Legal basis: Companies (Furnishing of Information about Payment to Micro and Small Enterprise Suppliers) Order 2019, issued under Section 405, Companies Act 2013 — also flows from Section 22, Micro, Small and Medium Enterprises Development Act 2006. Effective: ongoing half-yearly filing obligation. Source: https://indiacode.nic.in/handle/123456789/18098. Last reviewed by CA Harun Raaj: September 2026.
Every company that owes money to a registered Micro or Small enterprise supplier for more than 45 days must file Form MSME-1 with the Registrar of Companies (ROC) by October 31, 2026 — the deadline for the April–September 2026 half-year.
Key point: If your company has dues outstanding over 45 days to a Udyam-registered Micro or Small enterprise supplier as on September 30, 2026, you must file Form MSME-1 by October 31, 2026, or face a penalty of up to ₹3,00,000 under Section 405(4).
What Form MSME-1 Requires
Under Section 22 of the MSMED Act 2006, any entity buying goods or services from a registered Micro or Small enterprise must pay within 15 days (if there is no written agreement) or within the agreed payment period — which cannot exceed 45 days. If payment is delayed beyond 45 days, the buyer must pay compound interest at three times the RBI bank rate on the delayed amount.
Form MSME-1 operationalises this by requiring companies to disclose:
- Which MSME suppliers they owe money to.
- The amounts outstanding and how long they have been outstanding.
- The reason for the delay.
From April 1, 2025, the MSME classification thresholds were revised upward under the MSMED Act 2006 (as amended). Micro enterprises now extend to investment up to ₹2.5 crore and annual turnover up to ₹10 crore. Small enterprises now extend to investment up to ₹25 crore and annual turnover up to ₹100 crore. This means a larger set of your vendors may now qualify as Micro or Small enterprises — your MSME-1 reporting obligation may be wider than in earlier years.
Who Must File
Every company incorporated under the Companies Act 2013 — private limited, public limited, OPC, or Section 8 — that has outstanding payments to any Micro or Small enterprise supplier exceeding 45 days as on September 30, 2026, must file.
LLPs are not covered. The Order 2019 was issued under the Companies Act 2013, so Form MSME-1 with the ROC does not apply to LLPs, even though they may carry a separate disclosure obligation under the MSMED Act 2006 if they are audited entities.
A nil return is not required. If you genuinely have no outstanding dues to MSME suppliers exceeding 45 days as on September 30, 2026, you do not need to file — but verify this carefully. The 45-day clock runs from the agreed payment date, or from the date of acceptance (or deemed acceptance) of goods or services.
Identifying Your MSME Suppliers
A supplier is eligible for MSME-1 disclosure only if registered under the MSMED Act 2006 via the Udyam Registration portal (udyamregistration.gov.in). A vendor who has not obtained Udyam Registration — even if they would otherwise qualify by size — is not an "MSME supplier" for this purpose.
Collect the Udyam Registration Number (URN) from your vendors and verify their classification against the current thresholds:
Only Micro and Small enterprises are covered for MSME-1. Medium enterprises fall outside the scope of Section 22 of the MSMED Act 2006 and the MCA Order 2019.
Deadline: October 31, 2026
Form MSME-1 is a half-yearly return with two annual windows:
The deadline for the April 1, 2026 to September 30, 2026 period is October 31, 2026. Filing is on the MCA21 V3 portal at mcav3.mca.gov.in.
Step-by-Step: Filing on MCA V3
- Identify MSME suppliers: Collect Udyam Registration Numbers from vendors and verify status at udyamregistration.gov.in.
- Identify outstanding dues over 45 days: Review accounts payable ageing and list all invoices where the due date was more than 45 days before September 30, 2026.
- Log in to MCA V3: Navigate to E-file → Company Forms Filing → MSME-1.
- Fill Form MSME-1: Provide the company CIN and, for each MSME supplier with outstanding dues, their name, Udyam number, amount outstanding, reason for delay, and financial year in which dues arose.
- DSC and submit: The authorised signatory — a director or CFO as designated — signs with a valid DSC and submits.
- Pay the filing fee: The fee is scaled to the company's paid-up capital under the Companies (Registration Offices and Fees) Rules 2014.
Penalty for Non-Filing or Late Filing
Under Section 405(4) of the Companies Act 2013:
- Company: Penalty of ₹25,000 (initial) plus ₹500 per day for each day of continuing default, up to a maximum of ₹3,00,000.
- Officer in default: Same structure — ₹25,000 plus ₹500 per day, up to a maximum of ₹3,00,000.
The ROC adjudicates under Section 454, and adjudication orders for MSME-1 non-compliance are publicly available and increasingly issued.
Illustrative example: Priya Components Private Limited, a Delhi-based auto-parts company, discovers in October 2026 that it has outstanding dues of ₹4,80,000 to three Udyam-registered Micro enterprise suppliers — all between 60 and 90 days overdue as on September 30, 2026. Priya Components must file MSME-1 by October 31, 2026. If it files on November 15, 2026 (15 days late), the penalty exposure is ₹25,000 + (15 × ₹500) = ₹32,500 for the company, plus the same amount for each officer in default.
I'm CA Harun Raaj. If this affects your company's compliance calendar, reach out.
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See Also
Frequently asked questions
Do we need to include an unregistered vendor in Form MSME-1?
No. Only suppliers with a valid Udyam Registration and classified as Micro or Small enterprises at the time of supply are covered by the Order 2019. Document your attempts to obtain the Udyam Registration Number (URN) from any vendor who refuses to share it, which protects the company if the vendor later claims MSME status in a recovery proceeding.
We paid the MSME supplier in October 2026, before the deadline. Do we still need to file MSME-1?
Yes. Form MSME-1 reports dues outstanding as on September 30, 2026, so a payment made in October does not remove the obligation to report what was outstanding on that date. You can note the subsequent payment date in your own records.
Can the Company Secretary sign Form MSME-1 on MCA V3?
Form MSME-1 must be signed by a director or CFO using their DSC. A Company Secretary who is also a director may sign in that capacity, but a CS who is not a director cannot be the authorised signatory for this form.
Our MSME supplier refuses to share their Udyam Registration Number. What do we do?
If a supplier refuses to share their URN, the company cannot confirm their MSME status and is not required to assume it for MSME-1 purposes. Keep a written record, such as an email request, since this contemporaneous documentation helps if MSME status is claimed later.
We incorporated in October 2025. Do we need to file MSME-1 for the April–September 2026 period?
Yes, if the company had outstanding MSME supplier dues exceeding 45 days as on September 30, 2026. The MSME-1 filing obligation arises whenever the conditions under Section 22 of the MSMED Act 2006 and the Order 2019 are met — there is no grace period for newly incorporated companies.
Are LLPs required to file Form MSME-1?
No. The Companies (Furnishing of Information about Payment to Micro and Small Enterprise Suppliers) Order 2019 was issued under Section 405 of the Companies Act 2013, and Form MSME-1 with the ROC applies only to companies incorporated under that Act, not LLPs.
Is a nil return required if we have no overdue MSME dues on September 30, 2026?
No. If a company genuinely has no outstanding dues to Udyam-registered Micro or Small enterprise suppliers exceeding 45 days as on September 30, 2026, it is not required to file Form MSME-1 for that half-year.
What is the interest liability if we delay paying an MSME supplier beyond 45 days?
Under Section 22 of the MSMED Act 2006, a buyer who delays payment beyond the agreed period (capped at 45 days) must pay compound interest at three times the RBI bank rate on the delayed amount, in addition to the MSME-1 disclosure obligation.
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