MSME Form 1 Due 31 October 2026: Filing Checklist for April–September 2026

MSME Form 1 Due 31 October 2026: Filing Checklist for April–September 2026

Companies that had relevant payments to Micro or Small Enterprise suppliers outstanding for more than 45 days, or payments that were made after crossing the 45-day period during April–September 2026, must file MSME Form 1 with the Ministry of Corporate Affairs by 31 October 2026.

This return is easy to miss, because the trigger is a payment delay, not a fixed event, and the penalty runs per day for the company and each officer in default. This checklist covers who files, what to report, and how to get the vendor data right.

Who must file

A company must file if both are true:

1. It bought goods or services from a supplier that qualifies as a Micro or Small Enterprise. Medium enterprises are not covered by MSME Form 1. Companies should verify the supplier's current MSME classification while preparing the return.

2. A payment to that supplier was outstanding for more than 45 days from the date of acceptance or deemed acceptance.

The requirement comes from Section 405 of the Companies Act, 2013 and the Specified Companies (Furnishing of Information about Payment to Micro and Small Enterprise Suppliers) Order, 2019, as revised in 2024.

It applies to private, public and one person companies. LLPs, partnerships and proprietors do not file MSME Form 1, but they are still bound by the MSMED Act payment limit and the income-tax rule.

Paid after 45 days but cleared before 30 September? The revised Form 1 also requires reporting of payments that were liquidated after 45 days, even if the amount was subsequently paid before the end of the half-year.

Due dates

What to report

For each relevant Micro or Small Enterprise supplier, the revised Form 1 requires details including:

• supplier name and PAN;
• payments made within 45 days, including payments through TReDS or other modes;
• payments made after 45 days;
• amounts outstanding for 45 days or less;
• amounts outstanding for more than 45 days; and
• the reason for the delay in payment or amount outstanding.

Filing checklist

1. 1

   Confirm which vendors currently qualify as Micro or Small Enterprises

   Start from a verified vendor list rather than relying only on the MSME flag captured at onboarding. A supplier's MSME classification can change over time based on the applicable investment and turnover criteria. Verify the current classification and Udyam status of relevant vendors before preparing the return.

2. 2

   Pull every MSE invoice for April–September 2026

   Include invoices raised before 1 April 2026 that were still unpaid on that date.

3. 3

   Fix the acceptance date for each invoice

   The 45-day period runs from the date of acceptance or deemed acceptance of the goods or services, not simply from the invoice date. Use supporting records such as GRNs, delivery records, service acceptance records or other documented evidence to establish the acceptance date.

4. 4

   Flag every invoice paid after 45 days or still outstanding beyond 45 days

   For MSME Form 1, identify payments that were made after 45 days as well as amounts that remain outstanding beyond 45 days. Separately, under the MSMED Act, where there is no written agreement, payment is generally required within 15 days; where there is a written agreement, the agreed payment period cannot exceed 45 days.

5. 5

   Record the reason for each delay

   Disputed quality, missing documents and pending approvals are common reasons. Keep the evidence.

6. 6

   Reconcile before filing

   Reconcile the Form 1 data with your accounts payable records and the applicable financial-statement and tax disclosures. The reporting requirements may differ across these records, so any differences should be explainable and supported by appropriate documentation. The MSMED (Amendment) Act, 2026 introduces graded penalties for certain Section 22 contraventions, subject to the commencement of the relevant provisions.

7. 7

   File on the MCA V3 portal by 31 October 2026

   MSME Form 1 is filed without a statutory filing fee. Submit the form electronically on the MCA V3 portal and digitally sign it through the authorised signatory specified in the form.

Penalty for Non-Filing or Incorrect/Incomplete Information

Section 405(4) of the Companies Act provides penalties for failure to furnish the required information, as well as for furnishing information that is incorrect or materially incomplete.

Separately, the supplier is owed compound interest at three times the RBI bank rate under Section 16 of the MSMED Act, which is not tax-deductible, and the late principal is deductible only when paid under Section 43B(h) / Section 37(2)(g) of the Income-tax Act, 2025.

How Figment helps

The hardest part of MSME Form 1 is Step 1: knowing which vendors are micro or small right now. Figment's MSME compliance solution checks the Udyam status and category of your whole vendor list in one bulk run from an Excel upload of PANs or Udyam numbers. See also our guide to bulk updating MSME vendor details.