Form MSME-1: due dates, who must file, and what it means for small suppliers

Twice a year, Form MSME-1 makes a company tell the Registrar of Companies which micro and small suppliers it has kept waiting beyond 45 days, how much it owes them, and why. The next one, for April to September 2026, is due by 31 October 2026. Here is who files it, what it asks, what skipping it costs, and what it means for the small firm waiting to be paid.

What Form MSME-1 is

MSME-1 (officially “MSME Form I”) comes from an order the Ministry of Corporate Affairs issued on 22 January 2019 under Section 405 of the Companies Act, 2013, which lets the government require companies to furnish information. It gives a form to a November 2018 direction that companies paying micro and small suppliers beyond 45 days report, each half-year, the amount due and the reasons for the delay. It is filed online with the Registrar and signed digitally by a director or another authorised officer.

Who must file it

The order calls them “specified companies”: companies that buy goods or services from micro and small enterprises and pay them more than 45 days after the goods or services were accepted, or deemed accepted. An amendment dated 15 July 2024 narrowed this: only companies with payments pending to a micro or small enterprise for more than 45 days now file. Three boundaries:

• Companies only. The order is made under the Companies Act, so LLPs, partnerships and proprietorships do not file MSME-1, whatever they owe. A foreign company is covered for its business in India; the 2024 form takes a foreign company registration number.
• Micro and small suppliers only. Dues to medium enterprises are not reported.
• No size test for the buyer. The order applies to all companies, however small.

Due dates: 31 October and 30 April

Paragraph 3 of the 2019 order fixes two dates: the return for April to September is due by 31 October, and the return for October to March by 30 April. The 2024 amendment did not change them, and as of 23 October 2026 we found no MCA extension for the current half-year.

What the return asks for

The 2019 form asked for each supplier’s name, PAN, amount due and the date it fell due, plus the reasons for delay. The form substituted in July 2024 goes further. For the period chosen, it asks supplier by supplier (name and PAN) for the number and amount of payments:

• paid within 45 days, split between TReDS (the RBI-authorised platforms for settling MSME invoices) and other modes;
• paid after 45 days;
• outstanding for 45 days or less;
• outstanding for more than 45 days.

It also wants, against each supplier, the reason for the delay or for the amount still outstanding. In practice that means a payables ageing by supplier, tied to acceptance dates.

Is a nil return required?

No. Since July 2024 only companies with payments pending to a micro or small enterprise for more than 45 days must file, so a company with nothing overdue files nothing. One point is unsettled: a note on the form also asks for amounts “liquidated after 45 days”, and professionals disagree on whether a company that paid late during the half-year, but owes nothing overdue at its end, must still file. If that is you, decide it with your company secretary and note why.

Penalty for not filing

The penalty comes from Section 405(4) of the Companies Act, as substituted by the Companies (Amendment) Act, 2020 with effect from 21 December 2020. If a company fails to comply with an order under Section 405, or furnishes information that is incorrect or incomplete in a material respect, the company and every officer in default are liable to a penalty of Rs 20,000, plus Rs 1,000 for each day after the first that the failure continues, up to a maximum of Rs 3 lakh. Section 446B softens this for small companies, one person companies, start-ups and producer companies: no more than half the penalty, capped at Rs 2 lakh for the company and Rs 1 lakh for an officer. Filing wrong or incomplete numbers is penalised the same way.

What it means if you are the supplier

You do not file MSME-1; your buyer does. But it is one of three pressures on a company that pays a small supplier late, and all three bite only if the buyer knows you are micro or small:

• MSMED Act. A registered micro or small supplier must be paid by the agreed date, and the agreed period cannot exceed 45 days from acceptance. After that the buyer owes compound interest, with monthly rests, at three times the RBI bank rate.
• Income tax. Under Section 43B(h), which continues as Section 37(2)(g) of the Income-tax Act, 2025 from FY 2026-27, a buyer that pays late cannot deduct the expense until the year it actually pays.
• Company law. The overdue amount, and the buyer’s reason for it, goes into a return filed with the Registrar.

Our guide to Udyam and the 45-day rule covers the first two. The practical point: register on Udyam (it is free) and put your Udyam number on every invoice and vendor form, because a finance team can only report, and prioritise, a supplier it knows is micro or small. Parts of the MSMED (Amendment) Act, 2026 came into force on 15 October 2026; they leave the 45-day and interest rules (Sections 15 and 16) unchanged.

What to do this week

If your company buys from micro or small firms:

• Flag suppliers whose Udyam registration shows micro or small, and ask the rest.
• List their invoices with acceptance and payment dates for April–September 2026, plus older unpaid ones.
• If anything is pending beyond 45 days, file by 31 October 2026 with a real reason for each delay.
• Paid late but nothing pending? Settle the filing question with your CS and record it.
• Pay what is overdue: the interest compounds, and the tax deduction waits.
• Put 30 April 2027 on the calendar.

If you are the small supplier:

• Check that your Udyam registration is current and shows micro or small.
• Add the Udyam number to your invoice template and send the certificate to each corporate client’s accounts team.
• Note when each client accepted your work; the 45 days run from acceptance or deemed acceptance.
• Follow up before day 45. For a badly overdue invoice, our 45-day post covers the MSME Samadhaan complaint route.

If your firm files MSME-1 for clients, HireMaze can run the lead-up: a document request for each client’s supplier ageing, reminded automatically after three days and with a review step, and a task with an owner and a 31 October due date on a board the whole firm can see.

Frequently asked questions

What is the due date for Form MSME-1?

31 October for the April–September half-year and 30 April for the October–March half-year. The April–September 2026 return is due by 31 October 2026, and the October 2026–March 2027 return by 30 April 2027.

Who needs to file MSME Form 1?

A company that buys goods or services from micro or small enterprises and has payments to them pending for more than 45 days from acceptance or deemed acceptance. LLPs, partnerships and proprietorships do not file it, and dues to medium enterprises are not reported.

Is a nil MSME-1 return required?

No. Since July 2024 only companies with payments pending to a micro or small enterprise for more than 45 days must file. Whether a company that paid late but owes nothing overdue at the half-year end must still file is disputed, so check with your company secretary.

What is the penalty for not filing Form MSME-1?

Under Section 405(4) of the Companies Act, 2013, the company and every officer in default are liable to a penalty of Rs 20,000, plus Rs 1,000 for each day after the first that the failure continues, up to Rs 3 lakh. Small companies, one person companies, start-ups and producer companies pay at most half, under Section 446B.

Does a micro or small supplier file MSME-1?

No. The buying company files it. What the supplier controls is whether the buyer knows it is micro or small: keep your Udyam registration current and put the number on every invoice.