- October 23, 2026
- Miscellaneous
MSME Form-1 Filing Deadline Is 31 October — Who Must Report Overdue Supplier Payments
MSME Form-1 Filing Deadline Is 31 October — Who Must Report Overdue Supplier Payments
If your company buys goods or services from micro or small enterprises and any payment to those suppliers has crossed the 45-day mark, a half-yearly return to the Ministry of Corporate Affairs may be due from you — and the deadline for the April–September 2026 period is 31 October 2026. This guide explains, in plain terms, what Form MSME-1 is, which companies must file it, what the penalties are for missing the deadline, and how to get your vendor dues reconciled before you file.
The Short Answer
Form MSME-1 is a half-yearly return filed with the MCA by "specified companies" — companies that have payments pending to micro or small enterprise suppliers for more than 45 days from the date of acceptance (or deemed acceptance) of the goods or services. The reporting window is April–September (due 31 October) and October–March (due 30 April). The return for April–September 2026 is therefore due on 31 October 2026. Failure to file can attract a penalty of ₹20,000 on the company and every officer in default, plus ₹1,000 per day of continuing failure, capped at ₹3 lakh. Note: this is general information, not legal advice — confirm your company's position with your CA or company secretary before filing.
What Is Form MSME-1?
Form MSME-1 is a half-yearly return filed under Section 405 of the Companies Act, 2013. It was introduced through the Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019, and the Order was amended in 2024. The purpose of the return is simple: it makes companies disclose, every six months, the payments they owe to micro and small enterprise suppliers that have remained outstanding beyond 45 days, along with the reasons for the delay.
The 45-day benchmark comes from Section 15 of the Micro, Small and Medium Enterprises Development (MSMED) Act, 2006. Under that provision, a buyer must make payment to a micro or small enterprise supplier within 45 days from the day of acceptance or deemed acceptance of the goods or the services. Form MSME-1 is the MCA's mechanism for tracking compliance with that rule.
Who Must File — and Who Need Not
Specified companies only
The requirement applies to "specified companies" — that is, companies that have payments pending to micro or small enterprise suppliers beyond the 45-day limit. Partnership firms, sole proprietorships and LLPs are not covered by this filing requirement in their capacity as buyers; the obligation sits on companies under the Companies Act. If a company has no such overdue payments for the half-year, there is nothing to report and no return is triggered for that period.
Medium enterprises are outside this return
It is worth noting that this particular requirement covers suppliers who are micro or small enterprises only. Dues owed to medium enterprises do not fall within the Form MSME-1 reporting net, even though the MSMED Act's delayed-payment framework covers wider situations elsewhere.
Filing Periods and Deadlines
The return covers two half-yearly periods:
- April to September — due by 31 October of the same year.
- October to March — due by 30 April of the following year.
So the return covering April–September 2026 is due on 31 October 2026. With the deadline only days away, companies that have not yet reconciled their vendor ledgers should treat this as urgent.
Penalties for Missing the Deadline
Non-compliance is not a minor technical lapse. Under Section 405(4) of the Companies Act, a company — and every officer of the company who is in default — that fails to furnish the required information can face a penalty of ₹20,000, plus a further ₹1,000 for every day the default continues, subject to a maximum penalty of ₹3 lakh.
Interest and tax consequences beyond the fine
The penalty under the Companies Act is only one side of delayed payments to small suppliers. Separately, delayed payments can attract interest under Section 16 of the MSMED Act — payable to the supplier at the stipulated rate — and can also affect the timing of income-tax deductions under Section 43B(h) of the Income Tax Act, which links the allowability of the expense to actual payment within the prescribed period. In other words, paying small suppliers late carries both a reporting consequence and a financial one, so it deserves attention well before the return is prepared.
Practical Steps: Reconcile Your Vendor Dues Before 31 October
Filing accurately starts with clean books. Here is a practical checklist to work through before the deadline:
- Identify your micro and small suppliers. Ask vendors for their Udyam registration status if you are unsure. If you are registering your own business as an MSME, see our step-by-step Udyam registration guide for how the classification works.
- Age every outstanding payable. For each invoice from a micro or small supplier, measure the days elapsed since acceptance or deemed acceptance of the goods or services. Flag everything beyond 45 days.
- Record the reasons for delay. The return asks for the reasons behind delayed payments — disputes over quality, missing documentation, or cash-flow constraints should be documented honestly and consistently with your internal records.
- Cross-check with your purchase and payment teams. Missed or misclassified invoices are the most common cause of inaccurate returns. A short reconciliation exercise now avoids corrections later.
- Confirm whether anything is actually due. If no payments to micro or small suppliers were outstanding beyond 45 days during April–September 2026, the return is not triggered — but document that conclusion so it stands up to scrutiny later.
- Get your CA or CS to review the return. The intersection of the Companies Act, the MSMED Act and income-tax timing rules is genuinely technical. A professional review before 31 October is the cheapest insurance.
If you are on the supplier's side of the table and struggling with a buyer who is simply not paying, the MSME Samadhaan portal offers a statutory route to recover delayed payments — worth reading alongside this guide.
Frequently Asked Questions
What is the MSME Form 1 due date for April–September 2026?
31 October 2026. The Form MSME-1 return for the April–September half-year must be filed with the MCA by that date.
Does every company have to file Form MSME-1?
No. Only specified companies — those with payments pending to micro or small enterprise suppliers beyond 45 days — are covered. Partnerships, sole proprietorships and LLPs as buyers are not covered by this particular requirement.
What is the penalty for not filing MSME Form-1?
Under Section 405(4) of the Companies Act, ₹20,000 on the company and every officer in default, plus ₹1,000 per day of continuing failure, up to a maximum of ₹3 lakh.
Can delayed payments to small suppliers affect income tax?
Yes, potentially. Beyond the MCA penalty and interest under Section 16 of the MSMED Act, delayed payments can affect when the expense is deductible under Section 43B(h) of the Income Tax Act. Discuss the specifics with your tax adviser.
Sources
- TaxGuru — "Form MSME-1 Filing Due Date, Applicability & Penalties" (22 Oct 2026) — https://taxguru.in/company-law/form-msme-1-filing-due-date-applicability-penalties.html
- TaxGuru — "MSME Form 1 Due 31 October 2026: Who Must Report Overdue Supplier Payments?" (Oct 2026) — https://taxguru.in/company-law/msme-form-1-due-31-october-2026-report-overdue-supplier-payments.html
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