. 11 U.S.C. § 350(a) says that after an estate is fully administered and the court has discharged the trustee, the court shall close the case. Section 350(b) says a case may be reopened in the court in which it was closed to administer assets, to accord relief to the debtor, or for other cause. On the discharge side, 11 U.S.C. § 1328(a) directs the court to grant a discharge of all debts provided for by the plan or disallowed under section 502, except the categories listed in paragraphs (1) through (4) — including debts provided for under section 1322(b)(5), debts of the kinds specified in listed paragraphs of section 523(a), restitution or criminal fines included in a criminal sentence, and restitution or damages awarded in a civil action for willful or malicious injury causing personal injury or death.

  • Fed. R. Bankr. P. 5009(a) presumes a Chapter 7, 12, or 13 estate fully administered when the trustee files a final report and final account certifying full administration and no objection is filed by the United States trustee or a party in interest within 30 days.
  • Fed. R. Bankr. P. 5009(d) lets a Chapter 12 or 13 debtor move for an order declaring that a secured claim has been satisfied and the lien released under the terms of the confirmed plan.
  • 11 U.S.C. § 524 describes the effect of a discharge, including that it operates as an injunction against acts to collect a discharged debt as a personal liability of the debtor.

Where do local court rules change the closing steps?

The federal framework is uniform, but the mechanics of getting from final payment to a closed file vary by district, and that is where people get surprised. In New Hampshire, LBR 2015-5 says that when the trustee determines the plan has been completed the trustee may file an Interim Report and Account, that a Final Report and Account is filed in accordance with United States Trustee guidelines indicating the case is ready to be closed, and that under 11 U.S.C. § 350(a) and Bankruptcy Rule 5009(a) a case will not be closed until at least 30 days after the Final Report and Account is filed. In the Southern District of Illinois, the court's Chapter 13 flowchart directs the debtor to file a motion for discharge within 21 days of the report of plan completion, and shows the case closing a minimum of 14 days after the last order is entered. Check your own district's rules.

  • Bankr. D. Mass. Rule 3011-1 requires the Chapter 13 trustee, before closing, to file a Trustee's Final Distribution Report in a form approved by the United States trustee.
  • The Middle District of Alabama's Chapter 13 anatomy chart shows a Rule 9007-1 motion for discharge after plan completion, then the financial management certificate, then discharge, then closing at least 14 days after the last order.

What does the end of a case look like in practice?

In the Middle District of Florida, the procedure manual describes the sequence concretely: when the Chapter 13 trustee files a Notice of Completion of Plan, the court reviews the docket to determine whether all requirements for entering a discharge have been met. That review checks that the debtor is an individual, that no waiver of discharge or order withholding discharge is in place, and that a Statement of Completion of Course in Personal Financial Management has been filed or waived. In a joint case, if only one spouse meets the criteria, only that spouse is eligible for a discharge. That manual also notes that the Chapter 13 trustee may sometimes file a Notice of Completion of Plan and ask the court not to enter a discharge — for example, where the debtor has not filed the required domestic support certificate. A case can be closed without a discharge if required documents were not timely filed.

  • Bankr. M.D. Fla. guidance states it is not necessary to file a motion to reopen the case in order to file the missing document and receive a discharge in that situation.
  • The most commonly missed filing named there is the Certification About a Financial Management Course (Official Form 423); in a joint case each debtor must take the course and file separately.

What documents and paperwork are involved at the end?

Expect a short stack, mostly generated by other people. The trustee produces a final report and account; Fed. R. Bankr. P. 5009(a) ties the presumption of full administration to that filing plus a 30-day objection window. You may be responsible for a certification about completing a personal financial management course — Official Form 423 in the Middle District of Florida's description — and, where applicable, a certification about domestic support obligations under 11 U.S.C. § 1328(a). Some districts require a motion for discharge from you rather than treating it as automatic. Keep the discharge order itself. The District of Maryland's debtor FAQs note that copies of bankruptcy records can be viewed and printed at the clerk's office, and that documents are also available online through PACER with an account. Storing your own copy is cheaper and faster than requesting one later.

