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Form DE-172, Creditor's Claim (Probate), page 1
Moderate · 54/100Form Complexity Index

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What this form asks for

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California Form DE-172, also known as the Creditor's Claim, is a mandatory form for any individual or entity seeking to collect a debt from a deceased person's estate. Filing this claim with the probate court and serving it to the personal representative is a critical step to ensure the debt is considered for payment before the estate's assets are distributed. Today, this form can be filled out quickly and accurately using AI-powered services like Instafill.ai, which can also convert non-fillable PDF versions into interactive fillable forms.
Fillable fields112
Pages2
Form Complexity IndexModerate, 54/100

The AI checks your answers before you download

14 checks built for this form, so a wrong date or a missing answer is caught before anyone else sees it.

Ensures Claim Amount Consistency

The 'Total amount of the claim' listed in Box 1 on the first page must be a valid positive number. This amount must exactly match the calculated 'TOTAL' of the itemized claims listed on the second page. This check prevents mathematical errors and ensures the claim's primary value is consistent throughout the document, which is critical for court processing. If the amounts do not match, the claim could be rejected for ambiguity.

Verifies Claimant Identification

The 'Claimant (name)' field in Box 2 must be completed, and exactly one checkbox from options 2a through 2e must be selected to identify the claimant's entity type. This is essential for establishing the legal identity of the creditor. A failure to provide this information will render the claim invalid as the estate cannot verify who is making the claim.

Validates 'Other' Claimant Type Specification

If checkbox 2e ('other') is selected to describe the claimant's entity type, the adjacent text field specifying the type must be filled in. This provides necessary clarification when the standard categories do not apply. An empty specification field makes the claimant's legal status unclear and may lead to rejection of the form.

Checks Claimant Authority Declaration

In Box 4, one of the two checkboxes must be selected to declare whether the filer is the creditor or a person acting on their behalf. If 'a person acting on behalf of creditor' is selected, the reason must be provided in the space indicated. This validation confirms the filer's legal standing to submit the claim, and failure to complete it properly can invalidate the submission.

Confirms Location of Supporting Facts

In Box 5, the filer must check either 'on reverse' or 'attached' to indicate where the detailed facts supporting the claim are located. This directs the court and personal representative to the full itemization and evidence for the debt. If neither is selected, the claim may be considered incomplete and unsupported.

Validates Page 1 Signature and Date

The signature block on page 1 must include a valid date and a typed or printed name of the signatory. The date must be a valid calendar date and cannot be in the future. This is required for the declaration under penalty of perjury, and an missing or invalid date can nullify the legal statement.

And 8 more checks
  • Ensures Case Information Consistency
  • Validates Itemized Claim Dates
  • Verifies Itemized Claim Amount Format
  • Requires Proof of Service Method Selection
  • Validates Mail Service Details Completeness
  • Validates Personal Delivery Details Completeness
  • Checks Proof of Service Signature Date Logic
  • Requires Claimant Address

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How to Fill Out DE-172 Online for Free in 2026

What the AI walks you through.

  1. Navigate to Instafill.ai and upload or select the Form DE-172, Creditor's Claim.
  2. Provide the court and estate information, including the county, court address, estate name, and case number.
  3. Enter your details as the claimant, including your name, address, and your status (e.g., individual, corporation).
  4. Specify the total amount of the claim and provide a detailed itemization on the second page, including dates, descriptions, and amounts for each item.
  5. Attach any required supporting documents, such as a copy of a note or written instrument.
  6. Review all entered information for accuracy, then sign and date the claim under penalty of perjury.
  7. Download the completed form to file with the court clerk and serve a copy to the estate's personal representative and their attorney.

Common Mistakes in Completing DE-172

The ones the AI is built to catch.

