In this guide
Companies covered by the MSME reporting requirement must file MSME Form I for April–September 2026 by October 31, 2026, unless an applicable MCA extension provides otherwise.
The form reports payments and outstanding amounts relating to micro and small enterprise suppliers. It is a company-law filing with the Registrar of Companies, not an application for MSME registration or a GST return.
Who Must File MSME Form I?
The requirement applies to specified companies that receive goods or services from micro or small enterprises and have qualifying payments pending for more than 45 days from acceptance or deemed acceptance.
It can apply to private companies, public companies and One Person Companies. The buyer need not be an MSME.
LLPs, ordinary partnership firms and proprietorships do not file this company form merely because they have outstanding supplier payments. Payment obligations under other laws should be checked separately.
| Situation | Treatment |
|---|---|
| Company has qualifying micro/small supplier dues exceeding 45 days | Filing requirement applies |
| Company deals only with medium enterprises | Those suppliers do not trigger this requirement |
| All relevant payments were made within 45 days and no qualifying overdue dues exist | No nil return is ordinarily required |
| Supplier was paid after 45 days during the half-year | Review the delayed-payment information required by the revised form |
| Buyer is an LLP or proprietorship | MSME Form I is not its company-law filing |
Do not assume reporting is unnecessary because the supplier balance is zero on September 30. The revised form expressly includes amounts liquidated after 45 days, so review payment history as well as closing balances.
Which Suppliers Count as Micro or Small?
Verify each supplier’s Udyam registration, classification and relevant business activity. MSME includes medium enterprises, but MSME Form I concerns micro and small enterprises.
The revised classification limits effective April 1, 2025 are:
| Category | Investment in plant and machinery or equipment | Annual turnover |
|---|---|---|
| Micro | Not exceeding ₹2.5 crore | Not exceeding ₹10 crore |
| Small | Not exceeding ₹25 crore | Not exceeding ₹100 crore |
Both investment and turnover criteria matter. Avoid outdated limits or classifying suppliers solely by the value of purchases your company made from them.
TaxClear’s Udyam registration guide explains the classification framework.
How Does the 45-Day Rule Work?
For this reporting test, count from acceptance or deemed acceptance of goods or services, rather than automatically using the invoice date or contractual payment due date.
Keep delivery, service-completion, acceptance and written-objection records where relevant.
For example, goods accepted on August 1, 2026 and still unpaid on September 30 have remained unpaid for more than 45 days. Include the qualifying dues in the company’s reporting review.
The reporting threshold does not give every buyer an automatic 45-day interest-free credit period. Payment deadlines and delayed-payment interest under the MSMED Act are separate legal questions.
Reporting Period and Deadline
| Reporting period | Ordinary filing deadline |
|---|---|
| April 1–September 30, 2026 | October 31, 2026 |
| October 1, 2026–March 31, 2027 | April 30, 2027 |
An extension for AOC-4, LLP Form 8 or income-tax returns does not automatically extend MSME Form I. Ensure that any relaxation specifically covers this filing.
Information to Prepare
Create a supplier-wise working covering:
- Supplier name, PAN and Udyam details;
- Relevant micro/small classification;
- Invoice and acceptance dates;
- Amounts paid within 45 days;
- Amounts paid after 45 days;
- Outstanding amounts aged 45 days or less;
- Outstanding amounts aged more than 45 days;
- Payment modes, including TReDS where applicable;
- Reasons for delayed payment.
Compare these figures with purchase ledgers, bank records, credit notes and supplier confirmations. Do not exclude a supplier merely because its classification has not been recorded in your accounting software.
Once the filing requirement applies, complete all applicable disclosures in the revised form before submission, rather than reporting only overdue invoices.
How to File on MCA V3
- Sign in using the appropriate MCA account.
- Open MSME Form I and select the periodic half-yearly return.
- Enter the company’s CIN or applicable identification details.
- Select April 1–September 30, 2026.
- Complete the supplier-wise payment and outstanding-dues disclosures.
- Explain delays and arrange the required digital signature.
- Submit, complete the portal requirements and retain the acknowledgement.
Check the final filing status. A saved draft or generated SRN alone does not establish completed filing.
What Happens If You Do Not File?
Failure to comply, or furnishing materially incorrect or incomplete information, can attract penalties under Section 405(4) of the Companies Act, 2013.
The provision specifies ₹20,000 for the company and each officer in default, with a further ₹1,000 per day for continuing failure after the first day, subject to a maximum of ₹3 lakh for each liable company or officer. The maximum is not ₹3 lakh per day. Applicable penalty-reduction provisions should be checked separately.
For applicability review and filing assistance, contact TaxClear’s ROC compliance team.
Frequently Asked Questions
Must every company file MSME Form I?
No. The specified-company reporting conditions must apply.
Is a nil return required?
Ordinarily, no. However, review payments made after 45 days during the reporting half-year before concluding that nothing is reportable.
Are medium-enterprise suppliers covered?
No. This reporting requirement concerns micro and small suppliers.
Does paying before September 30 remove all reporting?
Not necessarily. The revised form includes payments made after 45 days during the reporting period.
Does filing settle delayed-payment obligations?
No. Reporting does not settle supplier dues, interest or separate tax consequences.
