Quick answer
Who has to file MSME Form 1?
A company files MSME Form 1 when it has payments outstanding to micro or small enterprise suppliers for more than 45 days from acceptance or deemed acceptance of their goods or services. The return covers each half year and is due by 31 October (April to September) and 30 April (October to March).
- Filed under section 405 of the Companies Act, 2013
- Trigger: micro or small supplier dues beyond 45 days
- Due 31 October and 30 April
- Revised form since 15 July 2024 asks for ageing and reasons
- Penalty ₹20,000 plus ₹1,000 a day, up to ₹3 lakh
What is MSME Form 1 and why does it exist?
MSME Form 1 is the return the Ministry of Corporate Affairs uses to track how long companies take to pay their micro and small suppliers. It was introduced by an order dated 22 January 2019 (S.O. 368(E)) under section 405 of the Companies Act, 2013, which lets the government call for information from companies.
The order applies to "specified companies": companies that buy goods or services from micro and small enterprises and whose payments to them exceed 45 days from the date of acceptance or deemed acceptance, as defined in section 9 of the MSMED Act, 2006. The return asks for the amount due and the reason for the delay.
Medium enterprises are not covered. Only suppliers that are micro or small count, so the first job is to find out which of your vendors fall into those categories. A vendor's Udyam certificate shows its classification; our page on Udyam registration explains how those categories work.
Who needs to file MSME Form 1 after the 2024 amendment?
Since 15 July 2024, only companies that actually have payments to micro or small suppliers outstanding for more than 45 days need to file MSME Form 1. A company that paid every such supplier within 45 days has nothing to report for that half year.
The change came through the Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Amendment Order, 2024, S.O. 2751(E), which added a proviso to the 2019 order and replaced the form itself.
| Your position | File MSME Form 1? |
|---|---|
| You owe a micro or small supplier for more than 45 days from acceptance | Yes |
| You paid a micro or small supplier late during the half year | Check: the revised form asks for amounts liquidated after 45 days |
| All micro and small suppliers paid within 45 days | No return needed under the 2024 proviso |
| Late payments only to medium enterprises or non-MSME vendors | No |
| You are an LLP, partnership or proprietorship | No: the order covers companies |
Sources: Gazette text of S.O. 368(E), 22 January 2019 and S.O. 2751(E), 15 July 2024, checked 10 November 2026.
Need help with MSME Form 1 half-yearly return filing? Talk to a chartered accountant in Delhi today. First call is free.
What are the MSME Form 1 due dates?
MSME Form 1 is filed twice a year: by 31 October for the half year from April to September, and by 30 April for the half year from October to March. These dates come from paragraph 3 of the 2019 order and still apply.
| Half year | Period covered | Due date |
|---|---|---|
| First half | 1 April 2026 to 30 September 2026 | 31 October 2026 |
| Second half | 1 October 2026 to 31 March 2027 | 30 April 2027 |
Due dates per para 3 of the Specified Companies Order, 2019 (Gazette text). File on the MCA V3 portal.
What information does the revised MSME Form 1 ask for?
The revised MSME Form 1 asks for a supplier-wise table: each micro or small supplier's name and PAN, what was paid within 45 days, what was paid after 45 days, what is outstanding for 45 days or less and for more than 45 days, and the reason for any delay.
- Company details: CIN, name, registered office address, email and PAN.
- Return period: start and end dates of the half year.
- Payment mode: amounts paid through TReDS (the trade receivables discounting system) are shown separately from other modes.
- Reason for delay: one explanation for each supplier with late or outstanding dues.
- Signature: a director, managing director, manager, company secretary, CFO, CEO or authorised representative signs digitally.
The portal offers an Excel template for companies with many suppliers. The form also reminds the signatory that section 405(4) penalises incorrect or incomplete information, so the numbers need to tie back to your ledgers.
How to file MSME Form 1: step by step
The work is mostly in the accounts, not on the portal. A clean vendor master saves hours each half year.
- 1
Tag MSME vendors
We list every vendor that has given you a Udyam number and mark which are micro, small or medium.
- 2
Age the payables
From your purchase ledger, we age each micro and small supplier's bills from the date you accepted the goods or services.
- 3
Decide if filing applies
If any amount crossed 45 days in the half year, the company files; otherwise we record why no return was needed.
- 4
Collect reasons for delay
Your accounts team gives a short reason for each late supplier, such as a disputed bill or pending quality check.