Inconsistent or Incorrect Claim Amount
Claimants often enter a total claim amount in Section 1 that does not match the sum of the itemized amounts listed on the second page. This usually happens due to manual calculation errors or last-minute changes to one section but not the other. An inconsistent amount creates ambiguity, will likely lead to a request for clarification, and can delay the processing and payment of a valid claim. To avoid this, double-check your math and ensure both figures are identical before filing.
Vague or Insufficient Claim Description
In the 'Facts supporting the claim' section, many claimants provide vague descriptions like 'personal loan' or 'services rendered' without necessary details. The instructions require itemizing the claim and describing the service or debt in detail, including dates. A vague claim makes it impossible for the estate's representative to verify its legitimacy, often resulting in an automatic rejection and forcing the creditor into a more complex and costly legal process to prove the debt.
Forgetting to Complete the Proof of Service
The 'Proof of Mailing or Personal Delivery' on the second page is a legally required declaration that is frequently overlooked or filled out incorrectly. Claimants may forget to sign this section, choose the wrong delivery method, or fail to fill it out at all. Without a properly executed Proof of Service, there is no legal evidence that the claim was sent to the estate's representative, which can invalidate the entire claim even if it was filed correctly with the clerk.
Failing to Attach Supporting Documents
The form instructions state that if a claim is based on a written instrument like a promissory note, contract, or invoice, a copy must be attached. Claimants frequently forget to include this crucial evidence, submitting only the form itself. This omission makes the claim incomplete and gives the personal representative a valid reason to reject it, as there is no provided proof of the underlying obligation. Always gather and attach all relevant documentation before filing.
Incorrectly Identifying the Claimant Entity
In Section 5, individuals may select the wrong entity type, such as a sole proprietor checking 'an individual' instead of 'an individual or entity doing business under the fictitious name of...'. This mistake can create legal challenges regarding the true identity of the creditor and whether the person signing has the authority to act. Such errors can lead to the claim being disputed on technical grounds, delaying or jeopardizing payment.
Mistaking Service for Filing
A critical error is mailing a copy to the personal representative but failing to file the original document with the court clerk's office as instructed. The form's warning explicitly states that the claim is invalid if not filed on time with the court. This mistake often stems from misunderstanding the two distinct requirements: notifying the estate and formally lodging the claim with the judicial system. Since many court forms are only available as non-fillable PDFs, tools like Instafill.ai can convert them into fillable versions and help guide users through the process to avoid such procedural errors.
Including Debts Incurred After Death
The instructions on the reverse side clearly state not to include debts incurred after the date of the decedent's death, with the exception of funeral claims. However, claimants sometimes mistakenly itemize charges or services that occurred after the individual passed away. This will lead to the rejection of those specific line items and can cast doubt on the accuracy of the entire claim, complicating the approval process.
Missing Signatures or Dates
An unsigned legal document is invalid, yet claimants often forget to sign in one of the two required places: the main claim declaration on page one and the Proof of Service declaration on page two. A missing signature or date is an immediate red flag for the court clerk and the estate's representative, and it will result in the form being rejected or returned. Always perform a final review to ensure both signature lines are properly signed and dated.
Using Incorrect Case Information
Entering the wrong 'Estate of' name or 'Case Number' in the header is a common data entry error. This information must exactly match the court's records for the probate case. An incorrect case number can cause the claim to be misfiled or rejected by the court clerk, potentially causing you to miss the strict filing deadline. To prevent this, carefully copy the information from the 'Notice of Administration' or other official court documents. AI-powered tools like Instafill.ai can help by saving and accurately auto-filling repetitive case information across multiple documents.

Frequently Asked Questions About DE-172

 

