Engagement
MSME Form I Filing for Companies
Supplier data to filed return, every half-year.
Overview
Under section 405 of the Companies Act, 2013, companies are required to report payments due to micro and small enterprise suppliers. The Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019, dated 22 January 2019, prescribes a half-yearly return in MSME Form I: for April to September by 31 October, and for October to March by 30 April. Since MCA Notification S.O. 2751(E) dated 15 July 2024, the return is required only from companies that have payments pending to a micro or small enterprise for more than 45 days from the date of acceptance or deemed acceptance of the goods or services, which is the outer payment limit in section 15 of the Micro, Small and Medium Enterprises Development Act, 2006.
The revised form is supplier-wise. For each micro or small supplier it asks for the number and amount of payments made within 45 days, separately through TReDS and through other modes; payments made after 45 days; amounts outstanding for 45 days or less and for more than 45 days; and the reason for any delay. Medium enterprises are outside the return. A supplier's category follows its Udyam registration, under the limits revised with effect from 1 April 2025: investment up to ₹2.5 crore and turnover up to ₹10 crore for a micro enterprise, and up to ₹25 crore and ₹100 crore for a small enterprise.
The figures come from the company's books, so most of the work is reconciliation: confirming which suppliers hold a micro or small Udyam registration, fixing the acceptance date for each invoice, and ageing payments and balances against the 45-day limit. The firm shares a data sheet in the form's own format, reviews the finance team's working, prepares the return for the director's digital signature, files it, and keeps the working on record for the next half-year. Delayed payments also carry compound interest at three times the bank rate notified by the Reserve Bank of India under section 16 of the MSMED Act, which the review flags for the company and its auditors.
Key Deliverables
- Supplier-wise data sheet in the format of the revised MSME Form I
- Review of each supplier's Udyam classification as micro or small
- Ageing of payments and balances against the 45-day limit
- Preparation and filing of MSME Form I with the Registrar
- Record of the half-year working, including where no return is required
- Calendar for the 31 October and 30 April returns
Documents & E-Forms
- MSME Form I
- S.O. 2751(E)
- Sec. 405
- MSMED Sec. 15
- Udyam
When to Engage
In early October and early April, once the books for the half-year are closed, so that the supplier data can be checked before the due date.
Typical turnaround: Scoped in the engagement letter.
Download the MSME Form I data sheet (Excel)Frequently Asked
About this engagement