A customer has stopped paying. What the filings tell you about whether they can

The invoice went out in April. It is now September. You have had four “next week”s, one “the client hasn’t paid us either”, and last month, a partial transfer that felt more like a gesture than a payment.

You are trying to decide one thing, and it is not whether they owe you. It is whether they can pay you, or whether you are near the front of a queue that is about to get much longer.

The register will not tell you what is in their bank account. Nothing public will. But it answers a narrower and surprisingly useful version of the question: has this company been getting weaker, has it stopped doing the things a functioning company does, and is there somebody standing ahead of you in the queue.

Here is how to read it, cheapest checks first.

You are not imagining the scale of this

India’s Ministry of MSME runs a delayed-payment portal, Samadhaan, where a micro or small enterprise can file against a buyer who has not paid. The homepage is a dashboard of live counters with no as-on date, and it shows two different totals. Read on 14 September 2026:

The first counter, applications filed by micro and small enterprises, was 2,56,892. The same page now tells suppliers to file new applications at a different portal, the MSME ODR portal. Treat that 2,56,892 as a stock of applications, not a live flow.

A second set of tiles counts cases at Micro and Small Enterprise Facilitation Councils: 1,12,691 cases filed, ₹31,672.96 crore recorded as payable, 65,528 of those cases disposed. That is not a subset of 2,56,892, and it is not a total you can add to it.

Both count only the disputes somebody formalised. Whatever the true number of unpaid invoices is, it is larger.

The point is not to make you feel better. It is that the decision you are making right now, keep supplying or stop, escalate or settle, is one that a few hundred thousand suppliers make badly every year because they make it blind.

Check one: are they still a company at all

Free, thirty seconds, and it is the check that occasionally ends the conversation.

Look up the company’s status on the MCA master data search. If it comes back Strike Off or Under process of striking off, the entity you have been invoicing has been removed from the register or is being removed. That is not a payment problem, it is an existence problem, and it changes who you chase and how.

This is not exotic. In our snapshot of the register taken on 8 September 2026, more than one in four entities carried a strike-off status, which we have written up in full in how many companies in India actually still exist.

Other statuses that should stop you where you stand: Under Liquidation, which means a liquidator now controls the assets, and Under CIRP, which means an insolvency resolution process has begun and a moratorium applies to recovery action against the company. We cover what every status means separately.

And check you have the right entity while you are there. If you have never looked a company up before, start with the two-minute check on whether a company is real and come back here. Group companies with near-identical names are extremely common, and the invoice, the purchase order and the bank account do not always name the same one. Confirm by CIN, not by name.

Check two: who is ahead of you in the queue

This is the check almost nobody does, and it is the one that most changes what you should do.

On the MCA portal, under Master Data, there is a separate item called View Index of Charges. It is free. It lists every charge registered over the company’s assets: the lender, the amount secured, the date, and whether the charge has been satisfied.

A charge is a lender’s registered claim over the company’s property. If a bank lent against the company’s plant, receivables or stock and registered that charge, then in a wind-up that bank is a secured creditor. You, holding an unpaid invoice, are an unsecured one. Secured comes first.

So the index of charges answers a question you cannot ask anyone directly: if this company runs out of money, how much of what it owns is already spoken for?

Three patterns worth knowing how to read:

No charges at all. The company has not borrowed against its assets, or has not borrowed from anyone who registers charges. On its own this is mildly reassuring, and it also means there may be less collateral supporting the business than you assumed.

Several open charges, none recent. Ordinary secured borrowing. Note the amounts against what you know of the company’s size.

A new charge created recently, or several in quick succession. A company that has been pledging assets in the same months it stopped paying you is a company raising money against what it owns. That is a signal, and it is a signal you can see for nothing.

One caution, and it matters. A charge stays on the register until the company files to say it has been satisfied. Old, fully repaid loans routinely sit there for years because nobody filed the form. So an open charge is not proof of a live debt. It is proof of a claim that was registered and never formally released.

Check three: have they stopped filing

Every company has to file its financial statements and its annual return each year. Form AOC-4 carries the accounts, Form MGT-7 the annual return. Both hang off the annual general meeting, which for most companies has to happen by 30 September.

Late filing is not free. Under the Companies (Registration Offices and Fees) Second Amendment Rules 2018, notified on 7 May 2018, an overdue annual filing attracts an additional fee of ₹100 per day, charged separately for the annual return and the financial statements, wherever the filing period expired after 30 June 2018. It does not stop accruing and there is no cap.

Which is why a filing gap is such a loud signal. A company that has not filed for two years is not being forgetful. It is watching a meter run, and it either cannot produce accounts, cannot afford the auditor, or has stopped caring because there is nothing left to protect.

What to look for, in order of severity:

What you see	How to read it
Filed on time, every year	Boring. Boring is good
Filed late, but filed	Slow, disorganised, or short of cash at year end
Last year missing, this year not due yet	Watch it. Not yet a finding
Two or more consecutive years missing	The company has stopped doing what functioning companies do
Filings stop and directors start resigning	The two together are worse than either alone

That last row is the one to take seriously. Director changes are filed separately, and a cluster of resignations in the same window that the filings stopped is a different story from either on its own.

Check four: the direction of travel

Everything so far is free. This one is not, and it is usually where the ₹100 goes.

