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How to File a Delayed Payment Complaint Against a Buyer (MSME ODR Portal Guide, 2026)

How to File a Delayed Payment Complaint Against a Buyer (MSME ODR Portal Guide, 2026)

October 21, 2026

Short answer: if you run a micro or small business with a valid Udyam registration and a buyer has not paid you within the legal time limit, you can file a delayed payment complaint online, without going to court first, and claim compound interest on top of the unpaid amount. Since 15 October 2025, new complaints are filed on the MSME ODR portal (odr.msme.gov.in), not on the older MSME Samadhaan portal. This guide explains who can file, what to keep ready, the steps, and what to realistically expect.

This is general information, not legal advice. For a large claim or a disputed one, talk to a lawyer or your CA before you file.

MSME Samadhaan vs the MSME ODR portal

Many owners still search for “MSME Samadhan” and land on pages that describe the old process. Samadhaan was launched in 2017 as a delayed payment monitoring system: you filed there and the case went to your state’s Micro and Small Enterprises Facilitation Council (MSEFC). The Ministry of MSME then launched the ODR (Online Dispute Resolution) portal in June 2025. According to a Ministry of MSME letter dated 3 October 2025, as reproduced by TaxGuru, from 15 October 2025 all new delayed payment references are filed only on the ODR portal, and Samadhaan stays online only to track and migrate cases filed earlier. Someone who tries to file a new case on Samadhaan is redirected.

I could not open the ODR portal itself from here, so confirm the current filing screen when you log in. If you already have a pending Samadhaan case, you do not need to refile it.

Who can file

QuestionAnswer
Micro or small enterprise with valid Udyam registration?Yes, this is the basic requirement. Sole proprietorships, partnerships, LLPs and companies can all qualify if they are micro or small.
Medium enterprise?The delayed payment provisions of the MSMED Act protect micro and small suppliers. A medium business would normally need a civil suit or ordinary arbitration. A 2026 amendment bill is pending in Parliament but has not been passed, so do not count on it.
Trader?Unclear. The Act’s definition of “supplier” is generally read as covering manufacturing and service enterprises, and a law firm’s guide says trading-only units fall outside it. Take advice before relying on this route.
Udyam registered after the sale?Risky. A Supreme Court ruling, Silpi Industries v. Kerala SRTC (2021), as summarised by a law firm, held that registration must come before the contract or supply. Registering later does not give you earlier rights.

What counts as “delayed”: the 15 and 45 day rule

Section 15 of the MSMED Act, 2006 sets the clock. If you and the buyer agreed a payment date in writing, payment is due on that date. If there is no written agreement, payment is due within 15 days of the buyer accepting the goods or services. Even with an agreement, the period cannot exceed 45 days from acceptance. A 90-day credit clause in a purchase order does not override this.

How much interest you can claim

Under Section 16, a buyer who misses the deadline owes compound interest, with monthly rests, at three times the bank rate notified by the RBI. A third-party report puts the bank rate at 5.75% after the 7 October 2026 policy decision, which would make the interest rate 17.25% a year. I could not confirm that figure on the RBI site, so check the current bank rate on rbi.org.in before you calculate your claim.

As an illustration, on an unpaid ₹1,00,000 at 17.25% compounded monthly, three months of delay adds about ₹4,375 and twelve months about ₹18,681. That is my own arithmetic, so the portal’s calculation may differ slightly.

What to keep ready before you file

  • Udyam registration certificate (check its date against your invoices)
  • Purchase or work order, and any written payment agreement
  • Tax invoices showing dates and amounts
  • Delivery challans, e-way bills or proof that the work was completed and accepted
  • Emails, messages or letters in which you asked for payment, and any reply from the buyer
  • Bank statement showing the amount has not been received
  • A month-wise interest working at three times the bank rate

The portal’s exact upload list may differ from this one, which is based on law-firm guides, so follow the screen when you file.

What if there was no purchase order?

This is where many small suppliers get stuck. A buyer is in a hurry, promises to complete vendor registration later, and takes delivery on a phone call or a WhatsApp message. Months later the payment is held, and the buyer says there was no PO, so there was no order. The Act does not say a purchase order is mandatory. What the claim needs is proof of three things: that you supplied the goods or services, that the buyer accepted them, and on what date. A PO is only the easiest way to show that. Without one, you will have to prove it another way, and the portal may ask for more or take longer to process a thin file. I could not open the portal to see the form myself. One law-firm guide says the official FAQ asks for a work order or purchase order, and says that if the order was given orally you file an affidavit stating so, supported by emails, WhatsApp chats and accepted quotes. Other guides list a PO, work order or agreement as alternatives and do not say what happens when you have none. So the safe assumption is that a missing PO makes your file harder to get accepted, and that you should prepare an affidavit and strong substitute evidence. Check the live form before you file.

