MSME Form 1 for April-September 2026: Which Companies File by 31 October and What Goes In
A company files MSME Form 1 with MCA if it has dues to a micro or small supplier outstanding beyond 45 days from acceptance. On the V3 form, a late payment during the half-year also triggers it. The April-September 2026 return is due by 31 October 2026. Non-filing attracts ₹20,000 plus ₹1,000 a day, up to ₹3 lakh.
MSME Form 1 is the half-yearly return in which a company tells the Ministry of Corporate Affairs how much it owes micro and small suppliers, and for how long. The April-September 2026 return is due on 31 October 2026, the same month as the annual accounts filing, which is why it is easy to miss.
Who must file
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 dated 22 January 2019, as amended with effect from 15 July 2024.
- ✓Who files: companies (private, public and one person companies) that buy goods or services from micro or small enterprises.
- ✓Who does not: LLPs, partnership firms and proprietorships, which are not companies.
- ✓Which suppliers count: only micro and small enterprises with Udyam registration. Dues to medium enterprises are not reported.
- ✓The trigger: payment to such a supplier more than 45 days after the date of acceptance or deemed acceptance of the goods or services.
The wider trigger since July 2024
The 2024 amendment limited the obligation to specified companies with payments pending to micro or small enterprises for more than 45 days. The revised form on the MCA V3 portal, however, asks about four groups of micro and small vendors for the half-year:
- paid within 45 days;
- paid after 45 days;
- outstanding at the half-year end for 45 days or less;
- outstanding at the half-year end for more than 45 days.
Because of item 2, most practitioners read the form as requiring a filing if even one payment in the half-year was made after 45 days, even if nothing is outstanding on 30 September. MCA has not issued a clarification on this. The safer course is to file whenever either a late payment or an overdue balance exists.
What to report
| Detail | Source in your books |
|---|---|
| Supplier name and PAN | Vendor master |
| MSME category (micro or small) and Udyam number | Udyam certificate collected from the supplier |
| Amount due and outstanding | Payables ledger as on 30 September 2026 |
| Date from which the amount is due | Date of acceptance or deemed acceptance |
| Amounts paid after 45 days in the half-year | Payment register |
| Reason for delay | Your explanation, for example a quality dispute |
Due dates and penalty
| Half-year | Due date |
|---|---|
| October 2025 to March 2026 | 30 April 2026 (passed) |
| April to September 2026 | 31 October 2026 |
| October 2026 to March 2027 | 30 April 2027 |
Under section 405(4), as amended in 2020, the company and every officer in default are liable to a penalty of ₹20,000, plus ₹1,000 a day for a continuing failure, up to ₹3,00,000. Registrars have adjudicated such penalties for late MSME Form 1 filings, including the maximum. Incorrect or incomplete information is covered by the same penalty.
The links you should not miss
- ✓Interest to the supplier: under the MSMED Act, a buyer who pays late owes compound interest at three times the RBI bank rate, with monthly rests. The form tells the government, and the supplier can claim it.
- ✓Income tax: under section 37(2)(g) of the Income-tax Act, 2025 (earlier 43B(h)), a sum owed to a micro or small enterprise and not paid within the MSMED time limit is deductible only in the year it is actually paid.
- ✓Annual accounts: Schedule III requires disclosure of dues to micro and small enterprises in the financial statements. The Form 1 data and the accounts disclosure should agree.
A worked example
A Pune auto-component company, a private limited company, reviews its micro and small suppliers for April-September 2026.
- Supplier A (micro). Invoice ₹4,20,000, goods accepted on 5 June 2026, paid on 10 August 2026. Days: 25 (rest of June) + 31 (July) + 10 (August) = 66 days. Paid late within the half-year.
- Supplier B (small). Invoice ₹7,80,000, accepted on 10 August 2026, unpaid on 30 September. Days: 21 (rest of August) + 30 (September) = 51 days. Outstanding beyond 45 days.
- Supplier C (micro). Invoice ₹2,50,000, accepted on 1 September 2026, unpaid on 30 September. Days: 29. Outstanding but within 45 days.
- Supplier D (medium). ₹12,00,000 outstanding for 70 days. Not reported, because medium enterprises are outside the form.
Supplier B alone makes the filing compulsory. Supplier A would also trigger it on the V3 reading. The company files by 31 October 2026, reporting A and B with reasons for delay, and C and the on-time vendors in the categories the form asks for.
On the tax side, if the ₹7,80,000 to B is still unpaid on 31 March 2027, it is deductible only in the year it is paid.
Frequently asked questions
Do we file if every micro and small supplier was paid within 45 days?
No filing is required if no payment was made after 45 days and nothing is outstanding beyond 45 days on 30 September. Keep the working on file.
Does a 60-day credit term in our contract change the 45 days?
No. Under the MSMED Act, the agreed period cannot exceed 45 days from acceptance. A longer contract term does not extend it.
How do we know if a supplier is micro or small?
Ask for the Udyam registration certificate and record the category in the vendor master. Re-check each year, because the category can change with the supplier's turnover and investment.
Is there a filing fee or late fee on the MCA portal?
The penalty under section 405(4) is the main consequence of default. Check the fee shown on the V3 portal at the time of filing.
Sources
- ✓Instruction kit for MSME Form I (outstanding payments to micro or small enterprises), Ministry of Corporate Affairs
- ✓Change in form MSME-1: exhaustive disclosure framework, MMJC
- ✓MSME Form I and the 2019 Order, Mondaq
- ✓MSME Form 1 half-yearly return filing guide, Patron Accounting
This is a summary, not legal advice. Confirm the current form version and filing requirements on the MCA portal (mca.gov.in) before you file.
Written by
Founder, Airwix Technologies (Sleet)
Vatsal Sutariya is the founder of Airwix Technologies in Ahmedabad, the company that builds Sleet: SleetHR for HR and payroll, and Sleet Accounting for GST billing and books. He writes about GST, invoicing, business tax and choosing software for Indian businesses, and checks each rule against the official notification before it is published.
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