Delaying the payment of small suppliers is a business issue. Failure to report such an event may lead to a legal issue. The MSME Form or MSME Form I (Form MSME-1) is a semi-annual return that specified companies file with the Ministry of Corporate Affairs (MCA) to report payments that have been delayed beyond 45 days after receiving the goods or services from micro and small enterprise suppliers. Given that the return is due for the April-September period in 2026 on 31st October 2026, the date is important. This guide gives a detailed description of the form, its filers, deadlines, documents required, filing process, and penalties.
MSME Form I at a glance: MSME Form I is a semi-annual MCA return, filed under section 405 of the Companies Act, 2013, by specified companies that owe payments to micro or small enterprise suppliers beyond 45 days.
What Is MSME Form I?
MSME Form I is an e-form submitted twice a year by the businesses to the Registrar of Companies (ROC), which discloses the amount due for payment for micro and small enterprise suppliers over 45 days.
This is mandated under the Specified Companies (Furnishing of Information about Payment to Micro and Small Enterprise Suppliers) Order, 2019, which was notified by the MCA on 22 January 2019 under Section 405 of the Companies Act, 2013. This disclosure is made simply because delayed payments should be made known to the regulatory authority.
The form has details about the supplier, amount, reason for delay and date. With the 2024 revision in the MCA V3 portal, the disclosures include payments made within 45 days and over, and also outstanding balances.
MSME Form I is not a registration. The business will not get a certificate or a benefit out of filling the form. This is simply a disclosure made by the buyer regarding its suppliers.
Why Is MSME Form I Important for MCA Compliance?
MSME Form I turns accounts payable into a compliance matter. Late payments to small suppliers choke their working capital, so the law asks larger buyers to disclose delays and explain them. For your company, it matters in four ways:
- Statutory reporting: Section 405 gives the filing legal force.
- Transparency: Directors and auditors see supplier ageing clearly.
- Supplier relationships: Small vendors can raise complaints on the MSME Samadhaan portal, and the Facilitation Council can award dues with interest.
- Cross-checks: Disclosures can be compared with annual accounts and tax filings.
One distinction is critical. Reporting dues is not the same as settling them. Filing the form does not discharge your payment duty under the MSMED Act, 2006. Under Section 15, payment is due by the agreed date (never beyond 45 days from acceptance) or, without a written agreement, within 15 days. Section 16 adds compound interest at three times the RBI bank rate on delayed payments.
Who Is Required to File MSME Form I?
Only specified companies must file. That means a company registered under the Companies Act, 2013 that obtains goods or services from micro or small enterprise suppliers and has payments pending beyond 45 days from the date of acceptance or deemed acceptance. The trigger has three parts:
- The filer is a company: LLPs, partnership firms and sole proprietorships are not covered by this MCA order, though the MSMED Act may still apply to them as buyers.
- The supplier is a micro or small enterprise: Medium enterprises are outside the form. Under the classification effective 1 April 2025, a micro enterprise has investment up to ₹2.5 crore and turnover up to ₹10 crore; a small enterprise has investment up to ₹25 crore and turnover up to ₹100 crore.
- Payment is pending beyond 45 days from acceptance or deemed acceptance.
Most sources, including MCA-aligned professional commentary, say there is no nil return. If no qualifying payment crossed 45 days in the half-year, no filing is needed. Do not assume every company with an MSME vendor must file.
Always verify supplier status with the Udyam registration certificate and PAN, and check classification for the relevant period, not last year’s certificate.
MSME Form I Due Date and Filing Frequency
MSME Form I is filed twice a year, by the last day of the month after each half-year ends.
| Reporting period | Due date | Next occurrence |
| April to September | 31 October | 31 October 2026 |
| October to March | 30 April | 30 April 2027 |
The MCA reminded stakeholders about the 30 April 2026 deadline for October 2025–March 2026 on its official channels, so the schedule is current. MCA sometimes extends other forms, but the MSME Form I dates have not typically been extended. Do not plan around an extension.
One common confusion is the clock. The 45 days run from acceptance or deemed acceptance, not the invoice date. If you do not object in writing within 15 days of delivery, deemed acceptance is generally the delivery date. A short written credit term, say 20 days, can also make a payment late under Section 15 well before day 45.
Documents and Information Required for MSME Form I
Gather your data before you log in. The form itself asks for specific particulars, while the rest is internal support.
Information entered in the form:
- Company CIN and PAN
- Supplier name and PAN
- Amount outstanding and amounts paid within or after 45 days
- Reasons for delay or non-payment
Records to keep ready internally:
- Udyam certificate or supplier declaration
- Invoices, delivery or service-completion proof, and any written objections
- Written credit terms and bank payment records
- Accounts payable ageing report and ledger reconciliation
- Add valid Digital Signature Certificate (DSC) of the authorised signatory
Not every supporting document must be uploaded. Keep them for audit and ROC queries.