- 5
Prepare and sign
We fill the form or the Excel import, and a director or other authorised signatory signs with a DSC.
- 6
File and keep records
We file before the due date and keep the ageing working with your year-end papers for the auditor.
What is the penalty for not filing MSME Form 1?
Under section 405(4), a company that fails to file MSME Form 1, or files wrong or incomplete figures, is liable to a penalty of ₹20,000, and so is every officer in default. A continuing failure adds ₹1,000 a day after the first, up to ₹3 lakh.
ROCs do impose this. In an order dated 6 January 2026, the ROC Coimbatore imposed the maximum ₹3,00,000 on a company and on each of four officers, including its managing director and CFO, for late MSME returns. The order is reproduced on TaxGuru. Penalties are paid on the MCA e-adjudication portal within 90 days, and an appeal lies to the Regional Director within 60 days.
Paying MSME suppliers late can carry tax effects for the buyer too. Ask your tax adviser how this applies to your company for the current year before finalising accounts.
Delhi companies and MSME supplier dues
Delhi has a large base of micro and small suppliers, from fabricators in Wazirpur and Okhla to traders in Chandni Chowk and service firms across the city. A Delhi company buying from them on 60 or 90-day credit often crosses the 45-day line without realising it is reportable.
Companies registered in Delhi file with ROC Delhi, but MSME Form 1 is filed online like every other ROC form. The usual trouble spots we see locally are vendors who registered on Udyam after the purchase relationship began, invoices accepted late because goods were inspected weeks after delivery, and bills that sit unpaid because they are under dispute. Each of these needs a clear position in your working before you file.
How CA in Delhi handles MSME Form 1
We take MSME Form 1 on as a twice-yearly job, or as part of a wider annual compliance package for a private limited company. You get a fixed quote before work starts, based on how many vendors you have and whether earlier half years are pending.
- What you send: the vendor list with Udyam numbers, the purchase ledger or payables ageing for the half year, and reasons for any late payments.
- What we do: tag micro and small suppliers, age the dues, decide whether a return is needed, prepare the form and file it.
- What you get back: the filed form and SRN, or a note recording why no return was required, plus a vendor master you can keep updated.
ROC compliance work is handled by the listed firm whose services include it, Moneymji, or by a partner professional we brief. See all listed chartered accountant firms in Delhi. Manufacturers in the industrial belt can read about our work for businesses in Wazirpur, and if you also need monthly books kept, look for an accountant near you in our directory.
Frequently asked questions
What is MSME Form 1 in simple words?
It is a report a company sends to the ROC every six months listing the micro and small suppliers it has not paid within 45 days of accepting their goods or services, with the amounts and the reasons. It does not apply to payments to medium enterprises or to suppliers without micro or small status.
Is a nil MSME Form 1 required?
Since the 15 July 2024 amendment, the order says only companies with payments outstanding to micro or small suppliers for more than 45 days furnish the form. If nothing crossed 45 days, there is nothing to report. Some websites still advise nil returns from the earlier rule; we record the position in your file either way.
Does MSME Form 1 apply to LLPs or proprietors?
No. The order is made under the Companies Act, so it applies to companies, including private limited companies and OPCs. LLPs, partnerships and proprietorships do not file it, though they should still pay micro and small suppliers on time for commercial and tax reasons.
How is the 45 days counted?
From the day the company accepts the goods or services, or the day they are deemed accepted, as defined in section 9 of the MSMED Act. Delivery date and acceptance date can differ when goods are inspected, so your records should show when acceptance actually happened.
Which suppliers count as micro or small?
Suppliers classified as micro or small enterprises under the MSMED Act, which in practice means those holding Udyam registration in those categories. Ask each vendor for its Udyam certificate and keep it on file. A vendor classified as medium does not go into MSME Form 1.
Who signs MSME Form 1?
The revised form can be signed digitally by a director, managing director, manager, company secretary, CFO, CEO or an authorised representative. The signatory needs a valid DSC registered on the MCA portal, so check this a week before the due date.
What happens if earlier half years were missed?
File the missed returns as soon as you can, oldest first, with accurate figures from that period. The ROC can still adjudicate a penalty under section 405(4), but correcting the record early puts the company in a better position than waiting for a notice.
Is MSME Form 1 part of annual ROC filing?
It is a separate half-yearly return, not part of AOC-4 or MGT-7. Many companies handle it with their ROC compliance calendar so the October and April dates are not missed.