The MSME Form 1 due date for the April to September 2026 half-year is 31 October 2026. If your company paid even one micro or small supplier more than 45 days after accepting their goods or services, or still owes one past that line, this half-yearly return to the Registrar of Companies is probably yours to file.
Most finance teams find out the hard way: an auditor flags a Udyam-registered vendor in the creditors list, someone asks whether “MSME-1 was filed”, and nobody is sure whether a company with nothing overdue on 30 September needs to file at all. This guide covers the legal basis, who must file, what the form asks for, the V3 filing steps, the penalty, and the income-tax hit that sits next to it.
MSME Form 1 Due Date for 2026
The 2019 MCA order fixes two half-years and two due dates. Each return is due one month after its half-year ends.
| Half-year covered | MSME Form 1 due date |
|---|---|
| 1 April to 30 September 2026 | 31 October 2026 |
| 1 October 2026 to 31 March 2027 | 30 April 2027 |
| 1 October 2025 to 31 March 2026 | 30 April 2026 (passed) |
As of 19 October 2026 we found no MCA circular extending the 31 October date. Extensions for this form are rare, but check the news section of the MCA portal before you rely on any later date.
There is no government fee. The MCA instruction kit says the fee rules section is “not applicable”, and no additional fee is prescribed for late filing. The cost of missing the date is the penalty under Section 405(4), covered below.
What MSME Form 1 Is and Where It Comes From
MSME Form 1 (written “MSME Form I” in the order, and often searched as the MSME half yearly return) is a return in which a company reports its payments to micro and small enterprise (MSE) suppliers that crossed 45 days. Three pieces of law sit behind it:
- Section 405 of the Companies Act, 2013. It lets the Central Government order companies to furnish information or statistics within a set time, and it carries the penalty.
- The Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019, notified as S.O. 368(E) on 22 January 2019. Paragraph 3 sets the two due dates. Paragraph 2 asked for a one-time initial return of dues outstanding on that date, which is now history.
- The Amendment Order, 2024, notified as S.O. 2751(E) on 15 July 2024. It added a proviso saying who must file and replaced the form with a more detailed one. The new form went live on the V3 portal the same week.
We found no later amendment to the order, the form or the due dates in 2025 or 2026. The supplier thresholds did change: from 1 April 2025 a micro enterprise can have up to ₹2.5 crore in plant and machinery or equipment and ₹10 crore turnover, and a small enterprise up to ₹25 crore and ₹100 crore. More of your vendors may now count as small enterprises than before.
The 45-Day Rule Behind the Return
Section 15 of the Micro, Small and Medium Enterprises Development Act, 2006 (MSMED Act) tells a buyer when to pay a micro or small supplier:
- With a written agreement: on the agreed date, but the agreed period can never exceed 45 days from acceptance or deemed acceptance.
- Without a written agreement: before the “appointed day”, the day after 15 days from acceptance or deemed acceptance.
Acceptance is normally the day of delivery or of the service being rendered. If you object in writing within 15 days, acceptance moves to the day the supplier removes the objection. If you do not object within 15 days, you are deemed to have accepted on the delivery day. So the clock usually starts on delivery, not on the invoice date or the day the invoice reached accounts.
Note the gap. The form tests 45 days, but a supplier with no written terms is legally overdue after 15. A late payment also costs money: Section 16 makes the buyer pay compound interest with monthly rests at three times the RBI bank rate, whatever the contract says, and Section 23 says that interest is not deductible for income tax.
Who Must File MSME Form 1
The order calls them “specified companies”: companies that get supplies of goods or services from micro and small enterprises and whose payments to those suppliers exceed 45 days from acceptance or deemed acceptance. The 2024 proviso narrows it further: only specified companies “having payments pending” to a micro or small enterprise for more than 45 days must furnish the form.
In practice, all of these must be true:
- You are a company. The order is made under the Companies Act, so private, public and one person companies are in scope whatever their size. The form also accepts an FCRN for foreign companies. LLPs, partnership firms and proprietors do not file it.
- The supplier is a micro or small enterprise. Dues to medium enterprises are not reported. Under the MSMED Act a “supplier” is an MSE that has filed its memorandum, which today means a Udyam registration. Ask vendors for their Udyam certificate and check it on the Udyam portal.
- At least one payment crossed 45 days from acceptance or deemed acceptance in the half-year.
If your vendors are not registered yet, our Udyam registration guide explains what they get from it, and the online Udyam process guide walks them through the form. Under the Act’s definition a vendor becomes a “supplier” once registered, so keep each certificate’s registration date on file.
Is a Nil Return Required?
No. The order makes no provision for a nil return. Only specified companies must file, and since the 2024 proviso only those with payments pending beyond 45 days. If every micro and small supplier was paid within 45 days of acceptance during the half-year, there is nothing to file. Keep the working papers that show it, because your auditor will ask.
The grey area is a payment that crossed 45 days but was cleared before 30 September. The proviso speaks of payments “pending”, which some practitioners read as dues still unpaid at the end of the half-year. But the form’s own note asks you to report amounts “liquidated after 45 days of acceptance”, and it has a separate column for amounts paid after 45 days. Our reading: if any MSE payment crossed 45 days at any point in the half-year, file. There is no fee, and Section 405(4) penalises a missed or incorrect return.
