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MSME-1:
Half-yearly return of dues outstanding to micro and small suppliers

Half-yearly return of dues to micro and small suppliers outstanding beyond 45 days.

Last reviewed: 2026-08-19 · every figure carries its source

When it is due — the statutory rule
The Specified Companies Order 2019 fixes the dates directly: by 31 October for the Apr–Sep half-year and by 30 April for Oct–Mar
In practice, this cycle

31 Oct 2026 for the Apr–Sep 2026 half-year; 30 Apr 2027 for the Oct 2026–Mar 2027 half-year

Late: Penalty up to ₹3 lakh (s.405(4))See the full additional-fee ladder →See this date in the compliance calendar →

What MSME-1 does

Half-yearly return by 'specified companies' disclosing amounts due to micro and small enterprise (MSE) suppliers outstanding for more than 45 days from the date of acceptance/deemed acceptance of goods or services (the s.15 MSMED Act clock), with supplier-wise details and reasons for the delay. Filed for each half-year: April–September and October–March.

Who files — and the thresholds

Every company (any size) that (a) received goods/services from suppliers registered as micro or small enterprises (Udyam), and (b) has payments to them outstanding beyond 45 days as at the half-year end / during the half-year. Medium enterprises do NOT count. No outstanding beyond 45 days = no return required (a nil MSME-1 is not mandated).

Attachments

  • No mandatory document attachments — the form itself captures supplier name, PAN, amount due, date from which due, and reasons for delay; optional attachment for supplementary details

What filing late costs

Penalty under s.405(4), Companies Act 2013 (post-2020 decriminalisation): company and every officer in default liable to ₹20,000, plus ₹1,000/day of continuing failure, capped at ₹3,00,000. (Older articles still quote the pre-2020 'fine up to ₹25,000' — the current adjudicated-penalty figures are the ₹20,000/₹1,000/day/₹3 lakh set.)

Compare all three additional-fee regimes side by side →

Common mistakes

Counting 45 days from the invoice date instead of from acceptance/deemed acceptance of the goods or services under s.15 MSMED Act (and ignoring that a shorter agreed credit period governs, with 45 days as the statutory ceiling)

Including medium enterprises or unregistered vendors — only Udyam-registered micro and small suppliers are in scope; collect Udyam certificates from vendors to know who counts

Filing nil returns unnecessarily (not required when nothing is outstanding beyond 45 days) while missing the half-year where a single invoice slipped past 45 days

The statutory basis

Section 405, Companies Act 2013 read with the Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order 2019 (S.O. 368(E) dated 22 Jan 2019); the 45-day rule from s.15, MSMED Act 2006; penalty under s.405(4) as substituted by the Companies (Amendment) Act 2020

Open the source document →

MCA extends dates ad hoc in some years. This page encodes the statutory position — verify the current date on mca.gov.in before filing.

Frequently asked

We paid the MSE supplier on day 50 — do we still report?

The obligation is triggered by amounts outstanding beyond 45 days. An amount that crossed 45 days during the half-year falls within the return's scope even if since paid — report it with the payment/delay particulars per the form.

How do we know a supplier is micro or small?

By their Udyam registration. Best practice is an annual vendor declaration collecting Udyam numbers; without MSE registration the supplier is outside MSME-1 (though interest under s.16 MSMED can still be claimed by registered suppliers).

Is there a late fee per day like AOC-4?

No ₹100/day regime and no filing-fee slab applies in the same way (MSME-1 has no normal fee); the real exposure is the s.405(4) adjudicated penalty for non-filing or wrong information — up to ₹3 lakh for the company and each officer — plus the disallowance under s.43B(h) of the Income-tax law for payments beyond the MSMED limit.

More company filings
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Files the year's audited financial statements — balance sheet, P&L, Board's report — with the ROC. · 30 Oct 2026 (AGM 30 Sep) · OPC: 27 Sep 2026
MGT-7
Annual return of shareholding, members, directors, KMP, meetings and remuneration. · 29 Nov 2026 (AGM 30 Sep; practitioners target 28 Nov)
MGT-7A
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KYC of every DIN holder — now once every third financial year, by 30 June. · Next: 30 Jun 2028 if compliant through FY 2025-26
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This is a filing reference, not legal advice. Filing obligations turn on your company's own facts — its AGM date, paid-up capital, turnover, borrowings, supplier profile and any ROC extension in force. This page is a reference to the forms and their statutory due rules, not legal or professional advice, and it does not create an advocate-client relationship. Due dates shown assume an AGM held on 30 September 2026 where the rule is AGM-linked; MCA extends dates ad hoc in some years and this page encodes the statutory position, so verify the current date on mca.gov.in before filing, and take advice on your own facts before acting. Forms and figures here were reviewed on 19 August 2026.

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