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MSME COMPLIANCE  • 2026-27

MSME COMPLIANCE  • 2026-27

India's MSMEs work under three compliance regimes at once: indirect tax (GST), employment law (now the four Labour Codes) and the MSME framework itself, which governs payment terms, registration and access to government credit. Each has its own calendar, and a missed date usually costs money in late fees, interest or lost tax deductions. This guide brings them together so that owners, finance teams and company secretaries can plan the year in one place.

Key numbers at a glance

  • • ₹10 crore: turnover ceiling for a micro enterprise
  • • 45 days: maximum payment period to micro and small suppliers
  • • 21 November 2025: the four Labour Codes came into force
  • • ₹10 crore: CGTMSE collateral-free guarantee ceiling

1. Who qualifies as an MSME

Since 1 April 2025, an enterprise is classified on both its investment in plant, machinery or equipment and its annual turnover. The same limits apply to manufacturing and services. If an enterprise crosses either limit, it moves to the next category.

CategoryInvestment in plant, machinery or equipmentAnnual turnover
MicroUp to ₹2.5 croreUp to ₹10 crore
SmallUp to ₹25 croreUp to ₹100 crore
MediumUp to ₹125 croreUp to ₹500 crore

Udyam Registration is the gateway
Registration on the Udyam portal is online, paperless and free, and is based on Aadhaar and PAN. Almost every central MSME benefit depends on it: the 45-day payment protection, CGTMSE guarantees, priority-sector lending, public procurement preferences and the MSME Samadhaan delayed-payment mechanism. Review your Udyam classification each year after your income-tax return and GST data update it.

2. GST compliance calendar for MSMEs

Most MSMEs with aggregate turnover up to ₹5 crore can choose the QRMP scheme (Quarterly Return, Monthly Payment): returns are filed quarterly, but tax is still paid every month. Businesses above ₹5 crore, or those that do not opt in, file monthly.

Monthly and quarterly returns

  • Return / form
  • Who files
  • Frequency
  • Due date
  • GSTR-7 / GSTR-8
  • TDS deductors / e-commerce operators (TCS)
  • Monthly
  • 10th
  • GSTR-1
  • Monthly filers (turnover above ₹5 crore, or not in QRMP)
  • Monthly
  • 11th
  • IFF (Invoice Furnishing Facility)
  • QRMP filers, for B2B invoices of months 1 and 2 (optional, up to ₹50 lakh a month)
  • Monthly
  • 13th
  • GSTR-1 (QRMP)
  • QRMP filers
  • Quarterly
  • 13th after quarter
  • GSTR-3B
  • Monthly filers
  • Monthly
  • 20th
  • PMT-06
  • QRMP filers, tax for months 1 and 2 of the quarter
  • Monthly
  • 25th
  • GSTR-3B (QRMP), Category X states
  • MH, GJ, KA, TN, TS, AP, KL, Goa, MP, CG, Puducherry, A&N, Lakshadweep, DNH & DD
  • Quarterly
  • 22nd after quarter
  • GSTR-3B (QRMP), Category Y states
  • All other states/UTs, including Haryana, Delhi, UP, Punjab, Rajasthan, Bihar, West Bengal
  • Quarterly
  • 24th after quarter
  • CMP-08
  • Composition taxpayers (tax payment statement)
  • Quarterly
  • 18th after quarter

Half-yearly and annual returns

  • Return / form
  • Who files
  • Due date
  • ITC-04 (job work)
  • Principals sending goods for job work. Turnover above ₹5 crore: half-yearly. Up to ₹5 crore: annually
  • 25 Oct & 25 Apr
  • GSTR-4
  • Composition taxpayers (annual return)
  • 30 June
  • GSTR-9
  • Regular taxpayers with turnover above ₹2 crore (FY 2025-26 return)
  • 31 Dec 2026
  • GSTR-9C
  • Self-certified reconciliation statement, turnover above ₹5 crore
  • 31 Dec 2026
  • CMP-02
  • Opting into the composition scheme for the next year
  • Before 1 April
  • QRMP option
  • Opting in or out of QRMP for a quarter
  • Last day of the quarter's first month

