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Chapter 13

Completing a Chapter 13 plan: what has to happen before discharge

Making your final Chapter 13 payment does not by itself end the case. Under 11 U.S.C. § 1328, the court grants a discharge after you complete all plan payments, certify that any required domestic support obligations are current, and file proof that you finished the personal financial management course. Most districts add a local certification or motion and a short objection window first.

Key points

  • The trustee typically files a notice of plan completion once all payments are received, and that notice starts a short filing deadline for you.
  • Under 11 U.S.C. § 1328(a), the court grants the discharge after plan payments are complete and any required domestic support obligation certification is filed.
  • A missing personal financial management course certificate is the most common reason a case is closed without a discharge.
  • Long-term debts being cured under 11 U.S.C. § 1322(b)(5) and debts described in 11 U.S.C. § 523(a) are carved out of the Chapter 13 discharge.
  • Local rules control the forms and deadlines, and they differ meaningfully from district to district.

You made the last payment. That is the hard part, and it is worth saying plainly: most of the work is behind you. But the discharge order is a separate step, and in many districts a case that is otherwise finished gets closed without one because a single form never got filed. This page walks through what the court is waiting for after your final payment, who files what, and roughly how long the last stretch takes.

How does finishing a Chapter 13 plan actually work?

Completing a Chapter 13 plan is a two-part process: the trustee closes out the money, and you close out the paperwork. When the trustee determines that all plan payments have been received, the trustee files a Notice of Plan Completion with the court and serves it on you and your attorney (W.D. La. LBR 5009-1). That notice starts a short clock. Within a set number of days, you file whatever certification or motion your district requires — commonly a statement that all plan payments are complete, that any required domestic support obligations are current, and that you finished the personal financial management course. The court then reviews the docket to confirm the discharge requirements are met before entering the order (Bankr. M.D. Fla. Procedure Manual — Discharge - Chapter 13). If nothing is missing and no party objects, the discharge order is entered and the case is closed shortly afterward.

What can delay or block a discharge after the last payment?

Several things change the outcome after your final payment. The most common is a missing course certificate: the Middle District of Florida's procedure manual identifies the Certification About a Financial Management Course (Official Form 423) as the document debtors most often fail to file, and notes that a case may be closed by the clerk's office without a discharge when required documents are not timely filed. A missing domestic support certification has a similar effect — a trustee may file a notice of plan completion and ask the court not to enter a discharge (Bankr. M.D. Fla. Procedure Manual — Discharge - Chapter 13). A prior bankruptcy discharge received within the periods described in 11 U.S.C. § 1328(f) can also produce a notice of closing without discharge (W.D. La. LBR 5009-1). Creditors and the trustee generally get an objection window, and a timely objection delays entry until the court resolves it (E.D. Mich. LBR 2015-3).

What does federal law say about the Chapter 13 discharge?

11 U.S.C. § 1328(a) sets the federal rule. As soon as practicable after you complete all payments under the plan — and, where you are required by a judicial or administrative order or by statute to pay a domestic support obligation, after you certify that all amounts due on or before the certification date have been paid — the court shall grant a discharge of debts provided for by the plan, unless the court approves a written waiver of discharge you executed after the order for relief. The discharge does not reach everything. Section 1328(a) carves out long-term debts being cured under 11 U.S.C. § 1322(b)(5), certain debts described in 11 U.S.C. § 523(a), criminal restitution and fines, and restitution or damages for willful or malicious injury causing personal injury or death. Once entered, a discharge voids judgments determining personal liability on discharged debts and operates as an injunction against collection (11 U.S.C. § 524).

Where do local court rules change the steps?

Federal law says when a discharge is granted; local rules say what you file and how fast. The variation is real, so read your own district's rule or ask your attorney rather than assuming a national deadline. In the Eastern District of California you file a § 1328 certificate within 30 days of the trustee's notice, and parties then have 14 days to object to the clerk's notice of intent to enter discharge (E.D. Cal. LBR 5009-1). South Carolina splits the clock: the trustee has 45 days after the last payment, and you have 28 days after the trustee's notice (S.C. LBR 3015-5). Several districts require a motion instead of a certificate — Massachusetts, Montana, and both Indiana districts all use a motion for entry of discharge (D. Mass. LBR Appendix 1, Rule 13-22; Mont. LBR 4004-1; N.D. Ind. L.B.R. B-4004-2; S.D. Ind. B-4004-1).