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This plan is for your DE-172: your own AI agent fills it as often as 5 times a month. To fill other forms and upload your own, choose a Professional plan from your account.
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How does the AI fill out DE-172?
You answer a few questions in plain words, or upload a document you already have. The AI reads what you give it and puts each answer into the right field of DE-172, on every page, in seconds. It checks the answers against the form's own rules, and you review and change anything before you download, print or sign.
What happens to my information?
It is encrypted in transit and at rest, and it is never used to train AI.
How complex is DE-172 to fill out?
DE-172 has a Form Complexity Index of 54 out of 100, in the moderate tier: 112 fillable fields across 2 pages. Instafill.ai's AI fills it in under a minute, with every field there for you to review before you download.
What is the purpose of the Creditor's Claim (DE-172) form?
This form is used to make a formal claim for money or property that a deceased person owed you. It must be filed with the court and sent to the personal representative of the deceased person's estate.
Who needs to fill out this form?
Any individual, business, or other entity that is owed a debt by a person who has passed away must fill out this form to seek repayment from the estate.
What is the deadline for filing a Creditor's Claim?
You must file the claim before the LATER of four months after the personal representative was appointed, or sixty days after you received a Notice of Administration from the estate.
Where do I submit this form?
You must file the original, completed form with the court clerk at the Superior Court address listed at the top of the form. You must also mail or deliver a copy to the personal representative and their attorney.
What is the 'Proof of Mailing or Personal Delivery' section for?
This section on the back of the form is your sworn statement that you have sent a copy of the claim to the estate's personal representative. You must complete this section for your claim to be valid.
What information do I need to provide to support my claim?
You must itemize the claim on the reverse side, showing the date the debt was incurred, a detailed description of the item or service, and the amount claimed for each. Do not include debts incurred after the date of death, except for funeral claims.
What if my claim is secured by a loan or other written document?
If your claim is secured by a note or other written instrument, you must attach a copy of that document to your claim form. If the original is unavailable, you must state the reason why.
What happens after I file my claim?
After you properly file the claim with the court and serve the personal representative, the personal representative or their attorney will notify you whether your claim has been allowed or rejected.
What if the amount of my claim is not yet certain or depends on a future event?
If your claim is not yet due, is contingent, or the amount is not yet ascertainable, you must state the specific facts supporting the claim in the space provided.
Can I use AI to help me fill out this form?
Yes, services like Instafill.ai use AI to help you accurately auto-fill form fields from your saved information, which can save time and reduce errors.
How can I fill out the Creditor's Claim form online?
You can use a service like Instafill.ai to upload the PDF form, fill it out interactively on your computer, and then download the completed document for printing and filing.
The PDF of the form I have is not fillable. What can I do?
If you have a non-fillable PDF, you can use a tool like Instafill.ai. It can convert flat, non-fillable PDFs into interactive forms that you can easily type into.
How should I send the form to the court and the personal representative?
You should mail or take the original claim to the court clerk's office for filing, preferably using certified mail with a return receipt. A copy should be mailed or personally delivered to the personal representative and their attorney.
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California state forms: Judicial Council of California Form DE-111, Petition for Probate (Probate—Decedents Estates), DS 1891, Applicant/Vendor Disclosure Statement (State of California Department of Developmental Services), Judicial Council of California Form DE-120, Notice of Hearing—Decedent's Estate or Trust, Judicial Council of California Form DE-120, Notice of Hearing—Decedent's Estate or Trust, Murrieta Police Department Citizen Complaint Form (California Penal Code § 148.6 Advisory Statement), California Department of Social Services, Sworn Statement, State of California Department of Transportation California Civil Rights Laws Certification, State of California Department of Transportation Darfur Contracting Act Certification, Form DOT ADM-0077, State of California Department of Transportation, Contract Requirements, State of California Department of Transportation Subcontractor List, State of California Department of Transportation, Certified DVBE Summary, Bidder Declaration GSPD-05-105, State of California Level of Care Rate Determination Protocol Matrix, State of California Accessible Form, State of California Form SOC 321, Request for Order and Consent - Paramedical Services, State of California Darfur Contracting Act Certification, State of California Department of Veterans Affairs COMMERCIALLY USEFUL FUNCTION (CUF) CERTIFICATION FORM, Form ADR-100, Statement of Agreement or Nonagreement, Civil Appeal Case Information Statement, Form APP-014, Appellant's Proposed Statement on Appeal (Unlimited Civil Case)

