The MSME payment clock starts before the payment run.

Which date did your ageing report use?

Look at one supplier bill waiting for approval. The invoice date is recorded. The receipt date may be in stores. A quality objection may be in someone's inbox. The payment run has its own date. Before you count days, decide which facts the applicable rule needs.

I would not start by adding a deadline formula to every vendor tagged MSME. The delayed-payment provisions concern relevant micro and small suppliers, with definitions and eligibility that need checking. A broad label in the master is not the whole legal analysis.

The official MSMED Act text sets out “appointed day” and acceptance/deemed-acceptance definitions in Section 2, and payment obligations in Section 15. Read those together. A slogan about 45 days misses the question of when and how the clock starts.

This article is a records guide for the AP desk, not a determination of every supplier's eligibility or a tax computation. Current classification, registration facts and applicable law should be reviewed before the file is used for statutory action.

Start with status and the written terms

Obtain the supplier's relevant registration information through your agreed onboarding process. The official Udyam portal is the reference point, not a logo pasted onto a quotation. Keep the evidence and the date of your check.

Match it to the legal supplier, not merely a similar trading name. A parent, branch or related concern might appear in correspondence. The account being paid should be connected to the supplier whose status you reviewed.

Then locate the written payment terms. Section 15 addresses the agreed written date and limits the agreed period to 45 days from acceptance or deemed acceptance. Where there is no agreement, it refers to the appointed day, defined by reference to a fifteen-day period. Have the precise application reviewed; do not turn this paragraph into an automatic calendar formula.

An internal vendor master saying 60 days does not make a statutory restriction disappear. Nor does a late invoice-approval timestamp automatically restart a clock that depends on other facts. Keep the commercial term visible so the reviewer can see the conflict.

The point is not to make AP guess which date is legally correct. It is to stop the relevant facts being lost before anyone can make that decision.

The acceptance trail belongs beside the bill

Record delivery or service completion evidence. For goods, the GRN is a useful reference, but don't assume every GRN is final quality acceptance. Your process may record receipt and inspection separately.

A genuine objection needs its own record. Keep what was rejected, when the issue was communicated in writing and what happened to resolve it. The Act's definition addresses written objections within the specified period; a vague “quality hold” entry made later does not explain that history.

Our quality-rejection guide separates receipt from acceptance as an operational control. For a statutory payment review, that separation needs documentary dates rather than a recollection of when someone looked at the material.

When purchase negotiates a replacement or credit, retain the correspondence. A supplier dispute can affect how the account is settled, but AP should not treat every disputed balance as automatically outside delayed-payment rules. Get the actual treatment reviewed.

The official Samadhaan FAQs explain the delayed-payment mechanism and some eligibility questions. They are useful context, not a substitute for applying the Act to your contract and facts.

Keep income tax and GST questions separate

There can be income-tax consequences as well as the MSMED payment obligation. The provision commonly referred to as Section 43B(h) has made this a familiar year-end question. Ask your CA which law and provision apply to the tax year being reviewed, including any successor provision.

Do not calculate that deduction treatment from a generic overdue tag. The statutory scope, supplier classification, payment facts and relevant accounting year need to be established. Use the Income Tax Department's current guidance and law, not an old screenshot.

The GST 180-day payment condition is another question. Its clock and treatment are not interchangeable with the micro/small supplier obligation. A single red cell called “tax overdue” conceals more than it explains.

Keep separate reviewer outcomes where necessary. The working file can share invoice and payment evidence, but it should not collapse distinct legal decisions into one status.

Give treasury a file it can act on

A practical review row contains the supplier identity, checked status, invoice reference, receipt/acceptance facts, written terms and the reviewed deadline. Add actual payment references and any unresolved dispute. Name the next owner rather than writing “pending” indefinitely.

Ask treasury to confirm the actual settlement, not just whether the payment was proposed. A payment run approval and a bank transfer are separate events. If the transfer failed or was split, retain that outcome.

When status evidence changes, keep the previous check and the effective facts. Replacing a master flag without history makes earlier review decisions hard to explain.

EntryLedger can supply an extracted, reviewed invoice record. It does not verify Udyam status, determine statutory acceptance, manage your payment run or calculate a tax deduction. Invoice validation is useful evidence about the bill, not a payment-compliance certificate.

Before the next Friday run, choose one relevant supplier and assemble the file from the original documents. If the deadline cannot be established without three phone calls, the missing control is not another reminder. It is the missing acceptance trail.

AP records guide, not personalised tax or legal advice. Official source wording checked on 12 October 2026. Have your CA or responsible adviser apply the effective law to your facts before a statutory payment decision or return adjustment.