The accounts attached to the AOC-4 give you turnover, profit or loss, and the balance sheet, for each year the company filed. One year tells you very little. Three years tells you the direction, and direction is what you are actually after.

Read them in this order:

1. Revenue, year on year. Falling revenue with rising trade payables is a company paying its suppliers later because it has less coming in.
2. Trade payables. If the figure is climbing while revenue is flat, you are not being singled out. Everyone is being paid late.
3. Borrowings, read against the index of charges. Debt going up while revenue goes down is the shape you least want to see.
4. The auditor’s report. Auditors are careful people who occasionally say something plain. A going-concern remark is not a formality.

We have written separately on how to find a private company’s revenue, and on getting the documents out of the portal, which is fiddlier than it should be.

Bear in mind what you are reading. Accounts filed in January 2026 describe the year that ended in March 2025. By the time you read them they describe a company that existed eighteen months ago. They are a direction, not a snapshot.

What the register absolutely will not tell you

This is the part that most posts on this subject skip, and skipping it is how people talk themselves into false confidence.

It will not tell you whether they can pay you this month. There is no cash position in a public filing. A company with good accounts can be out of money by Tuesday.

It will not tell you whether they are paying other people. A supplier who is being paid and one who is not look identical from outside.

It will not tell you about disputes, GST defaults or bounced cheques. None of that is in the MCA record.

It will not tell you the truth, only what was filed. The register holds filings. Filings lag, filings can be wrong, and a company in trouble is not usually the one filing promptly.

And it does not tell you what to do. Nothing here is legal advice, and the right move in a real dispute depends on your contract, your evidence and your appetite, none of which are on the register.

What the register does give you is calibration. You go from “I have a bad feeling” to “this company has not filed for two years, has three open charges, and lost two directors in the spring”. That is a different conversation, both with yourself and with them.

What the filings change about your options

Broadly, four moves, and the filings push you towards one of them.

Keep supplying, on tighter terms. Defensible if the company is filing, the accounts are stable, and the delay looks like working-capital pressure rather than collapse. Shorten terms, take advances, cap exposure.

Stop supplying, keep talking. The usual answer when the filings have gone quiet but nothing formal has happened. You stop adding to the exposure without turning it into a fight.

Escalate. If you are a micro or small enterprise, delayed payment under the MSMED Act is still the low-cost formal route, and the substantive law behind it is worth knowing about. New applications are now directed to the MSME ODR portal rather than to Samadhaan itself. Section 15 of the MSMED Act 2006 requires the buyer to pay by the date agreed in writing, and caps that agreed period: “in no case the period agreed upon between the supplier and the buyer in writing shall exceed forty-five days from the day of acceptance”. Where there is no written agreement at all, payment is due on the “appointed day”, which section 2(b) puts at fifteen days after acceptance. Note which way round that runs: forty-five days is a ceiling on what can be agreed, not an entitlement every buyer has.

If the buyer is a company, the overdue amount may already be on the public record in its own words. Twice a year it has to name its micro and small suppliers and the sums outstanding past 45 days, in the filing where your buyer says what it owes you.

Section 16 then does the work. Interest on a delayed payment is compound, with monthly rests, “at three times of the bank rate notified by the Reserve Bank”, and it applies “notwithstanding anything contained in any agreement between the buyer and the supplier or in any law for the time being in force”. The contract cannot bargain it away.

The protection is not universal: Chapter V runs in favour of a “supplier”, which section 2(n) confines to micro and small enterprises. A medium enterprise is outside it. That is a real lever and many suppliers never mention it.

The insolvency route has a floor. The Central Government fixed the minimum default at one crore rupees by notification S.O. 1205(E) dated 24 March 2020, under the proviso to section 4 of the Insolvency and Bankruptcy Code 2016. Section 4 sets the threshold for the whole of Part II, which is where an operational creditor’s application lives, so below ₹1 crore the Code is not available to you whatever the merits. Above it, sections 8 and 9 set out the demand notice and application route.

One exception worth knowing if your debtor is small: a separate notification of 9 April 2021 sets ten lakh rupees as the threshold for the pre-packaged insolvency resolution process available to MSME corporate debtors.

Settle cheap and move on. Sometimes the filings tell you the queue is long, the assets are pledged, and forty paise in the rupee today beats a judgment in four years. That is not defeat, it is arithmetic, and you can only do the arithmetic if you have looked.

The order to do this in

1. Status and CIN. Free. Confirms the entity exists and is the one you invoiced.
2. Index of charges. Free. Tells you who ranks ahead of you.
3. Filing history. Whether the last two years were filed at all. This is visible before you pay for anything.
4. The accounts, three years of them. This is the paid step, and it is the one that converts a hunch into a direction.
5. Director changes over the same window. Cheap to add once you are pulling documents anyway.
6. Write down what you found, with the date. If this becomes a dispute, “the register showed no filings since 2024 when I checked on 11 September 2026” is worth having, and worth having with the document behind it.

If you want the whole set in one go rather than eight passes through the portal, that is what we do: what a full retrieval contains, and what it costs, registry fee included.

Whatever you decide, decide it having looked. The worst version of this situation is not the customer who cannot pay. It is the supplier who kept shipping for another two quarters because nobody spent ₹100 and twenty minutes finding out.

Written by the Entiva team, who read Indian company filings for a living. Not legal advice.