Key dates for the next six months

  • Date
  • Compliance
  • What it covers
  • 25 Oct 2026
  • ITC-04 (Apr–Sep)
  • Job-work return for businesses above ₹5 crore turnover
  • 31 Oct 2026
  • MSME-1 (Apr–Sep)
  • Companies report dues to micro and small suppliers pending over 45 days
  • 30 Nov 2026
  • Statutory bonus
  • Bonus for FY 2025-26, payable within eight months of year end
  • 31 Dec 2026
  • GSTR-9 / GSTR-9C
  • Annual return and reconciliation for FY 2025-26
  • 13 Jan 2027
  • GSTR-1 (Oct–Dec)
  • Quarterly outward-supply return for QRMP filers
  • 22 / 24 Jan 2027
  • GSTR-3B (Oct–Dec)
  • Quarterly summary return; date depends on your state

Late fees and interest

  • Default
  • Consequence
  • Late GSTR-1 / GSTR-3B
  • ₹50 per day (₹20 per day for nil returns). Maximum: ₹2,000 (turnover up to ₹1.5 crore), ₹5,000 (₹1.5–5 crore), ₹10,000 (above ₹5 crore); ₹500 for nil returns
  • Late GSTR-4
  • ₹50 per day, capped at ₹2,000 (₹500 for nil returns)
  • Late GSTR-9
  • ₹50 per day (turnover up to ₹5 crore), ₹100 per day (₹5–20 crore), ₹200 per day (above ₹20 crore), subject to turnover-linked caps
  • Late payment of tax
  • Interest at 18% a year on the net cash liability (Section 50(1), CGST Act)
  • ITC wrongly availed and utilised
  • Interest at 18% a year where ITC is wrongly availed and utilised (Section 50(3), as amended retrospectively by the Finance Act, 2022), plus penalty exposure under Section 122

3. GST changes MSMEs cannot ignore

  • Change
  • What it means for your business
  • Status
  • GSTR-3B hard-lock
  • From the July 2025 tax period, liability auto-filled from GSTR-1/IFF cannot be edited in GSTR-3B. Corrections must be made through GSTR-1A before filing GSTR-3B.
  • In force
  • Three-year time bar
  • A return cannot be filed once three years have passed from its due date. Old pending returns are now permanently barred, so clear backlogs immediately.
  • In force
  • GSTR-9 exemption
  • Taxpayers with turnover up to ₹2 crore are exempt from filing the annual return (Notification 15/2025-CT).
  • In force
  • GST rate rationalisation
  • Two main slabs of 5% and 18%, with 40% on specified goods. Review the classification and rate of every product and service you sell and buy.
  • In force
  • Simplified registration
  • Under the optional Rule 14A route, applicants whose self-assessed monthly output tax on supplies to registered persons will not exceed ₹2.5 lakh get registration within three working days (Notification 18/2025-CT).
  • From 1 Nov 2025
  • Faster refunds
  • 90% of refunds claimed on account of inverted duty structure can be sanctioned provisionally after a system risk check (CBIC Instruction 06/2025-GST), which helps working capital.
  • From 1 Oct 2025

4. The 45-day payment rule: protection for MSME suppliers

The MSMED Act, 2006 and the Income-tax law together create a strong incentive for buyers to pay micro and small suppliers on time. This matters to MSMEs on both sides of a transaction: as suppliers waiting for money, and as buyers purchasing from smaller vendors.

  • Provision
  • Rule
  • Section 15, MSMED Act
  • Pay within the agreed period, which can never exceed 45 days from acceptance. If there is no written agreement, pay within 15 days.
  • Section 16, MSMED Act
  • Late payment attracts compound interest with monthly rests at three times the RBI bank rate, whether or not the supplier claims it.
  • Section 23, MSMED Act
  • That interest is not deductible for income-tax purposes.
  • Section 43B(h), Income-tax Act, 1961 / Section 37(2)(g), Income-tax Act, 2025
  • Amounts owed to micro and small enterprises (manufacturing and services, not traders) that remain unpaid beyond the Section 15 limit are deductible only in the year they are actually paid. From tax year 2026-27 the same rule applies under Section 37(2)(g) of the Income-tax Act, 2025.
  • MSME-1 (companies)
  • Half-yearly return to the MCA of dues outstanding to micro and small suppliers beyond 45 days: by 31 October (April–September) and 30 April (October–March).
  • MSME Samadhaan
  • Micro and small suppliers can file delayed-payment claims online. They are referred to the state Micro and Small Enterprises Facilitation Council for conciliation and arbitration.

Watch out
Unlike other Section 43B items, paying before the income-tax return due date does not save the deduction. A contract with 60-day credit terms does not override the 45-day statutory ceiling. Ask vendors for their Udyam certificate, tag them in your accounting system, and run an ageing report before every quarter end.

