MSME Form I Due by 31 October 2026
Check whether your company has payments pending to micro or small enterprises for more than 45 days.
First check applicability—do not file blindly
Under the amendment dated 15 July 2024, only specified companies having payments pending to a micro or small enterprise for more than 45 days from acceptance or deemed acceptance are required to furnish MSME Form I.
What is MSME Form I?
MSME Form I is a half-yearly return filed with the Registrar of Companies. It gives prescribed information relating to payments made or remaining outstanding to micro and small enterprise suppliers.
The reporting requirement arises under an order issued under Section 405 of the Companies Act, 2013. The form is presently available as a web-based form on the MCA V3 portal.
The half-yearly return for this period is ordinarily filed by 31 October.
The half-yearly return for this period is ordinarily filed by 30 April.
Who should check the filing requirement?
A company should carry out the applicability check where:
- It has purchased goods or services from a micro or small enterprise.
- The supplier qualifies as a micro or small enterprise under the applicable MSME framework.
- Payment remains pending for more than 45 days from acceptance or deemed acceptance.
- The company falls within the definition of a specified company under the governing order.
Important eye-opener
Do not identify MSME suppliers only from the ledger name. A supplier may have obtained Udyam registration during the year, changed its classification or supplied an incorrect registration number. Obtain and verify the relevant supplier declaration and Udyam details.
Understanding the payment period
Under Section 15 of the MSMED Act, the written credit period agreed between the buyer and supplier cannot exceed 45 days from acceptance or deemed acceptance. Where there is no written agreement, payment is linked to the appointed day under the Act.
| Situation | Practical review |
|---|---|
| Goods accepted without objection | Consider the date of actual delivery and acceptance. |
| Service completed | Check service completion, approval and invoice records. |
| Written objection raised | Keep evidence of the objection and its resolution. |
| Part payment made | Calculate the ageing of the unpaid invoice balance. |
Do not rely only on the closing creditor balance
A year-end or half-year creditor balance is not sufficient for preparing MSME Form I. The company should review invoices and payments during the entire reporting period.
The revised web form captures the number and amount of transactions under different payment and outstanding categories, including payments made within or after 45 days and amounts outstanding for different periods.
Invoice-wise preparation checklist
- Obtain the complete trade-payables ledger.
- Collect supplier-wise Udyam registration details.
- Separate micro and small enterprises from medium enterprises.
- Verify the date of delivery or completion of service.
- Check the invoice date and acceptance date separately.
- Review the written credit terms with each supplier.
- Map payments against the correct invoices.
- Identify part payments, advances and credit notes.
- Calculate invoice-wise ageing beyond 45 days.
- Reconcile the working with the general ledger and financial statements.
Most commonly missed points
The filing focuses on micro and small enterprise suppliers—not every entity registered as an MSME.
The legal test refers to acceptance or deemed acceptance, which may differ from the invoice date.
Payments made after 45 days during the period may also require correct reporting in the form.
MSME Form I and financial statements are separate checks
Filing the form does not replace MSME disclosures in the financial statements, interest evaluation, confirmation of supplier status or examination of applicable income-tax consequences. Each requirement should be reviewed separately.
Example
A company received goods from a registered micro enterprise and accepted them without objection. The payment remained outstanding beyond 45 days.
The company should examine MSME Form I applicability, calculate the correct outstanding amount invoice-wise and retain the purchase, receipt, acceptance, Udyam and payment records supporting the return.
Documents to keep ready
- Supplier master and trade-payables ledger
- Udyam certificates or supplier declarations
- Purchase invoices and debit or credit notes
- Goods-receipt or service-completion records
- Purchase orders and written payment terms
- Bank statements and payment allocation details
- Invoice-wise ageing and reconciliation
- Details of disputes or written objections
Professional assistance
GURURAAJA SANJAY & CO., CHARTERED ACCOUNTANTS assists companies with MSME supplier identification, invoice-wise ageing, ledger reconciliation, financial-statement disclosure review and preparation of MSME Form I supporting workings.
Need help checking MSME Form I applicability?
Complete an invoice-wise review before filing and preserve clear supporting records.
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