MSME-1 is a reporting obligation created by a Central Government order under section 405 of the Companies Act, 2013. It does not come from the MSMED Act. Companies report dues to micro and small enterprise suppliers outstanding beyond 45 days, twice a year, with the reason for delay. The next filing, for April to September 2026, is due on 31 October 2026.

1. The source of the duty is an order, not a section

Section 405(1) lets the Central Government, by order, require companies generally, a class of companies or any company to furnish information about their constitution or working within a time the order specifies. Under section 405(2) the order is published in the Gazette, and the publication date is treated as the date the requirement is made. Section 405(3) allows the Government to call for records or further information to test whether what was filed is correct and complete.

MSME-1 rests on the Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019, dated 22 January 2019. The order applies to companies that obtain goods or services from micro and small enterprises and whose payments to them run beyond 45 days from acceptance or deemed acceptance. Medium enterprises are outside the order.

2. What is reportable

The return lists the supplier’s name and PAN, the amount due, the date from which it is due and the reasons for the delay. The trigger is the 45-day mark, which is different from the 15-day default in section 15. A company that pays a supplier on day 30 with no written agreement has breached section 15 but has nothing to report here.

3. The October 2026 cycle: a working calendar

The statutory dates are 31 October for the April–September period and 30 April for the October–March period. The internal dates in the middle column are suggestions, working back from the deadline.

4. Where filings go wrong

•      The vendor master has no MSE flag, so a qualifying supplier is never extracted.

•      Acceptance dates are replaced by invoice dates, which shifts the 45-day count.

•      The reasons for delay are generic. A reason such as “disputed quality” should be supported by the written objection on file.

•      The return is prepared from a spreadsheet that differs from the ledger or from the section 22 note in the accounts (Article 6).

5. Consequences of default

Section 405(4), as substituted by the Companies (Amendment) Act, 2020 with effect from 21 December 2020, provides a monetary penalty for failing to comply with an order or for knowingly furnishing information that is incorrect or incomplete in a material respect. It reaches the company and officers in default. The amount should be read from the current text of the sub-section rather than from summaries.

6. An open point: dues settled inside the half-year

Commentary is not uniform on whether an amount that crossed 45 days but was paid before the half-year ended must be reported. The order refers to payments exceeding 45 days, while the current e-form’s fields and instructions drive what the portal accepts. Read the instruction kit for the version on the MCA portal and decide the treatment once, in writing, rather than half-year by half-year.