Evidence that can stand in for a PO:

  • Emails, WhatsApp messages or call records in which the buyer asked for the material or work, agreed the rate, or promised vendor registration
  • A delivery challan or gate pass signed and stamped by the buyer’s store or security
  • The tax invoice, e-way bill and transport receipt (lorry receipt), which show the goods reached the buyer
  • The buyer’s goods receipt note, inspection report, or any sign of use, such as the material being consumed in their production
  • Earlier invoices from the same buyer that they paid, which show a pattern of dealing
  • Any part-payment or acknowledgement of the amount due
  • A signed and notarised affidavit stating that the order was oral and describing what was supplied, when and on whose request (reported as required for oral orders; confirm the format with your state council)

The Act also has a rule on acceptance. As I understand Section 15, if the buyer does not object in writing within 15 days of delivery, the goods are treated as accepted. That is another reason to send a written demand, and to keep the date of delivery clear on your invoice and challan. A buyer who raises an objection will say the goods were not as ordered, which your documents must answer.

Be realistic. A claim backed only by your own invoice is weak, and the buyer can deny the supply or the terms, which turns a payment case into a dispute about facts. That slows things down and may need a lawyer. Also remember the Udyam registration rule above: the supply must come after your registration date, whatever the paperwork.

To avoid this next time, even when a buyer is in a hurry, get a one-line email or message before dispatch with the item, quantity, rate and payment term, and a signed delivery copy of the challan. Send the invoice the same day. These cost nothing and are often the difference between a clean claim and a disputed one.

How to file on the ODR portal, step by step

  1. Send the buyer a written demand first, quoting the invoice numbers, the due dates and the interest you will claim. It gives you a paper trail and sometimes it is enough.
  2. Register on odr.msme.gov.in as a complainant using your Udyam number, mobile number and email. Check that your name, PAN and contact details match.
  3. Start a new complaint and fill in the buyer’s name and address, invoice numbers, supply dates, agreed payment terms, the principal and the interest.
  4. Upload your documents as PDFs.
  5. Review and submit. The portal gives you a case reference number you can track from your dashboard.

What happens after you file

According to the Ministry’s description of the system, there are three stages:

  1. Online negotiation. Before the matter reaches the council, the buyer is notified and both sides can exchange offers on the portal. This stage is voluntary and either side can opt out.
  2. Conciliation by the MSEFC. If there is no settlement, your state’s council takes up the reference and tries to conciliate, with online meetings.
  3. Arbitration. If conciliation fails, the council arbitrates, or refers the matter to an arbitral institution, and passes an award.

The law expects the council to decide a reference within 90 days. A buyer who wants to challenge the award in court must first deposit 75% of the awarded amount (Section 19), and the award can be enforced like a court decree if the buyer still does not pay.

What it costs

I could not find an official fee schedule. A law firm’s guide says filing is free for micro and small enterprises, and a YourStory report says some businesses spent under ₹1,000 to file. If an outside arbitral institution is used, its fees may apply, and a lawyer will charge their own fees if you hire one.

How well does it actually work?

There are good examples. The Ministry’s press release describes a Mumbai engineering firm that recovered ₹21.06 lakh and a Kolkata chemicals firm that recovered about ₹5 lakh from a public sector buyer. But the system is new and results vary. YourStory reports that in Telangana more than 800 cases had been filed by August 2026 and about 85 had been resolved, with slow conciliation when the buyer contests the claim. Treat it as a cheaper and more structured route than court, not a guaranteed quick one.

Pressure that can work before you file

Section 43B(h) of the Income Tax Act can also give your buyer a reason to pay. As I understand it, a buyer can claim a tax deduction for purchases from a micro or small supplier only in the year the payment is actually made, if it is made after the 15 or 45 day limit. Ask your CA how this applies to your buyer before you mention it in a demand letter.

For the future, the Samadhaan page also asks MSMEs to onboard on a TReDS platform (RXIL, M1xchange or Invoicemart), where invoices can be financed before the buyer pays.

Sources: Ministry of MSME Samadhaan portal page; PIB release of 24 July 2026 on the national ODR framework; MSMED Act, 2006 summary on dcmsme.gov.in; TaxGuru’s reproduction of the Ministry letter dated 3 October 2025; YourStory (September 2026); Aran Law and Sansa Legal guides. Verified October 2026. I could not open odr.msme.gov.in directly, could not confirm the RBI bank rate on the RBI site, and could not find an official fee schedule or an official ruling on traders, so check those on the portal and with an advocate.

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