A company files MSME Form 1 if, during the half-year, it had payments outstanding to any micro or small enterprise supplier for more than 45 days from the date of acceptance or deemed acceptance. The return for April to September is due by 31 October; the return for October to March is due by 30 April. It is filed on the MCA V3 portal and reports, supplier by supplier, the amounts due, how long they have been outstanding and the reasons for delay.
Who has to file
Every company, private or public, listed or not, that buys goods or services from micro or small enterprises is a potential filer. It becomes a "specified company" for a half-year when any payment to such a supplier has stayed outstanding for more than 45 days from the date of acceptance or deemed acceptance. LLPs, partnership firms and proprietors do not file MSME-1, though they are still bound by the payment rules of the MSMED Act and the income-tax rule on late payment.
| Half-year | Period covered | Due date | Next deadline |
|---|---|---|---|
| First half | 1 April to 30 September | 31 October | 31 October 2026 |
| Second half | 1 October to 31 March | 30 April | 30 April 2027 |
The test is the 45-day mark from acceptance, not your PO credit term. A 60-day term does not stop a supplier's invoice from being reportable after day 45.
What to report
The form asks for each micro or small supplier: name and PAN, the amount due, the date from which it is due, and the reason for the delay. The form revised in July 2024 also asks the company to split payments to these suppliers into amounts paid within 45 days and after 45 days, and amounts outstanding up to 45 days and beyond 45 days. Prepare the data from your creditor ledger before you open the form.
- Freeze the creditor ledger as at 30 September (or 31 March).
- Filter suppliers that have given Udyam details showing micro or small status.
- For each invoice, take the acceptance date and count 45 days.
- List every invoice that crossed day 45 unpaid during the half-year, with the amount and the reason for delay in plain words (quality dispute, documents pending, cash flow).
- Cross-check with the Section 22 disclosure in the accounts and the income-tax workings under Section 37(2)(g).
- Have a director sign with a DSC and file on the MCA portal before the due date.
Worked example (hypothetical)
A private limited company in Pune buys packaging from a small enterprise in Chakan. One invoice of ₹6,00,000 was accepted on 10 August 2026 on a 30-day term. Day 45 from acceptance is 24 September 2026. On 30 September the invoice is still unpaid, so the company is a specified company for April to September 2026 and must file MSME Form 1 by 31 October 2026, showing ₹6,00,000 due from 9 September 2026 (the agreed date) with the reason for delay.
If the company pays on 10 October, the invoice still appears in the April to September return, because it was outstanding beyond 45 days during that half-year. That is why buyers who track MSME-1 like to clear MSE invoices before the half-year closes, and why suppliers who mention it in a reminder in late September often get paid.
Edge cases
- No MSE dues beyond 45 days: no return is required for that half-year.
- Supplier did not give Udyam details: the company is expected to know the status of its suppliers; ask in writing and keep the replies.
- Disputed invoice: report it if it crossed 45 days unpaid and give the dispute as the reason.
- Late filing: non-compliance with an order under Section 405 attracts a penalty on the company and its officers in default.
For suppliers: an MSME-1 deadline is leverage. A reminder that says "this invoice will appear in your MSME-1 for the half-year" reaches the compliance team, not just purchase. If that fails, FundRaksha sends a legal notice within 24 hours and can take the claim to the Facilitation Council.
Sources
Last reviewed: 2026-10-21. Information for Indian businesses; not legal advice.