U.S. Code » Title 11 » Chapter CHAPTER 11— REORGANIZATION › Subchapter SUBCHAPTER V— SMALL BUSINESS DEBTOR REORGANIZATION

11 U.S.C. § 1192

Discharge

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If the plan of the debtor is confirmed under section 1191(b) of this title, as soon as practicable after completion by the debtor of all payments due within the first 3 years of the plan, or such longer period not to exceed 5 years as the court may fix, unless the court approves a written waiver of discharge executed by the debtor after the order for relief under this chapter, the court shall grant the debtor a discharge of all debts provided in section 1141(d)(1)(A) of this title, and all other debts allowed under section 503 of this title and provided for in the plan, except any debt—(1) on which the last payment is due after the first 3 years of the plan, or such other time not to exceed 5 years fixed by the court; or(2) of the kind specified in section 523(a) of this title.(Added Pub. L. 116–54, § 2(a), Aug. 23, 2019, 133 Stat. 1083.)Statutory Notes and Related SubsidiariesEffective Date

Section effective 180 days after Aug. 23, 2019, see section 5 of Pub. L. 116–54, set out as an Effective Date of 2019 Amendment note under section 101 of this title.

Notes of Decisions
Cited in 36 cases (35 in the last 5 years), 1993–2026 · leading case: Avion Funding v. GFS Indus., 99 F.4th 223 (5th Cir. 2024).
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Avion Funding v. GFS Indus., 99 F.4th 223 (5th Cir. 2024). · cites it 3× “See 11 U.S.C. § 1192 (requiring court to “grant the debtor a discharge” of all specified debts (emphasis added)).”
Benshot, LLC v. 2 Monkey Trading, LLC, 142 F.4th 1323 (11th Cir. 2025). · cites it 2× “” 11 U.S.C. § 1192 . Appellant BenShot, LLC argues that Subchapter V applies to both individual and corporate debtors, so neither group can discharge debts listed under § 523(a).”
Prudential Ins. Co. of Am. v. Farley (In re Farley), 158 B.R. 48 (E.D. Pa. 1993). “Requiring Prudential to have appealed the plan, while the bankruptcy court was similarly considering whether the interest rate “cram down” conformed with 11 U.S.C. § 1192 (b), would have been “a waste of judicial resources.”
Karen W. Hall & Spuddog Farm Props. LLC - Adversary Proceeding (Bankr. M.D. Fla. 2023). · cites it 4× “The parties dispute whether the exceptions to discharge under § 523(a) apply to non- individual debtors receiving a discharge under 11 U.S.C. § 1192 . Although case law on Subchapter V is still evolving, all bankruptcy courts that have considered this issue have held that the…”
Cantwell-Cleary Co., Inc. v. Cleary Packaging, LLC (Bankr. D. Md. 2022). · cites it 4× “It argued that 11 U.S.C. § 1192 (2), which falls within Subchapter V, provides that small business debtors are not entitled to discharge “any debt .”
Halo Human Resources, LLC v. Am. Dental of LaGrange LLC (Bankr. M.D. Ga. 2025). · cites it 3× “650 , 654 (Bankr. D. Colo. 2024) (“The discharge of debt in consensual plans is governed by 11 U.”
In re: Logan Christopher Hisaw (Bankr. W.D. La. 2026). · cites it 3× “and under Article 4, herein, are enjoined from taking any action inconsistent herewith, including, but not limited to, any action to prosecute or collect any debt or Claim against any guarantor, Insider, or Affiliate; provided however, that all creditors shall retain the right…”
In Re: Revelant Holdings LLC (D. Colo. 2023). · cites it 2× “§ 523 (a)) applied to both individual and corporate debtors under 11 U.S.C. § 1192 (2), because the statutory language of § 1192(2) only carved out exceptions to the kind of debt specified in § 523(a) and did not carve out exceptions for the type of debtor.”
Ryan Louis (Bankr. C.D. Ill. 2022). · cites it 2× “11 U.S.C. §1192 . Similarly, if Attorney Pioletti had researched the issues, he would have seen another key benefit to consensual confirmation related to property of the estate and learned that property acquired post-petition is generally not property of the estate of a…”
Daren C. Daly (Bankr. S.D. Florida 2025). · cites it 2× “Except as otherwise expressly provided in the Plan or in this Confirmation Order, as of the Effective Date: (i) the Debtor shall be discharged from any debt to the fullest extent provided by 11 U.S.C. § 1192 and 1141(d); and (ii) all holders of any discharged claims against the…”
Smallhold, Inc. (Bankr. D. Del. 2025). · cites it 2× “At the same time, however, subchapter V and chapter 13 both have provisions (§§ 1141(b) and 1327(b), 51 11 U.S.C. § 1192 . 52 11 U.S.C. § 1186 (a)(1).”
Smallhold, Inc. v. Mountain Meadow Mushroom Farms (Bankr. D. Del. 2025). · cites it 2× “At the same time, however, subchapter V and chapter 13 both have provisions (§§ 1141(b) and 1327(b), 51 11 U.S.C. § 1192 . 52 11 U.S.C. § 1186 (a)(1).”
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— 11 U.S.C. § 1192(2) — 1 case
Halo Human Resources, LLC v. Am. Dental of LaGrange LLC (Bankr. M.D. Ga. 2025). “650 , 654 (Bankr. D. Colo. 2024) (“The discharge of debt in consensual plans is governed by 11 U.”
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