What are the MSME Form 1 due dates?

31 October for the April–September half-year and 30 April for the October–March half-year.

Do payments to medium enterprises go in MSME Form 1?

No. The Order covers micro and small enterprise suppliers only, though medium enterprises are still covered by other MSMED Act provisions.

What is the penalty for not filing MSME Form 1?

Under Section 405(4) of the Companies Act, 2013, failure to comply with an applicable information-furnishing order, or furnishing materially incorrect or incomplete information, attracts a penalty of ₹20,000, plus ₹1,000 for each day of continuing default after the first day, subject to a maximum of ₹3 lakh. The company and every officer in default are liable to these penalties.

MSME Form 1: Who Must File, Due Dates & Data

Q: Is a nil MSME Form 1 required?

Generally, no. Under the MCA's 2024 amendment, only specified companies with payments pending to micro or small enterprise suppliers for more than 45 days from the date of acceptance or deemed acceptance must file MSME Form 1. If no such qualifying overdue payments exist, a nil return is not required.

MSME Form 1 half-yearly return checklist showing micro and small vendor invoices ageing beyond 45 days

MSME Form 1: Who Must File, Due Dates and the Data You Need

Quick answer:

MSME Form 1 is a half-yearly return that a company files with the Registrar of Companies (MCA) when it owes money to micro or small enterprise suppliers for more than 45 days from the date of acceptance (or deemed acceptance) of goods or services. It is due by 31 October for April–September and by 30 April for October–March. Getting it right is mostly a data problem: you need each supplier's current Udyam category, the acceptance date of every invoice, and the payment date.

MSME Form 1 sits at the meeting point of three laws: the MSMED Act, 2006 (which sets the payment timeline of up to 45 days), the Companies Act, 2013 (which governs the filing requirement) and the Income-tax Act, 2025 (under Section 37(2)(g), corresponding to Section 43B(h) of the Income-tax Act, 1961, which restricts deductions for delayed payments to micro and small enterprises). The same vendor data feeds all three, so a company that prepares MSME Form 1 properly has already done much of the work for its Schedule III disclosure and the tax auditor's Form 3CD.

This guide covers who must file, the due dates, the data you need, and how to build the return from your ERP. For the current period's step-by-step filing checklist, see our post on the MSME Form 1 due date for April–September 2026.

What is MSME Form 1?

MSME Form 1 is the form prescribed under the Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019, issued under Section 405 of the Companies Act, 2013. The Order was amended by notification S.O. 2751(E) dated 15 July 2024, which substituted a revised MSME Form 1 with more detailed disclosures.

The return enables the government to track companies' delayed payments to micro and small enterprise suppliers, including the outstanding amounts and reasons for delay. It is filed electronically through the MCA V3 portal, and no government filing fee is payable for MSME Form 1.

Who must file MSME Form 1

A company must file if both conditions are met:

1. It receives goods or services from suppliers registered as micro or small enterprises (Udyam registration).

2. Its payments to micro and small enterprise suppliers remain outstanding for more than 45 days from the date of acceptance or deemed acceptance of the goods or services. The 45-day threshold is specified in the MCA's MSME Form 1 Order, which refers to Section 9 of the MSMED Act, 2006, although the relevant payment limit is prescribed under Section 15 of the Act.

The 2024 amendment clarified that only specified companies with payments to micro or small enterprises pending beyond 45 days must file.

