MSME Form 1 chase list for CA firms: April–September 2026 return due 31 October 2026
Short answer (checked 19 Oct 2026): The half-yearly MSME Form 1 for April–September 2026 is due on Saturday 31 October 2026. Under the 2019 Specified Companies Order made under section 405 of the Companies Act, 2013, as amended on 15 July 2024 (S.O. 2751(E)), only companies that have payments pending to a micro or small enterprise for more than 45 days from acceptance (or deemed acceptance) of the goods or services file it. The revised form is supplier-wise, by PAN, and it also asks for dues that were paid after 45 days during the half-year. So a company that cleared a late bill on 28 September may still have to file. Sources: the MCA MSME Form I page and the text of S.O. 2751(E). This is a starting point, not legal advice. Confirm on the MCA portal before you file.
What you get from this guide: a finished 10-day chase plan for your company clients, ending with MSME Form 1 filed by 31 October 2026. Sort every company client into one of three groups: no micro/small suppliers (nothing to file), micro/small suppliers but all paid within 45 days (no return; keep the working paper), and dues pending or paid after 45 days (file). The supplier-wise collect list, the four-column sheet the form expects, and short client scripts are below. Copy them into your own sheet.
The dates and rules you can rely on
| What | Who | Rule | Date |
|---|---|---|---|
| MSME Form 1, April–September 2026 | Companies with payments to micro or small enterprises pending over 45 days from acceptance or deemed acceptance | 2019 Order, para 3, proviso added by S.O. 2751(E), 15 Jul 2024 | 31 Oct 2026 (Sat) |
| MSME Form 1, October 2026–March 2027 | Same test, for the next half-year | Same Order | 30 Apr 2027 (Fri) |
| Who counts as a supplier | Micro and small enterprises only (medium enterprises are not reported) | MSMED Act 2006; Udyam classification | Status of each supplier on your list |
| The 45-day line | Days from acceptance or deemed acceptance of the goods or services | MSMED Act s.9 and s.15 (as referred to in the Order) | Count per invoice |
Two clocks, not one. Form 1 sorts dues at 45 days. The MSMED Act itself makes payment due on the agreed date, which can be at most 45 days, or within 15 days of acceptance where there is no written agreement (s.15). Interest under s.16 and the income-tax rule that delays the buyer's deduction for late payments to micro and small suppliers (s.43B(h) under the 1961 Act; check the matching provision for FY 2026-27 under the Income-tax Act, 2025) follow the Act's clock. A clean Form 1 does not prove the client paid on time. Our 45-day payment rule guide explains the supplier side.
Penalty: failure to furnish information under a section 405 order attracts penalties on the company and its officers in default under section 405(4). Check the current text of the section before you quote an amount to a client.
10-day chase plan (20–31 Oct 2026)
| When | Who | What to ask for or do | Tone tip |
|---|---|---|---|
| Tue 20 Oct | Every company client (private, public, OPC) | Ask for the creditors ageing as on 30 Sep 2026 and the list of suppliers flagged micro or small in the books. Note any client that has never collected Udyam status from suppliers. | One question: "Which of your suppliers are micro or small (Udyam registered)?" |
| By 22 Oct | Clients with no MSE flags in the ledger | Ask them to request Udyam certificates from their regular suppliers, at least the top 20 by purchase value. Record each answer (micro / small / medium / not registered). | Give them a ready one-line request to send (script below) |
| By 24 Oct | Clients with micro/small suppliers | Bill-wise data for Apr–Sep 2026: supplier name, PAN, invoice date, date of acceptance (or deemed acceptance), payment date and mode (TReDS or other), amount. | Ask for the Excel export, not PDFs |
| 25–26 Oct | Internal | Work out days from acceptance to payment for each bill. Put each client in its group: nothing to file / no return needed / must file. | Keep the working paper even when no return is needed |
| 27 Oct | Clients who must file | Send the draft supplier-wise table and ask for the reason for delay for each supplier. | Offer simple reason options: dispute on quality, pending documents, cash-flow, other |
| 28–29 Oct | Clients who must file | Take sign-off from the director, prepare the form on MCA V3 and get the DSC ready. | Check DSC expiry today, not on the 31st |
| By Fri 30 Oct | All filers | File MSME Form 1 for Apr–Sep 2026. 31 Oct is a Saturday, so do not plan on the last day. | Save the SRN and challan per client |
| 31 Oct | Internal only | Due date. Note the SRN, or the reason each pending client did not file. | Never file on presumed consent |
The four-column sheet the form expects (one row per supplier PAN)
| Supplier name | PAN | Paid within 45 days (TReDS / other) | Paid after 45 days | Outstanding ≤ 45 days | Outstanding > 45 days | Reason for delay |
|---|---|---|---|---|---|---|
| Supplier A | supplier PAN | count and ₹ | count and ₹ | count and ₹ | count and ₹ | short text |
The form also asks for the outstanding at the start of the period, the amount cleared, the amount added and the outstanding over 45 days at the end of the period. Build those four totals from the same sheet so they tie up. The MCA instruction kit allows one row per unique PAN; read it on the MCA page before you upload, since a filed return cannot simply be resubmitted.