Examples of local filing requirements after plan completion
DistrictWhat the debtor filesDeadline
E.D. Cal. (LBR 5009-1)Debtor's § 1328 certificate (Form EDC 3-190)30 days after the trustee's notice of completed plan payments
W.D. La. (LBR 5009-1)Statement regarding domestic support obligations and claimed homestead exemptions (Form B2830)30 days after the Notice of Plan Completion
S.C. (LBR 3015-5)Notice of Certification of Plan Completion plus the financial management course certificate28 days after the trustee's notice
D.S.D. (R. 3072-1B)Certification and Request for Discharge30 days after the trustee's Notice of Completion of Plan Payments
S.D. Ind. (B-4004-1)Motion for Entry of Discharge plus a Certification of Eligibility for each debtor30 days after the trustee's notice of completion
E.D. Va. (LBR 4008-2)Certificate of course completion45 days after the notice concerning issuance of discharge
W.D. Ky. (LBR 2083-1)Certification of Plan Completion and Request for Discharge (Local Form Q)30 days after the trustee's notice

What does the final stretch look like in practice?

A typical Chapter 13 plan runs roughly 36 to 60 months of payments to the trustee (U.S. Bankr. Ct. M.D. Ala., Anatomy of a Bankruptcy Chapter 13). Court flowcharts describe nearly the same ending sequence everywhere: finish the payments, complete the financial management course and file the certificate, respond to the notice about domestic support obligations, wait for the trustee's final report, and then the discharge order is entered and the case closes (Bankr. D. Minn. official guidance — Chapter 13 Process for Debtors without an Attorney). Timing after the last payment is usually measured in weeks to a few months rather than days, because the trustee has to reconcile disbursements and file a final report before the court acts. In the Southern District of Indiana, for example, the court issues the discharge 21 days after the required documents are filed if no objection is made (Bankr. S.D. Ind. official page — Chapter 12/13 Discharges).

  • The trustee files a notice of plan completion and, separately, a final report and account of the administration of the estate (W.D. La. LBR 5009-1).
  • You file the district's certification or motion within the local deadline, and joint debtors generally file separate ones (Bankr. D.S.D. R. 3072-1B).
  • Creditors and the trustee get an objection window — commonly 14, 21, or 30 days depending on the district (D. Mass. LBR Appendix 1, Rule 13-22; E.D. Mich. LBR 2015-3; N.D. Ind. L.B.R. B-4004-2).
  • In the Middle District of Alabama, the case is closed a minimum of 14 days after the last order in the case is entered (U.S. Bankr. Ct. M.D. Ala., Anatomy of a Bankruptcy Chapter 13).

What documents and information are involved at the end?

The end-of-case paperwork is short but unforgiving about deadlines. Most of it is certification: you are telling the court, under penalty of perjury, that the conditions for a Chapter 13 discharge have been met. In the Northern District of Indiana, the verified motion must separately affirm each statutory requirement enumerated on the local form, and a motion submitted in another form may be denied without notice or hearing (N.D. Ind. L.B.R. B-4004-2). If you owe a domestic support obligation, some districts also require the name and address of the recipient and of your employer (N.D. Ind. L.B.R. B-4004-2). Arizona requires the debtor to provide the trustee with certain information and to file a local form before the court enters the discharge (Ariz. LBR 2084-26). Keep the course completion certificate the provider issues; in a joint case, each debtor takes the course and files a separate certification.

  • The personal financial management course certificate — Official Form 423 in many districts (Bankr. M.D. Fla. Procedure Manual — Discharge - Chapter 13).
  • A certification or motion stating that all plan payments are complete (Mont. LBR 4004-1).
  • A domestic support obligation certification, where one applies, including amounts that came due after filing (Mont. LBR 4004-1).
  • A statement about homestead exemptions claimed in the case, required by several districts before discharge (E.D. Cal. LBR 5009-1).
  • Where counsel is involved, an attorney certification that the discharge requirements were explained to the debtor (Mont. LBR 4004-1).
  • Proof of service on the trustee, the U.S. Trustee, creditors, and any domestic support recipient (LAMB LBR 3015-5).