Applicability at a glance

Situation	File MSME Form 1?
Company has payments to micro or small enterprise suppliers pending for more than 45 days during the relevant half-year	Yes
All payments to micro and small enterprise suppliers are settled within 45 days, with no qualifying dues pending beyond 45 days	No — nil return is not required
Company paid an MSE invoice after 45 days, but before the half-year ended	Report the late payment when filing the applicable return. The revised form captures amounts paid after 45 days; the filing trigger remains subject to the Order's requirements.
Outstanding dues are only to medium enterprises	No — MSME Form 1 covers micro and small enterprises, not medium enterprises.
Supplier's Udyam registration or MSE eligibility has not been verified	Verify before excluding the supplier. Confirm qualifying status and applicable registration requirements, and retain supporting evidence.
Buyer is an LLP, partnership firm or proprietorship	Generally no — MSME Form 1 is a Companies Act filing for covered companies. Separate MSMED Act payment obligations and applicable income-tax provisions may still apply.
Foreign company has suppliers qualifying as micro or small enterprises in India	Potentially yes — the revised form includes an FCRN field. Confirm applicability based on the company's legal status and circumstances.

MSME Form 1 due dates

Half-year	Period covered	Due date
H1	1 April to 30 September	31 October
H2	1 October to 31 March	30 April

For the current cycle, the April–September 2026 return is due on 31 October 2026. As of 12 October 2026 we found no MCA extension for this period. Check the MCA portal before filing.

The 45-day rule: how acceptance dates work

The 45 days do not run from the invoice date. They run from the day of acceptance or the day of deemed acceptance, as defined in Section 2(b) of the MSMED Act:

Acceptance: the day the goods are delivered or services rendered, where the buyer accepts them.
Deemed acceptance: if the buyer raises no written objection within 15 days of delivery, the day of actual delivery is treated as the acceptance date.
Objection later removed: if the buyer objects within 15 days and the supplier then fixes the problem, acceptance is the day the objection is removed.

Under Section 15 of the MSMED Act, payment is due by the agreed date, which cannot be more than 45 days from acceptance. Where there is no written agreement, the limit is 15 days. That means a company with no written payment terms can be late after 15 days, even though MSME Form 1 only asks about dues beyond 45 days.

Most ERPs store the invoice date and the goods receipt (GRN) date, not a formal acceptance date. Agree one rule with your auditors (usually the GRN or service-entry date) and apply it consistently, because the same date drives Form 1, Schedule III and the Section 43B(h) disallowance.

Data you need for MSME Form 1

The revised form asks for amounts paid and amounts outstanding, split around the 45-day line, supplier by supplier. Build a single dataset with these fields:

Data field	Source	Why it matters
Supplier name and PAN	Vendor master	Required in revised MSME Form 1. These are the explicit supplier-level identification fields.
Udyam registration number and category (micro/small/medium)	Udyam certificate or verification records	Internal verification to establish whether the supplier qualifies as a micro or small enterprise. The revised form does not have a separate Udyam number field.
Category and registration status on the relevant date	Udyam certificate and status history	Helps establish supplier eligibility and retain evidence if classification or registration status changes.
Invoice number, date and amount	Accounts payable (AP) ledger	Supports invoice-level reconciliation and ageing calculations; not a separate field in the revised form.
Acceptance or deemed acceptance date	Goods receipt note (GRN), service-entry records and objection log	Establishes the starting point for calculating the applicable payment deadline under the MSMED Act.
Agreed payment terms	Purchase order or contract	Establishes the agreed period; without a written agreement, payment is generally due within 15 days, subject to the MSMED Act.
Payment date and amount	Bank records and payment run	Supports classification of payments as paid within 45 days or paid after 45 days.
Outstanding balance and ageing	AP ageing report	Supports reporting outstanding amounts for 45 days or less and for more than 45 days.
Reason for delay or outstanding amount	AP team and business owner	Required field in revised MSME Form 1 for the reason for delay in payment or the outstanding amount.