  • Trustee's final report and account, and in Massachusetts a Trustee's Final Distribution Report before closing
  • Certificate of completion for the personal financial management course, where required
  • Domestic support obligation certification, where a court order or statute requires those payments
  • The discharge order — the document creditors and credit reporting disputes will ask about

What should you ask a lawyer about the end of your case?

This page is general information, not advice about your case, and the end of a Chapter 13 is exactly where the general rule and the individual docket tend to diverge. Ask which of your debts fall inside the exceptions listed in 11 U.S.C. § 1328(a), because that answer is specific to your claims. Ask whether any lien survives: the Northern District of Iowa's debtor FAQs state that a discharge order relieves the debtor of the personal obligation to pay, and that valid liens against property existing before filing generally pass through bankruptcy unaffected, though certain liens may be avoided or satisfied through a plan. Ask whether a Fed. R. Bankr. P. 5009(d) motion to declare a lien satisfied makes sense for your mortgage or car. And ask what happens to any codebtor, since 11 U.S.C. § 1301(a) ties the codebtor stay to the case not being closed, dismissed, or converted.

  • Which of my debts are excepted from discharge under 11 U.S.C. § 1328(a)?
  • Do I need a Rule 5009(d) order declaring a secured claim satisfied and the lien released?
  • Is anything still outstanding that could delay or block the discharge order?
  • What changes for anyone who cosigned a consumer debt with me?

Frequently asked questions

How long after the final payment does the Chapter 13 discharge arrive?
11 U.S.C. § 1328(a) says the court grants the discharge as soon as practicable after the debtor completes all plan payments and files any required domestic support certification. It is not instant. Local steps add time — New Hampshire's LBR 2015-5 says a case will not be closed until at least 30 days after the trustee's Final Report and Account is filed.
Is a discharged case the same as a closed case?
No. The discharge is the court order addressing your personal liability on debts provided for by the plan under 11 U.S.C. § 1328. Closing is separate: under 11 U.S.C. § 350(a), the court closes the case after the estate is fully administered and the trustee has been discharged. A case can also be closed without a discharge if required documents were not timely filed.
Can a Chapter 13 case be reopened after it closes?
Yes. 11 U.S.C. § 350(b) allows a case to be reopened in the court where it was closed to administer assets, to accord relief to the debtor, or for other cause. The District of Massachusetts FAQs state that any party in interest may file a motion to reopen with the applicable filing fee, and the judge decides whether to reopen and may hold a hearing.
Does the discharge remove liens on my house or car?
Generally no. The Northern District of Iowa's debtor FAQs state that a discharge order relieves the debtor of the personal obligation to pay, while valid liens that existed before the filing generally pass through bankruptcy unaffected. Some liens may be avoided or satisfied through the plan, and Fed. R. Bankr. P. 5009(d) allows a Chapter 12 or 13 debtor to move for an order declaring a secured claim satisfied and the lien released.
What if I could not finish all the plan payments?
There is a separate route. 11 U.S.C. § 1328(b) allows the court, after notice and a hearing, to grant a discharge to a debtor who has not completed payments, but only where the failure is due to circumstances for which the debtor should not justly be held accountable, unsecured creditors already received at least Chapter 7 liquidation value, and modification under section 1329 is not practicable.
What happens to someone who cosigned a debt with me?
The codebtor stay in 11 U.S.C. § 1301(a) generally bars a creditor from collecting a consumer debt from an individual liable with the debtor, but it stops applying once the case is closed, dismissed, or converted to a case under chapter 7 or 11. Section 1301(c) also lets the court grant relief from that stay earlier in specified circumstances.
Do I still owe the Chapter 13 filing fee at the end?
Fees are paid at the front of the case, not the end. The Chapter 13 filing fee is $235 under 28 U.S.C. § 1930(a)(1)(B), plus a $78 administrative fee under the Bankruptcy Court Miscellaneous Fee Schedule, Item 8. 11 U.S.C. § 1325(a)(2) requires that any fee, charge, or amount required to be paid before confirmation has been paid.

Sources

By Antonio G. Jimenez, Esq. · Florida Bar No. 21022

Last reviewed July 26, 2026 · Sources verified July 26, 2026 · How we verify

Every figure on this page is drawn from a primary legal source and checked against our canonical legal database before publication. Bankruptcy.law is not a law firm and does not provide legal advice.

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