Form MSME-1 is a half-yearly return that any company — of any size — must file when payments to micro or small enterprise suppliers have run beyond 45 days. The two due dates each year: 30 April (for the October–March half) and 31 October (for the April–September half). There is no government filing fee.
The trigger is precise: the supplier must be Udyam-registered as micro or small (medium enterprises do not count), and the 45-day clock runs from acceptance of goods or services, not the invoice date. If no payment crossed 45 days in the half-year, no filing is needed — there is no nil return. CapEasy’s compliance team tracks this alongside your ROC calendar.
Since July 2024: the revised MSME-1 asks for the full payment picture once any payment breaches 45 days in the half-year: amounts paid within 45 days, amounts paid beyond 45 days (even if fully settled by period end), and amounts still outstanding on both sides of the 45-day line — with reasons for delay.
Who must file MSME-1
- Every company (private, public, OPC — size does not matter) with any payment to a micro or small supplier that exceeded 45 days from acceptance during the half-year.
- Micro and small only — dues to medium enterprises are outside MSME-1, whatever some summaries say.
- The supplier must hold Udyam (MSME) registration for the reporting duty to attach.
- No breach in the half-year means no filing — MSME-1 has no nil-return requirement.
Details required in the form
- Company CIN and PAN.
- Supplier-wise: name, PAN, amounts in each bucket (paid within 45 days, paid beyond 45 days, outstanding up to / beyond 45 days), the date from which amounts are due, and the reason for delay.
- Payment mode for amounts settled within 45 days (a revised-form field).
Due dates
| Half-year covered | Due date |
|---|---|
| October – March | 30 April |
| April – September | 31 October |
For FY 2026 that means 30 April 2026 (already past) and 31 October 2026.
Penalty for not filing
There is no per-day late fee because there is no filing fee. Instead, section 405(4) provides an adjudicated penalty: up to ₹20,000 on the company and on every officer in default, plus ₹1,000 per day of continuing failure, capped at ₹3 lakh. Registrars have actually levied these — multi-lakh adjudication orders exist — so treat the form as real, not decorative.
How to file MSME-1 on MCA V3
- Pull the creditor ageing for Udyam-registered micro and small suppliers for the half-year.
- Verify each supplier’s Udyam status and PAN.
- Log in to MCA V3 → Company e-Filing → Form MSME-1, enter the CIN and select the return period.
- Fill the supplier-wise buckets with reasons for delay.
- Affix the director’s DSC and submit — no fee is payable; save the SRN acknowledgment.
Verified against the Companies Act, 2013 / LLP Act, 2008, MCA rules and circulars as of 31 July 2026. Your exact position depends on your entity and any circulars MCA issues — we confirm it for you, and always recommend checking the official MCA portal. CapEasy is a private consultancy and is not affiliated with any government authority. This page is a guide, not legal advice.