Form MSME-1 Due Date 31 October 2026: Who Must File, the 45-Day Rule and Penalties

If your company buys goods or services from small vendors, there is a compliance deadline coming up that is easy to miss. The half-yearly Form MSME-1 for the period April to September 2026 is due on 31 October 2026. Missing it, or filing it with wrong figures, can lead to penalties for the company and for its officers.

This guide explains what Form MSME-1 is, which companies must file it, how the 45-day payment rule works and what a default can cost.

What Is Form MSME-1?

Form MSME-1 is a return prescribed by the Ministry of Corporate Affairs (MCA) under Section 405 of the Companies Act, 2013. Through it, specified companies disclose payments they owe to Micro and Small Enterprise suppliers that have remained pending beyond the permitted time.

The idea is simple. Small suppliers often struggle with cash flow when large buyers pay late. By asking companies to report delays to the Registrar, the law adds transparency and gives a nudge towards timely payment.

Who Needs to File Form MSME-1?

The requirement comes from the Specified Companies (Furnishing of Information about Payment to Micro and Small Enterprise Suppliers) Order, 2019, as amended in 2024.

A company must file when it has amounts pending to a Micro or Small Enterprise supplier for more than 45 days from the date the goods or services were accepted, or deemed to be accepted.

Two points deserve attention:

• Only Micro and Small suppliers count. A vendor classified purely as a Medium Enterprise is not covered by this return.
• Supplier status must be verified. Do not assume a vendor’s classification. Check the vendor’s enterprise registration before deciding whether a payment is reportable.

Understanding the 45-Day Payment Rule

The payment timelines come from Section 15 of the Micro, Small and Medium Enterprises Development (MSMED) Act, 2006.

• Where there is a written agreement between buyer and supplier, the agreed credit period cannot go beyond 45 days from acceptance or deemed acceptance.
• Where there is no written agreement, the shorter statutory timeline under the Act applies.

For example, suppose a company accepts a consignment of raw material from a Micro Enterprise on 1 July, and the invoice is still unpaid after 45 days. That outstanding amount needs to be examined for reporting in the next MSME-1 return.

A practical tip: record the date of acceptance for every invoice, not just the invoice date. The clock runs from acceptance or deemed acceptance, and this is where many companies slip.

Who Is a “Specified Company” for Form MSME-1?

Form MSME-1 is not required of every company. Only a specified company has to file it. A company becomes a specified company when both of the following conditions are met:

1. It buys goods or services from Micro or Small Enterprises. The company must have such suppliers on its vendor list.
2. It has not paid those suppliers within 45 days. The payment remains pending beyond 45 days from the date the goods or services were accepted, or deemed to be accepted.

If either condition is missing, the filing obligation does not arise for that period. For example, a company that buys only from large vendors, or one that pays all its Micro and Small suppliers within 45 days, has nothing to report.

Due Dates for Form MSME-1

The return is filed twice in a financial year, wherever applicable.

Reporting Period	Due Date
April to September	31 October
October to March	30 April

So for the April–September 2026 period, the due date is 31 October 2026, unless the MCA notifies an extension. Since extensions are never certain, it is safer to plan for the original date.

What Information Is Required?

The form asks for the company’s identification details, such as its CIN and registered office, along with supplier-wise information on reportable payments. Depending on the fields, this includes outstanding amounts and the reasons for delay.

The revised form introduced in July 2024 also covers amounts that were paid after the permitted 45-day period. Companies should therefore work from the latest form and instructions on the MCA portal rather than reusing an older template.

Step-by-Step Filing Process

1. Identify covered suppliers. List the vendors who are Micro or Small Enterprises.
2. Review invoices and payments. Check acceptance dates against payment dates for each supplier.
3. Prepare supplier-wise details. Compile outstanding and delayed-payment data in the format the form needs.
4. Complete the form on the MCA portal. Use the latest version.
5. Submit with authentication and keep the acknowledgement. Retain it with your compliance records.

Penalties for Non-Compliance

Section 405(4) of the Companies Act, 2013 provides for penalties where a company fails to comply with a direction under Section 405, or furnishes information that is materially incorrect or incomplete.

• A penalty of ₹20,000 applies to the company and to every officer in default.
• For a continuing default, an additional ₹1,000 per day may be levied, subject to a ceiling of ₹3 lakh.

There is also a separate financial risk. Late payment to a Micro or Small Enterprise may attract interest under Section 16 of the MSMED Act, 2006. In other words, a delayed payment can create both a reporting obligation and an interest liability.

Practical Compliance Checklist

• Reconcile vendor ledgers well before 31 October.
• Confirm the MSME status of each supplier on record.
• Keep invoice-wise acceptance dates and payment proofs together.
• Check whether any payments were made after 45 days, as the revised form asks for these as well.
• Download the latest form and instructions from the MCA portal before filing.
• Monitor MCA notifications for any extension.

Need help with your April–September 2026 MSME-1? Contact us before 31 October.

Disclaimer: This article is a general guide and does not constitute professional advice. Please consult a qualified professional for your specific circumstances. Due dates are subject to any extension notified by the MCA.