What should you ask a lawyer at this stage?

The questions worth asking at the end of a plan are narrow and practical, which makes them cheap to ask and expensive to skip. Bankruptcy court staff are limited in what they can tell you — the Middle District of Alabama states plainly that court employees cannot provide legal advice, including how to complete bankruptcy forms (U.S. Bankr. Ct. M.D. Ala., Anatomy of a Bankruptcy Chapter 13). If you are represented, your attorney's office usually handles the closing certifications, but confirm that rather than assume it. If you are not represented, the local rule for your district is the document to read, because it names the exact form and the exact number of days. Bring the trustee's notice of plan completion with you; it is the document that starts most of the deadlines and it tells the lawyer where in the sequence your case sits.

  • Which certification or motion does my district require, and what is the deadline running from the trustee's notice?
  • Has my financial management course certificate been filed, and is there a separate one on file for my spouse in a joint case?
  • Do I have a domestic support obligation certification to make, and does it cover amounts that came due after filing?
  • Which of my debts are being cured and maintained under 11 U.S.C. § 1322(b)(5) and will therefore continue after discharge?
  • Are there liens on my property that survive the discharge, and is anything worth addressing before the case closes?
  • If I cannot finish the remaining payments, is a plan modification or a hardship discharge under 11 U.S.C. § 1328(b) worth discussing?

Frequently asked questions

How long after the last payment does the discharge come?
Usually weeks to a few months, not days. The trustee first files a notice of plan completion and a final report, then you file the district's certification, then an objection window runs. In the Southern District of Indiana the court issues the discharge 21 days after the required documents are filed if no one objects (Bankr. S.D. Ind. official page — Chapter 12/13 Discharges).
What is the debtor education certificate, and when do I file it?
It is the certificate showing you completed an instructional course in personal financial management, filed as Official Form 423 in many districts (Bankr. M.D. Fla. Procedure Manual — Discharge - Chapter 13). It is a separate course from the pre-filing credit counseling. Most districts want it on file before the discharge is entered, and the Eastern District of Virginia sets 45 days from its notice (E.D. Va. LBR 4008-2).
What happens if my case closes without a discharge?
It is generally fixable. The Middle District of Florida states that it is not necessary to file a motion to reopen in order to file missing documents and receive a discharge (Bankr. M.D. Fla. Procedure Manual — Discharge - Chapter 13). Other districts do require reopening, and a reopening fee, before a discharge can be entered (KYWB LBR 2083-1; S.D. Ind. B-4004-1). Ask your district which applies.
Does the discharge remove liens on my house or car?
Generally no. A discharge order relieves the debtor of the personal obligation to pay a debt, while valid liens that existed before filing generally pass through bankruptcy unaffected — though certain liens may be avoided during the case or satisfied through the plan (Bankr. N.D. Iowa official page — FAQs: Debtor). Some districts' discharge orders direct fully paid secured creditors to deliver a release suitable for recording (E.D. Mich. LBR 2015-3).
Does my mortgage get wiped out at the end of a Chapter 13 plan?
Not if it is a long-term debt you have been curing and maintaining through the plan. 11 U.S.C. § 1328(a)(1) expressly excludes debts provided for under 11 U.S.C. § 1322(b)(5) from the discharge, which is the provision used for defaults cured over the plan on debts whose last payment falls after the plan ends. Ongoing payments continue after the case closes.
What if I cannot complete all the plan payments?
There is a narrow path. Under 11 U.S.C. § 1328(b), after notice and a hearing, a court may grant a discharge without completed payments only if the failure is due to circumstances for which the debtor should not justly be held accountable, unsecured creditors already received at least the Chapter 7 liquidation value, and plan modification is not practicable. Districts set out their own hardship procedures (S.C. LBR 3015-5).
Is the Chapter 13 discharge broader than a Chapter 7 discharge?
Somewhat. The Northern District of Iowa notes that a slightly broader discharge of debts is available in a Chapter 13 case than in a Chapter 7 case, and that 11 U.S.C. § 523(a) excepts various categories of debt from an individual debtor's discharge in either chapter (Bankr. N.D. Iowa official page — FAQs: Debtor). Which specific debts survive depends on your filings and any nondischargeability litigation.

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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