/ ROC Deadline Alert · Updated 2026-10-22
MSME Form I Half-Year October 2026, half-yearly return of MSE dues over 45 days.
Form MSME Form I half-yearly return for April-September 2026 period is due 29 November 2026. Mandatory for all companies with outstanding dues to Micro + Small Enterprise suppliers beyond 45 days as of 30 September 2026. Filed with ROC via MCA portal. Non-filing attracts Section 450 default penalty + Section 15 MSMED interest. Here's the compliance alert.
DC
Written by CA Durgesh Chavda
Chartered Accountant (ICAI) · Founder, Bharat Quantum Prospera · US incorporation, India-US DTAA, FEMA ODI, NRI taxation, cross-border structuring · LinkedIn
/ The core rule
Who must file + when.
- Form MSME Form I: half-yearly return of outstanding dues to Micro + Small Enterprise (MSE) suppliers that are over 45 days outstanding as of half-year end.
- Applicability: every company (not LLP, firm, individual) that has outstanding MSE supplier dues over 45 days.
- Half-year periods: April-September + October-March.
- Due dates: within 60 days of half-year end. So April-September 2026 period: due 29 November 2026. October-March 2027 period: due 29 May 2027.
- MCA Rules 2019: Specified Companies (Furnishing of Information about Payment to Micro and Small Enterprise Suppliers) Order 2019 under Section 405 Companies Act.
/ What goes in the return
The data points.
- Company CIN + PAN + registered office + applicable period.
- Each MSE supplier: PAN + Udyam number + total outstanding amount + aging bucket (46-60 days / 61-90 days / 91-180 days / 180+ days).
- Reason for delay (if specified).
- Interest payable under Section 15 MSMED (3x RBI bank rate compounded monthly).
/ Section 43B(h) interaction
The Income Tax trap.
- Section 43B(h) Income Tax Act disallows deduction for MSE expenses paid beyond 45 days. See our 43B(h) Year 2 guide.
- Form MSME Form I identifies the same universe of overdue payments.
- Tax auditor's Form 3CD Clause 22 cross-references MSME Form I data.
- Inconsistency between MSME Form I disclosure + Form 3CD disclosure attracts specific scrutiny.
/ Compliance checklist
What to do now.
- Compile list of MSE suppliers (verified via Udyam certificate).
- Extract outstanding dues as of 30 September 2026 - specifically those over 45 days from acceptance date.
- Age bucket analysis (46-60 / 61-90 / 91-180 / 180+ days).
- Compute Section 15 MSMED interest at 3x RBI bank rate compounded monthly.
- Reason-for-delay documentation.
- Reconcile with Section 43B(h) tax audit disclosure (Form 3CD Clause 22).
- File MSME Form I by 29 November 2026 via MCA v3 portal.
- Pay MSE suppliers before year-end 31 March 2027 to minimise Section 43B(h) disallowance.
Last updated: 2026-10-22.
/ Ready when you are
MSME Form I due 29 November 2026. 38 days left.
MSE supplier aging + Section 15 interest + MCA v3 portal filing. BQP integrated compliance: MSME Form I + Section 43B(h) + Form 3CD.
FAQ
Common questions, answered.
When is MSME Form I due for April-September 2026?
29 November 2026 - within 60 days of half-year end (30 September 2026). For October-March 2027 period: 29 May 2027. Form filed via MCA v3 portal under Specified Companies (Furnishing of Information) Order 2019.
Which companies must file MSME Form I?
Every company (Pvt Ltd / Public Ltd) with outstanding dues to Micro + Small Enterprise suppliers beyond 45 days as of half-year end. LLPs, firms, individuals NOT in scope. Based on acceptance date of goods/services + 45-day MSMED Act 2006 payment window.
Does MSME Form I apply if we always pay MSE suppliers on time?
If no MSE dues outstanding beyond 45 days at half-year end: no filing obligation. However, some practitioners file 'nil' return for compliance signal. Prudent approach: file nil return + maintain audit trail of all MSE invoice payments.
What's the penalty for not filing MSME Form I?
Section 450 Companies Act default penalty: up to INR 10,000 for first default + INR 1,000 per day of continuing default. Also Section 450 for every officer in default. More materially: inconsistency with Section 43B(h) tax audit disclosure attracts tax officer scrutiny.
How is MSE supplier identified for MSME Form I?
Via Udyam certificate - supplier's Udyam Registration Number specifies category (Micro / Small / Medium). MSME Form I covers only Micro + Small. Medium Enterprises are NOT in scope (same as Section 43B(h)). Collecting Udyam certificate at supplier onboarding is foundational compliance.
Does BQP handle MSME Form I + 43B(h) coordinated compliance?
Yes - standard. MSE supplier identification + Udyam verification + 45-day aging + Section 15 interest computation + MSME Form I filing + Section 43B(h) Form 3CD disclosure reconciliation + year-end payment prioritisation to preserve current-year deduction. Standard engagement for mid-size + large companies. WhatsApp +91 78018 87130.
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