California court forms: Judicial Council of California Form SC-105, Request for Court Order and Answer (Small Claims), Judicial Council of California Form SC-120, Defendant’s Claim and ORDER to Go to Small Claims Court (Small Claims), Judicial Council of California Form SER-001, Request for Sheriff to Serve Court Papers, Judicial Council of California Form SER-001, Request for Sheriff to Serve Court Papers, Affidavit for Collection of Personal Property California Probate Code Section 13100, Form POS-040, Proof of Service—Civil, Declaration of Facts of Death (California Superior Court), declaration-of-marriage-for-court-proceeding-california-family-law, ADOPT-200, Adoption Request, ADOPT-200, Stepparent Adoption Request, ADOPT-210, Adoption Agreement, ADOPT-310, Contact After Adoption Agreement, Judicial Council of California Form ADOPT-200, Adoption Request, Form ADR-107, Mediation Attendance Sheet, Form ADR-110, Order Appointing Referee, Form ADR-109, Stipulation or Motion for Order Appointing Referee, Form ADR-102, Request for Trial De Novo After Judicial Arbitration, Form ADR-108, Referee's Report (Code Civ. Proc., §§ 638, 639), Form ADR-106, Petition to Confirm, Correct, or Vacate Contractual Arbitration Award, Form ADR-104, Rejection of Award and Request for Trial After Attorney-Client Fee Arbitration

California probate forms: Judicial Council of California Form DE-111, Petition for Probate (Probate—Decedents Estates), Affidavit for Collection of Personal Property California Probate Code Section 13100, Form DE-142/DE-111(A-3e), Waiver of Bond by Heir or Beneficiary (Probate—Decedents Estates), Form DE-140, Order for Probate, Form DE-150, Letters (Probate), Form DE-154/GC-035, Request for Special Notice (Probate), Form DE-157, Notice of Administration to Creditors, Form DE-120(P), Proof of Personal Service of Notice of Hearing—Decedent's Estate or Trust, Form DE-131, Proof of Subscribing Witness (Probate), Form DE-174, Allowance or Rejection of Creditor's Claim, Form DE-221, Spousal or Domestic Partner Property Petition (Probate—Decedents Estates), Form DE-270 / GC-070, Ex Parte Petition for Authority to Sell Securities and Order, Form DE-315, Order Determining Succession to Primary Residence, Form DE-351/GC-101, Order Appointing Guardian Ad Litem—Probate, Form DE-115/GC-015, Notice of Hearing on Petition to Determine Claim to Property, Attachment to Notice of Hearing Proof of Service by Mail (Probate—Decedents' Estates and Guardianships and Conservatorships), Attachment to Notice of Hearing Proof of Personal Service (Probate—Decedents' Estates and Guardianships and Conservatorships), Form DE-125, Summons (Probate), Form DE-147, Duties and Liabilities of Personal Representative, Form DE-147S, Confidential Supplement to Duties and Liabilities of Personal Representative (Probate)

court claim forms: Form SC-100, Plaintiff's Claim and ORDER to Go to Small Claims Court, Judicial Council of California Form SC-105, Request for Court Order and Answer (Small Claims), SC-120, Defendant’s Claim and ORDER to Go to Small Claims Court (Small Claims), SC-105, Request for Court Order and Answer (Small Claims), Judicial Council of California Form SC-120, Defendant’s Claim and ORDER to Go to Small Claims Court (Small Claims), Form SC-100, Plaintiff’s Claim and ORDER to Go to Small Claims Court, Certificate of Service (Civil Court Claim), Form N161, Appellant’s notice (All appeals except small claims track appeals and appeals to the Family Division of the High Court), Plaintiff's Claim and ORDER to Go to Small Claims Court (SC-100), Form N161, Appellant's Notice (All appeals except small claims track appeals and appeals to the Family Division of the High Court), Form SC-100A, Other Plaintiffs or Defendants (Attachment to Plaintiff's Claim and ORDER to Go to Small Claims Court), Form N461: Claim for judicial review, Statement of Small Claim and Notice, Trial Court of Massachusetts, State of Michigan, Form MC 25, Notice of Intent to Escheat Unclaimed Personal Property, Form MC 35, Complaint, Claim and Delivery, Form MC 36, Motion for Possession Pending Judgment, Claim and Delivery, Order of Possession Pending Judgment, Claim and Delivery, Form MC 38, Bond, Claim and Delivery, Form MC 39, Judgment, Claim and Delivery, Form MC 55, Claim of Appeal

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