The MSME Form 1 half-yearly return due date for the half-year that ends this month — April to September 2026 — is 31 October 2026 (a Saturday). Form MSME-1 is the return through which a company tells the Registrar which of its micro and small enterprise suppliers it has not paid on time. It is easy to treat as one more MCA form. It is worth more attention than that, because the delay it records is the same delay that quietly moves a deduction out of this year’s tax computation and into a later one.
Two obligations sit on top of the same set of unpaid invoices, and most finance teams look at only one of them. This is the window to look at both before the filing date.
What the MSME Form 1 half-yearly return due date actually covers
Form MSME-1 exists under Section 405 of the Companies Act, 2013, read with the Specified Companies (Furnishing of Information about Payment to Micro and Small Enterprise Suppliers) Order, 2019, notified on 22 January 2019. It is filed twice a year, and each return covers a fixed half:
| Half-year period | Form MSME-1 due by |
|---|---|
| 1 April – 30 September | 31 October |
| 1 October – 31 March | 30 April |
So the return now approaching — for April to September 2026 — is due on 31 October 2026. What it discloses is not your whole vendor ledger. It is specifically the amount outstanding to a micro or small enterprise supplier, and the period for which it has stayed outstanding, where that amount has crossed the statutory payment window.
The trigger is not “we buy from small suppliers.” It is “we still owe a micro or small supplier, and the amount has been outstanding for more than 45 days from the date we accepted the goods or service.” No such balance on the reporting date, and there is nothing to report for that half.
Who has to file — and who your supplier has to be
The obligation is on the buyer: a company that has amounts payable to a supplier which is a registered micro or small enterprise. It reaches companies of every kind — private, public, large or small, and a One Person Company — because there is no turnover or size cut-off on the company that has to file. The size test sits on the supplier, not on you. Two limits are worth being precise about, because they are where filings go wrong:
First, it is micro and small only. Medium enterprises are outside the return — a due owed to a registered medium enterprise does not go into Form MSME-1. Second, the supplier’s status is what matters, not yours. You need to know which of your vendors actually hold a micro or small enterprise registration, because a supplier who has not registered, or who is a medium enterprise, sits outside this obligation even if the invoice is months old.
That is why the real work is not the form — it is the reconciliation behind it: taking your open payables and separating the micro and small enterprise suppliers from everyone else, then measuring how long each of those balances has been outstanding.
What “more than 45 days” actually means
The 45 days come from Section 15 of the MSMED Act, 2006. Where there is a written agreement, payment is due on the agreed date, but that date cannot be later than 45 days from the day of acceptance or deemed acceptance. Where there is no written agreement, the limit is 15 days. “Deemed acceptance” matters here: if you receive goods or a service and raise no written objection within 15 days, the law treats the delivery as accepted from that point, and the clock starts.
Count from acceptance, then, not from the invoice date or from when you happened to enter the bill — those are the dates teams reach for, and they are the wrong ones.
Why this half-year is different: the income-tax cost of a late MSME payment
Form MSME-1 is a disclosure. The consequence that has real money attached sits in the Income-tax Act. Since AY 2024-25, a sum a business owes to a micro or small enterprise, if it is not paid within the Section 15 time limit, is allowed as a deduction only in the year it is actually paid — not in the year the expense was booked. For a delay that runs across the year-end, that pushes the deduction into a later year and raises the tax payable in the year of the purchase.
This rule reaches micro and small enterprises registered under the MSMED Act; it does not apply to traders. It is the same 45-day (or 15-day) trigger as the MCA return — which is exactly why the two belong on one worklist. The half-year now closing feeds both the Form MSME-1 you file by 31 October and the year-end position that decides whether those deductions land in this year’s computation.
What to do before 31 October
Three steps clear most of the risk. Pull your open payables as at 30 September and identify which suppliers hold a micro or small enterprise registration — ask for it where you are not sure, rather than assuming. Age those balances from the date of acceptance and isolate anything past the Section 15 limit. Then report the qualifying dues in Form MSME-1 by 31 October, and where a balance is close to the line, decide deliberately whether to clear it now so the deduction is not deferred. Keep the working papers either way — a clean file that shows nothing was outstanding beyond the limit is itself the answer if the question is ever asked.