How To File MSME Form I On The MCA Portal?
Here is the process, step by step. Portal labels can change, so check the MCA portal for current instructions.
- Review supplier classifications and your accounts payable ageing.
- Identify outstanding amounts that meet the reporting conditions.
- Reconcile invoices, payments and supplier details against your books.
- Log in to the MCA portal (mca.gov.in) with your MCA V3 business user credentials.
- Open the form: MCA Services → Company e-Filing → Compliance Services → MSME – Half yearly return of Micro or Small Enterprise.
- Enter company and supplier particulars, including paid and outstanding amounts and reasons for delay.
- Sign and submit with a valid DSC and complete the authentication steps.
- Save the SRN acknowledgement and file your working papers.
No separate MCA filing fee is generally reported for this form, but confirm on the portal. Professional fees and DSC costs may apply.
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Penalties and Consequences of Non-Compliance
Failing to file, or filing materially incorrect or incomplete information, is covered by Section 405(4) of the Companies Act, 2013. ROC adjudication orders have applied a penalty of ₹20,000 on the company and each officer in default, plus ₹1,000 for every day the default continues, subject to a ceiling of ₹3 lakh. Relief for small companies may apply, so check your facts. Keep two consequences separate:
- Reporting default: the Section 405(4) penalty above.
- Delayed payment itself: compound interest under Section 16 of the MSMED Act, 2006. Section 22 also requires specified disclosures of unpaid dues in annual accounts. Under Section 43B(h) of the Income-tax Act, 1961, sums owed to micro and small enterprises beyond the Section 15 limit are deductible only when actually paid.
There are practical risks as well: audit queries, ROC scrutiny, strained vendor relations and supplier complaints. A late filing also does not wipe out the earlier default period. Each missed half-year can be a separate default.
MSME Form I vs Udyam Registration
| Point | MSME Form I | Udyam Registration |
| Nature | Reporting return | Registration process |
| Who acts | Buying company | The enterprise itself |
| Governing body | MCA (Section 405, Companies Act) | Ministry of MSME |
| What it does | Discloses overdue payments to micro and small suppliers | Records enterprise classification and unlocks MSME benefits |
| When relevant | Half-yearly, when payments cross 45 days | Once, with updates as details change |
The link between them is practical: the supplier’s Udyam record helps the buyer confirm whether a vendor is micro or small. Completing one never satisfies the other.
Common MSME Form I Filing Mistakes to Avoid
- Wrong supplier classification: treating every small vendor, or medium enterprises, as covered. Fix: collect Udyam certificates at onboarding.
- Counting from the invoice date instead of acceptance. Fix: track delivery dates.
- Ignoring late-paid invoices cleared before period end. Professional views differ on how the 2024 form treats these, so document your position.
- Unreconciled balances, such as unadjusted credit notes or part-payments.
- Missing the deadline because the DSC expired.
- Not keeping the SRN and working papers.
A quarterly payables review prevents most of these.
How UdyamitaHelpline.com Can Help With MSME Compliance
If delayed payments are hurting your business, or you are a buyer trying to get your supplier records in order, you do not have to work it out alone. Udyamita Helpline provides expert guidance on delayed payments to MSMEs and runs webinars on compliance and government schemes. Our membership gives you access to experts and resources.
Conclusion
The MSME form is a simple idea with real consequences. It asks companies to report overdue payments to micro and small suppliers, and it rewards those who track payables early. Check applicability each half-year, mark 31 October and 30 April, and keep clean supplier records. If you want a second opinion before filing, Udyamita Helpline is here to guide you.
FAQs
It is a half-yearly MCA return in which specified companies report payments to micro and small enterprise suppliers pending beyond 45 days from acceptance or deemed acceptance.
Companies under the Companies Act, 2013 with such pending payments. LLPs, firms and proprietorships are not covered, and medium-enterprise suppliers are excluded.
31 October for April–September and 30 April for October–March. The next dates are 31 October 2026 and 30 April 2027.
No. Udyam Registration is how an enterprise records its MSME status. MSME Form I is a buyer company’s disclosure of overdue supplier payments.
Generally yes, as there is no nil return. But confirm this by testing supplier status, acceptance dates and the 45-day condition first, and document the result.
The company and officers in default may face a Section 405(4) penalty, which ROC orders have applied as ₹20,000 plus ₹1,000 per day, capped at ₹3 lakh.