5. Labour law compliance checklist under the four Labour Codes

The Code on Wages, the Industrial Relations Code, the Code on Social Security and the Occupational Safety, Health and Working Conditions (OSH) Code came into force on 21 November 2025, replacing 29 central labour laws. The Central Rules under all four Codes were notified on 8–9 May 2026. Labour is a concurrent subject, so state rules also apply; several states, including Haryana and Delhi, had not notified final rules as of October 2026. Existing registrations and the old state rules continue during the transition.

Applicability thresholds at a glance

  • Obligation
  • Applies when
  • Change
  • Appointment letter
  • Every employee
  • New
  • Minimum wage and timely payment
  • Every employee, in every sector
  • Universal
  • ESIC
  • 10 or more employees (voluntary below 10; mandatory for hazardous work)
  • Pan-India
  • EPF
  • 20 or more employees
  • Unchanged
  • Grievance Redressal Committee
  • 20 or more workers
  • Unchanged
  • Factory (OSH Code)
  • 20 workers with power / 40 without power
  • Was 10 / 20
  • Contract labour licence
  • 50 or more contract workers
  • Was 20
  • Crèche
  • 50 or more employees
  • Unchanged
  • Works Committee
  • 100 or more workers
  • Unchanged
  • Standing orders; prior permission for lay-off, retrenchment, closure
  • 300 or more workers
  • Was 100
  • POSH Internal Committee
  • 10 or more employees (POSH Act, 2013)
  • Unchanged

The MSME checklist

Wages and pay structure

• Restructure salaries so that basic pay, DA and retaining allowance are at least 50% of total pay. Excluded allowances above 50% are added back to "wages" for PF, gratuity and bonus.

• Pay monthly wages by the 7th of the next month.

• Settle full and final dues within two working days of exit.

• Pay overtime at twice the ordinary rate, with the worker's consent.

• Pay statutory bonus of 8.33%–20% to eligible employees (wages up to ₹21,000 a month).

Employment documents

• Issue appointment letters in the prescribed format to every employee, including existing staff.

• Put fixed-term contracts on parity with permanent staff; gratuity is payable after one year of service.

• Adopt model standing orders or update HR policies on leave, working hours (48 hours a week) and discipline.

• Record written consent and safety arrangements before women work night shifts.

Social security

• The EPF wage ceiling has been raised from ₹15,000 to ₹25,000 a month, effective 17 September 2026. Enrol newly covered employees.

• Deposit PF and ESI contributions by the 15th of each month.

• Recompute gratuity provisions on the new wage base.

• Haryana: deposit Labour Welfare Fund (employee 0.2% up to ₹35 a month; employer twice that).

Registration, records and safety

• Check whether a single registration under the OSH Code is needed; existing registrations continue in the transition.

• Keep registers electronically and prepare for a single annual return.

• Constitute the Grievance Redressal Committee (20+ workers), with women in proportion to the workforce.

• Arrange free annual health check-ups where prescribed, and maintain safety measures.

Enforcement is softer, but not optional
Inspectors are now "Inspector-cum-Facilitators", and inspections are risk-based and digital. Many first-time offences can be compounded, and improvement notices give time to fix lapses. But the wage, PF and ESI exposure from a wrong pay structure builds up month by month, so it is better to fix it now than at the time of an inspection or dispute.

6. Monthly payroll compliance calendar

  • Due date
  • Compliance
  • Law
  • 7th
  • Pay previous month's wages; deposit TDS on salaries (TDS for March is due by 30 April)
  • Code on Wages; Income-tax law
  • 15th
  • EPF contribution and ECR filing
  • EPF Act / Code on Social Security
  • 15th
  • ESI contribution (3.25% employer + 0.75% employee)
  • ESI Act / Code on Social Security
  • As notified by state
  • Professional tax and Labour Welfare Fund
  • State laws
  • Within 2 working days
  • Full and final settlement on exit
  • Code on Wages
  • 30 Nov (annual)
  • Statutory bonus for the previous financial year
  • Code on Wages

7. Government schemes for MSMEs

Government support for MSMEs is mainly about credit: guarantees that replace collateral, subsidised loans for new units, and faster payment of receivables. Most schemes require Udyam registration and are accessed through banks, NBFCs or the scheme's own portal.