What Goes Into the Form
The 2024 form is short, but the supplier table needs a clean ledger. Part 1 is company details (CIN or FCRN, name, registered office, email, PAN), mostly pre-filled from your CIN. Part 2 is the return type (“Periodic Half-yearly return”) and the period, which must start on 1 April or 1 October. Part 3 is one row per supplier:
| Column | What you enter |
|---|---|
| Name of MSE supplier | Legal name |
| PAN of the supplier | Valid PAN, one row per PAN |
| Paid within 45 days | Number and amount, split into via TReDS and other modes |
| Paid after 45 days | Number of transactions and amount |
| Outstanding 45 days or less | Number of transactions and amount |
| Outstanding over 45 days | Number of transactions and amount |
| Reason for delay | Free text |
So for every supplier you list, you report all of their transactions in the half-year, including those paid on time. The “No.” fields mean number of transactions and take a value from 0 to 1,000. You can download an Excel template from the form, fill up to 1,000 rows and import it.
Think about the reason column before you type it. “As per agreement” is a weak answer, because Section 15 caps any written credit period at 45 days. Specific reasons hold up better: a quality dispute raised in writing, a supplier’s GSTIN mismatch, a bank account change pending verification.
How to File MSME Form 1 on the MCA V3 Portal
MSME Form 1 is a V3 webform, not a downloadable PDF form. You need an MCA user account (see our MCA V3 login guide) and a DSC registered on the portal for the signatory.
- Log in to the MCA portal and go to MCA Services, then Company e-Filing, then Compliance Services.
- Open “MSME – Half yearly return of Micro or Small Enterprise”. You can also find it through the site search.
- Enter or select the CIN. Company details fill in automatically.
- Enter the start date of the half-year (1 April 2026 for this return). The end date fills itself.
- Download the Excel template, fill one row per supplier PAN, and import it. Check the auto-calculated totals.
- Attach any supporting PDF if you need more space (optional, 2 MB each).
- Choose the signatory: director or MD (DIN), manager, CEO, CFO or authorised representative (DIN or PAN), or company secretary (membership number). A disqualified director cannot sign.
- Submit. An SRN is generated. Download the PDF, affix the DSC and upload it within 15 days, or the SRN is cancelled.
- Save the acknowledgement. The form is processed in STP mode and taken on record automatically.
Three things trip filers up. The kit says there is no provision for resubmission, and you cannot file a second return for the same period unless the first is marked defective, so check the data before you submit. A company flagged for INC-22A (ACTIVE) cannot file. And DSC errors are common; our DSC guide for MCA filings covers registration and signing.
Penalty for Not Filing MSME Form 1
Since the Companies (Amendment) Act, 2020, Section 405(4) is a civil penalty, not a criminal fine. If a company fails to comply with the order, or furnishes information that is incorrect or incomplete in any material respect:
| Who is liable | Penalty |
|---|---|
| The company | ₹20,000, plus ₹1,000 per day of continuing failure, up to ₹3,00,000 |
| Every officer in default | The same: ₹20,000, plus ₹1,000 per day, up to ₹3,00,000 |
The section applies one penalty clause to “the company and every officer of the company who is in default”, and the form itself reminds the signatory that wrong or incomplete figures fall under the same sub-section. Missing the return is not the only risk; filing it with numbers your ledger cannot back up is too.
The Income-Tax Link: Section 43B(h) and Section 37(2)(g)
The Finance Act, 2023 added clause (h) to Section 43B of the Income-tax Act, 1961, from assessment year 2024-25: “any sum payable by the assessee to a micro or small enterprise beyond the time-limit specified in section 15” of the MSMED Act is deductible only in the year it is actually paid. The usual 43B relief for paying before the return due date was switched off for this clause.
The Income-tax Act, 2025 took effect on 1 April 2026. The same rule is now Section 37(2)(g), in almost the same words, and Section 37(3) again excludes clause (g) from the return-date relief. For the year ended 31 March 2026 you apply Section 43B(h); for tax year 2026-27 onward, Section 37(2)(g).
The two tests do not match, so reconcile them rather than copy one into the other:
- MSME Form 1 looks at the 45-day line in each half-year.
- The tax rule looks at the Section 15 time limit, which can be 15 days where there is no written agreement, and at what is unpaid when the financial year closes.
A bill with no written credit terms that is 30 days old on 31 March stays out of MSME Form 1’s over-45-day columns, yet it is already past the Section 15 limit, so its deduction moves to the year you pay it. One MSE ageing report can serve both tests, plus the Section 22 MSMED disclosure in the audited accounts. If you are lining these up with your other ROC dates, our annual compliance calendar puts them in one place.
Frequently Asked Questions
What is the MSME Form 1 due date for October 2026?
31 October 2026, for the half-year from 1 April to 30 September 2026. The next return, for October 2026 to March 2027, is due 30 April 2027. We found no extension notified as of 19 October 2026.
Do I need to file MSME Form 1 if nothing is overdue?
No. There is no nil return. If no payment to a micro or small supplier crossed 45 days from acceptance during the half-year, you do not file. If one crossed 45 days but was paid before the half-year ended, the safer course is to file, because the form asks for amounts paid after 45 days.
Are dues to medium enterprises reported?
No. The order and the form cover micro and small enterprises only. Medium enterprises are also outside Section 15 of the MSMED Act and the Section 43B(h) or 37(2)(g) disallowance.
Can I file MSME Form 1 for a missed half-year?
Yes. The V3 form accepts any half-year starting on or after 1 October 2018, and there is no additional fee. Filing late does not remove exposure to the Section 405(4) penalty, which runs per day of continuing failure, so file as soon as you spot the gap.
How do I check whether a supplier is a micro or small enterprise?
Ask for the Udyam registration certificate, which states the category, and verify the number on the Udyam portal. A supplier’s category can change as its investment and turnover change, so recheck it at least once a year. If the supplier is itself a company, you can confirm its CIN and status with a free WeeDoo company search.
