MSME Form 1 Due Date in 2026: Who Files, What Data
Last updated: 6 November 2026
Quick Answer: MSME Form 1 is the half-yearly return in which a company reports dues to micro and small enterprise suppliers outstanding beyond 45 days. The 45 days run from acceptance or deemed acceptance. Returns for April to September are due by 31 October, and for October to March by 30 April; no filing fee applies.
Each MSME Form 1 due date set in paragraph 3 of S.O. 368(E) is easy to diarise and the webform is short; the hard part sits in the purchase ledger. For a Coimbatore pump maker buying castings from small foundries, the return is only as reliable as its vendor ageing.
For the MD or CFO, the decision table and vendor ageing column map below turn the filing rules into a half-year routine.
Which Order Requires the Half-Yearly Return?
Under section 405 of the Companies Act, 2013, the Central Government issued, on 22 January 2019, S.O. 368(E), the Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019.
A "specified company" buys from micro and small enterprises and pays them beyond 45 days from acceptance or deemed acceptance.
MSME Form 1 Applicability After the July 2024 Amendment
Private and public companies are covered, and the MCA instruction kit also provides for foreign companies, which file with an FCRN; only dues to micro and small suppliers count. Under the MSMED Act, 2006 a "supplier" is a micro or small enterprise that has filed a memorandum under section 8; in practice, the Udyam Registration. From 1 April 2025, S.O. 1364(E) of 21 March 2025 caps a micro enterprise at ₹2.5 crore of investment in plant and machinery or equipment and ₹10 crore of turnover, and a small enterprise at ₹25 crore and ₹100 crore.
The 2024 Proviso and the Revised Form
On 15 July 2024, S.O. 2751(E) added a proviso to paragraph 3. Only specified companies with payments pending to a micro or small enterprise for more than 45 days now furnish the information. The revised form asks for amounts outstanding beyond 45 days and amounts "liquidated after 45 days of acceptance", and splits timely payments between TReDS and other modes.
Where Readings of the Proviso Differ
A company that paid every micro or small invoice within 45 days files no nil return. The disputed case is late payment with nothing overdue at 30 September or 31 March: the proviso says "pending", the form note "liquidated"; confirm it with your company secretary.
MSME Form 1 Due Date for Each Half-Year
The MSME 1 due date is fixed by paragraph 3 of the order: two dates, unchanged by the 2024 amendment.
| Half-year | Due date | Next return (as of 6 November 2026) |
|---|---|---|
| 1 April to 30 September | 31 October | April to September 2027, due 31 October 2027 |
| 1 October to 31 March | 30 April | October 2026 to March 2027, due 30 April 2027 |
The webform accepts a period start of 1 April or 1 October only.
What Data Does the Form Ask For?
Field 3 takes one row per micro or small supplier:
- (b) supplier name
- (c) income-tax PAN
- (d) payments within 45 days, split between TReDS and other modes
- (e) payments after 45 days
- (f) amounts outstanding for 45 days or less
- (g) amounts outstanding for more than 45 days
- (h) reason for delay
Columns (d) to (g) each take a count of transactions, marked "No.", and a rupee amount. The MCA Excel template holds up to 1,000 rows, one unique PAN per row.
Half-Year Decision Table and Vendor Ageing Column Map
File or Not: Seven Half-Year Scenarios
| Scenario in the half-year | Basis | Return due? |
|---|---|---|
| No micro or small purchases | Nothing pending | No |
| Every micro or small invoice paid within 45 days | Nothing pending | No |
| Some invoices paid late, nothing overdue at the half-year end | Proviso "pending" vs form note "liquidated" | Readings differ: ask your company secretary |
| Micro or small dues overdue beyond 45 days at the half-year end | Within the proviso | Yes |
| Overdue dues only to medium enterprises | Order covers micro and small only | No |
| Supplier has shared no Udyam Registration | "Supplier" means one that filed its memorandum | Check status with your company secretary |
| Buying company is itself micro or small | No exception for buyer size | Same tests apply |
Vendor Ageing to Form: Column Map (illustrative layout)
| Ageing column | Form field | Working rule |
|---|---|---|
| Supplier name as per PAN | 3(b) | One row per PAN, not per GSTIN |
| Supplier PAN | 3(c) | Merge duplicates before import |
| Udyam number and category | Control only | Screens out medium and unregistered vendors |
| Acceptance or deemed acceptance date | Control only | Delivery date, or the date a written objection was resolved |
| Agreed due date | Control only | At most 45 days from the day of acceptance or the day of deemed acceptance |
| Paid within 45 days, TReDS or other modes | 3(d)(i), 3(d)(ii) | Count and amount for each |
| Paid after 45 days | 3(e) | Settled during the half-year |
| Open, 45 days or less | 3(f) | At 30 September or 31 March |
| Open, more than 45 days | 3(g) | At 30 September or 31 March |
| Reason for delay | 3(h) | Factual: quality dispute, invoice mismatch |
Who Signs the Return on the MCA Portal?
A director or managing director signs with an approved DIN; a manager, CEO, CFO or authorised representative with a DIN or PAN; a company secretary with a membership number. A disqualified director cannot sign.
- Open Company E-Filing, then Compliance Services and the MSME half-yearly return.
- Enter the CIN and period, then import the filled Excel template.
- Submit; the portal generates an SRN.
- Upload the PDF carrying the digital signature within 15 days, or the SRN is cancelled.
The MCA instruction kit for MSME Form I allows no resubmission, so check every row before submitting.
Penalty for Not Filing or Misreporting
Section 405(4), as substituted by the Companies (Amendment) Act, 2020, makes the company and every officer in default liable to a penalty of ₹20,000. A further ₹1,000 applies for each day after the first during which the failure continues, up to a maximum of ₹3 lakh. Incorrect or incomplete information in any material respect attracts the same penalty.
How the Return Connects to the 45-Day Payment Rule
Section 15 of the MSMED Act requires payment by the date agreed in writing, never more than 45 days from the day of acceptance or the day of deemed acceptance, or within 15 days if no date is agreed. Late payment draws section 16 interest, compounded monthly, at three times the Reserve Bank's bank rate.
The form buckets every invoice at 45 days whatever the agreed term. The same ageing feeds the year-end MSME disclosure in the financial statements, so build it once and reconcile both.
Getting the Vendor Ageing Ready: In-House or Outsourced
The return stays the company's own filing; a finance head can delegate the data: Udyam categories in the vendor master, acceptance dates at the GRN and an ageing on 45-day buckets.
An in-house team copes with a modest vendor list; a long one can be outsourced. Astral Business Consulting LLP, a Coimbatore-based management consulting and audit firm, provides outsourced accounts payable work that maintains the vendor master and prepares the vendor ageing through its Best Accountant division. The same division's virtual CFO services in Coimbatore issue a monthly MIS pack that includes creditor and debtor ageing.
During the half-year, payment assurance reviews of timely vendor payments and a pre-payment check of Udyam status can flag micro and small invoices before they pass 45 days.
Need Your Vendor Ageing Ready Before the Next Due Date?
Speak with the Best Accountant division of Astral Business Consulting LLP about preparing a 45-day vendor ageing your signatory can file from.