Credit and finance

  • Scheme
  • Who it helps
  • Key benefit
  • CGTMSE (Credit Guarantee Fund Trust for MSEs)
  • Micro and small enterprises, including retail and wholesale traders
  • Collateral-free loans with guarantee cover up to ₹10 crore (raised from ₹5 crore from 1 April 2025). Cover of 75%–85% depending on borrower category; annual fee as low as 0.37%.
  • Mutual Credit Guarantee Scheme (MCGS-MSME)
  • MSMEs buying plant and machinery
  • 60% guarantee on loans up to ₹100 crore, where equipment is at least 75% of project cost.
  • PM MUDRA Yojana
  • Non-farm micro businesses
  • Collateral-free loans: Shishu (up to ₹50,000), Kishore (up to ₹5 lakh), Tarun (up to ₹10 lakh), Tarun Plus (up to ₹20 lakh, for those who have repaid a Tarun loan).
  • PMEGP
  • New manufacturing and service units
  • Margin-money subsidy of 15%–35% on projects up to ₹50 lakh (manufacturing) and ₹20 lakh (services). The scheme was approved up to 31 March 2026; a five-year extension was still under consideration as of October 2026 and fresh subsidy releases are on hold. Check the KVIC portal before applying.
  • Stand-Up India
  • SC/ST and women entrepreneurs, greenfield projects
  • Bank loans from ₹10 lakh to ₹1 crore.
  • PM Vishwakarma
  • Artisans in 18 traditional trades
  • Loans up to ₹3 lakh at 5% interest, ₹15,000 toolkit support and paid skill training.
  • MSME credit card
  • Udyam-registered micro enterprises
  • Customised credit card with a limit of up to ₹5 lakh (announced in Budget 2025-26).

Growth, payments and market access

  • Scheme / measure
  • Key benefit
  • TReDS (invoice discounting)
  • Sell receivables from large buyers online. Budget 2026-27 proposes making TReDS the mandatory settlement platform for purchases by central public sector enterprises from MSMEs, CGTMSE cover for TReDS invoice discounting, and integration with GeM.
  • SME Growth Fund (Budget 2026-27)
  • New ₹10,000 crore equity fund to help high-potential SMEs scale. The Self-Reliant India Fund gets an additional ₹2,000 crore.
  • "Corporate Mitras" (Budget 2026-27)
  • ICAI, ICSI and ICMAI to train accredited professionals, especially in Tier-II and Tier-III towns, to help MSMEs meet compliance at lower cost.
  • Public procurement and GeM
  • Central ministries and CPSEs must source at least 25% of annual procurement from micro and small enterprises. Udyam-registered units can list on GeM.
  • ZED Certification
  • Bronze, Silver and Gold quality certifications with cost support; 100% cost support for women-led MSMEs.
  • Courier exports (Budget 2026-27)
  • Removal of the ₹10 lakh per-consignment limit on courier exports, to help small e-commerce exporters.

8. Our recommended action plan

1. Update your Udyam registration and confirm your current category under the revised limits.

2. Build one compliance calendar that combines GST, payroll, MCA and state labour dates, with a named owner for each.

3. Reconcile before you file. Match GSTR-1, GSTR-2B and books every month, and correct errors through GSTR-1A before GSTR-3B locks.

4. Audit your pay structure against the 50% wage rule and the new ₹25,000 EPF ceiling, and issue appointment letters to every employee.

5. Tag MSME vendors and track 45-day ageing to protect tax deductions and file MSME-1 on time.

6. Map the schemes you qualify for, especially CGTMSE, MUDRA and TReDS, before your next borrowing or capex decision.

Need help with MSME compliance?
Insight Juris LLP advises MSMEs on GST, labour code transition, corporate compliance and access to government schemes.

Key references: CGST Act, 2017 and CGST Rules, 2017 (Rules 14A, 59, 61, 61A, 62); Notification Nos. 15/2025 and 18/2025-Central Tax; CBIC Instruction No. 06/2025-GST; GSTN advisories on GSTR-3B hard-locking and the three-year time bar; MSMED Act, 2006 (Sections 15, 16, 23); Income-tax Act, 1961, Section 43B(h) and Income-tax Act, 2025, Section 37(2)(g); Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order; the Code on Wages, 2019, Industrial Relations Code, 2020, Code on Social Security, 2020 and OSH Code, 2020 and the Central Rules, 2026; Union Budget 2025-26 and 2026-27; Ministry of MSME scheme guidelines. Information is current as of 15 October 2026.

Disclaimer

This article is for general informational and educational purposes only and does not constitute legal, tax or financial advice. Laws, deadlines and scheme guidelines may change; readers should verify the latest position through official sources before acting.

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