The revised form captures:

Amount paid within 45 days
Amount paid after 45 days
Amount outstanding for up to 45 days
Amount outstanding for more than 45 days

Step-by-step: preparing MSME Form 1 from your ERP

Refresh MSE status of every vendor
Re-verify Udyam status and category for all active vendors at the start of each half-year. A supplier that registered under Udyam after onboarding is often missing from the vendor master. Record the date of each check.
Extract invoice-level data for the half-year
Pull every invoice from micro and small suppliers that was open at the start of the period, booked during it, or paid during it.
Fix the acceptance date
Apply your agreed rule (GRN, service-entry or objection-removal date). Flag invoices with no GRN for manual review.
Age each invoice against 45 days
Classify every invoice into the four buckets above. Use the agreed payment terms to also flag invoices that crossed the 15-day limit where there was no written agreement.
Capture reasons for delay
Ask business owners for a reason against each delayed invoice: quality dispute, missing documents, pending approval, and so on. Generic reasons invite questions.
Reconcile before filing
Tie the Form 1 totals to the AP ledger, the Schedule III MSME note and the Section 43B(h) workings (see the table below).
File and keep evidence
File on the MCA V3 portal with the digital signature of the authorised signatory. Keep the invoice-level working file, the Udyam verification evidence and the reasons for delay.

Reconciling MSME Form 1 with other disclosures

Disclosure	What it reports	Link to MSME Form 1
Schedule III note (financial statements)	Principal and interest unpaid at year-end; payments made beyond the appointed day; interest due for the period of delay; accrued unpaid interest; and further interest payable in subsequent years.	Reconcile the annual disclosure with supplier balances and delayed-payment records. Do not assume it must match H2 Form 1 exactly, as the reporting periods and disclosure requirements differ.
Form 3CD Clause 22	Interest inadmissible under Section 23 of the MSMED Act, along with amounts required to be paid to micro and small enterprises under Section 15, classified by whether they were paid within the prescribed time.	Uses the same supplier, acceptance-date and delayed-invoice records, with additional tax-audit calculations.
Section 43B(h) / Section 37(2)(g)	Under the Income-tax Act, 1961, Section 43B(h) defers the deduction for payments beyond the Section 15 deadline until actual payment. Its corresponding provision under the Income-tax Act, 2025 is Section 37(2)(g).	Uses the same delayed-payment records but applies the Section 15 deadline: 15 days without a written agreement, or the agreed period capped at 45 days.
MSMED Act Section 16 interest	Compound interest at three times the RBI-notified bank rate, with monthly rests, on delayed payments as prescribed by the Act. Such interest is not deductible under Section 23.	Calculate interest using delayed-payment records and reconcile it with Schedule III and Form 3CD.

For the tax auditor's side, see our Form 3CD Clause 22 checklist.

Penalty for not filing

Under Section 405(4) of the Companies Act, 2013, a company that fails to comply with an applicable information-furnishing order, or furnishes materially incorrect or incomplete information, is liable to a penalty of ₹20,000, plus ₹1,000 for each day of continuing default after the first day, subject to a maximum of ₹3 lakh. Every officer in default is separately liable to the same penalty limits.

Separately, the Micro, Small and Medium Enterprises Development (Amendment) Act, 2026 received Presidential assent on 13 August 2026. The Act provides that it will come into force on a date appointed by the Central Government through a notification in the Official Gazette, with different commencement dates permitted for different provisions. As of 12 October 2026, we could not locate a commencement notification in the official sources checked. Accordingly, confirm the latest Gazette notifications before stating that the amended provisions are in force; until the relevant provisions commence, the existing provisions continue to apply. See our summary of the MSMED Amendment Act 2026.

Key takeaways

MSME Form 1 is required only where a company's payments to micro or small suppliers exceed 45 days from acceptance.
Due dates: 31 October (April–September) and 30 April (October–March).
The 45 days run from acceptance or deemed acceptance, not the invoice date.
The revised 2024 form reports amounts paid and outstanding on both sides of 45 days.
Build one dataset and reconcile it with Schedule III, Form 3CD Clause 22 and Section 43B(h).

Frequently Asked Questions

A half-yearly return filed with the Registrar of Companies by companies whose payments to micro or small enterprise suppliers exceed 45 days from the date of acceptance or deemed acceptance. It is prescribed under Section 405 of the Companies Act, 2013.