Collect list for each company client
- Company name, CIN, financial year, whether it has any micro or small suppliers (Y/N)
- Creditors ageing as on 30 Sep 2026, bill-wise
- For each micro/small supplier: name, PAN, Udyam number and category, written payment terms (if any)
- For each bill in Apr–Sep 2026: invoice date, date of acceptance or deemed acceptance, payment date, mode (TReDS or other), amount
- Bills still unpaid on 30 Sep 2026 and their age in days
- Reason for delay per supplier (disputes, missing documents, cash-flow, other)
- Last MSME Form 1 filed (period and SRN), to carry forward the opening outstanding
- Director who will sign, DSC validity, owner on your team, draft sent date, sign-off date, SRN
Clients ask fewer "do we have to file this?" questions when the dates sit on a one-page calendar with your firm's name on it. Free national dates and a browser .ics builder: free CA due-date calendar tool.
WhatsApp / email script pack
First check: "Hello. The half-yearly MSME return for April to September 2026 is due on 31 October. Please send your creditors list as on 30 September, and tell us which suppliers are micro or small enterprises (Udyam registered), by [date]."
Supplier status request (for the client to forward): "Dear supplier, for our MSME compliance, please share your Udyam registration certificate, or confirm that you are not registered, by [date]. Thank you."
Bill-wise data: "For each micro or small supplier, please send the bills for April to September 2026 in Excel: invoice date, date you accepted the goods or service, payment date and amount. We need it by [date] to file before 31 October."
Reason for delay: "These [n] suppliers were paid, or are still unpaid, more than 45 days after acceptance. The return asks for a reason for each. Please choose one per supplier: quality dispute, documents pending, cash-flow, other (please say)."
Sign-off: "Your MSME return for April–September 2026 is ready. Summary attached. Please reply 'OK to file' and keep the director's DSC ready by [date], so we can file before 31 October."
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If you want branded quarterly packs
The White-Label Client Compliance Calendar for CA Firms (₹999/year) sends four quarterly packs with your firm name on the DOCX, PDF and WhatsApp image, plus national .ics/.xlsx and extension notes, so 31 October and 30 April are already on every client's page. Files are made after checkout (not instant). 14-day refund from when you receive the first pack. Disclosure: that is an Unadhi product. You can use this chase list without buying anything.
This guide is general information, not legal advice and not an official government publication. Orders, forms and dates can change by notification. Check the MCA portal and the current Order before you file or message clients. Your firm stays responsible for advice to your clients.
Sources to re-check
- MCA, MSME Form I (half-yearly return of outstanding payments to micro or small enterprises, pursuant to the Order of 22 January 2019 under section 405): mca.gov.in
- Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Amendment Order, 2024, S.O. 2751(E), 15 Jul 2024 (only companies with dues pending over 45 days file; revised form): ibclaw.in (text)
- Ministry of MSME, delayed payments and the MSME ODR portal: odr.msme.gov.in
- Related guides: ROC AOC-4 / MGT-7 chase list · Q2 TDS: collect before 31 Oct · MSME 45-day payment rule · what belongs on a white-label calendar
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