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Letter from the table · RC/CF/2026/T.51

Letter from the table: Do not turn 15 days into one rule for every invoice

Prakash Bhatia argues that India’s existing payment protections should be enforced rather than replaced by a universal 15-day deadline.

Prakash BhatiaCo-author · Cashflow Council · IndiaAhmedabad, India
Cashflow23 October 2026Opposes

Translated from Gujarati.

To the Cashflow Council

I am writing in English as a translation of what owners in my Gujarati-speaking community have been saying. I do not speak for every owner. I can tell you what I have heard repeatedly: we want to be paid on time, but we are not sure the proposed 15-Day Pay Standard understands the rules we already live under.

My own experience is not a story of an invoice lost for months. It is a story of how little room there is between a written payment term, a buyer’s payment process and the money needed to keep going.

On 4 April 2026, I sent an undisputed invoice for ₹1,18,000 to a large buyer. The buyer recorded acceptance on 8 April. Our written terms allowed payment within 45 days of acceptance. I sent a reminder on 12 May, then followed up again when the due period passed. The money arrived on 25 May. It was late against the agreed term, but the delay was measured in days, not months. During those days, I had to manage the gap from my own cash and arrange short-term credit.

I did not threaten the buyer or start a formal dispute. I kept the invoice, acceptance record and email trail together, and asked the accounts-payable desk for a payment date. I also checked what recourse was available to a registered micro or small enterprise. India’s MSMED Act gives a 15-day limit where there is no written payment agreement and permits a written term of up to 45 days. The law also provides for compound interest on delayed payment, at three times the RBI bank rate, and section 43B(h) affects when a buyer can claim a tax deduction for payment made beyond the statutory time limit.1

Those protections matter. But they do not put interest into my account automatically. A supplier still has to decide whether to pursue a claim, preserve the documents, and risk turning a buyer relationship into a formal dispute. A small owner may be legally entitled to money and still hesitate to press the claim while hoping for the next order. That is a weakness in enforcement, not proof that every invoice in every place should have the same 15-day deadline.

That is why I oppose CF-001 as drafted. A universal 15-day rule would be stricter than the written 45-day period Indian law currently allows for covered micro and small suppliers. It could make a buyer treat an otherwise valid 45-day agreement as unacceptable, or respond by making acceptance harder to establish. I worry most about the practical result: more arguments over whether an invoice is “undisputed,” or whether the clock has started, while the supplier has to keep chasing the money.

Some owners around me would welcome a firm 15-day term. Others say their buyers need a documented period that fits the way orders are checked and approved. The common request I hear is not “let buyers take as long as they like.” It is: do not make the supplier carry the burden of a rule that is impossible to enforce in the real relationship.

I support prompt payment, automatic calculation of interest where the law requires it, and publication of payment performance. I would support the Council asking buyers to disclose their terms and actual payment times, to acknowledge when an invoice is received, and to give a written reason when they dispute it. I would also support a standard that says the applicable local law governs where it gives the supplier stronger protection or allows a different written term. And I want the Council to press for practical routes to enforcement, including ways to raise a claim without a small supplier having to fear retaliation for doing so.

These are not arguments for weakening India’s protections. The 15-day default where there is no written agreement should mean something. The 45-day ceiling should mean something too. The problem is the distance between a right on paper and a right an owner feels safe using. A new standard should help close that distance, not replace local protections with one number that may fit some members and unsettle others.

The consultation closed on 24 September. As the Council considers the ballot, I ask you to record this as opposition to the draft as written—not opposition to paying small suppliers promptly. Please revise it so that local legal protections are respected, payment terms are visible, and late payment has consequences that a small supplier can realistically pursue.

Prakash Bhatia
Co-author · Cashflow Council
Ahmedabad, India

Notes and sources

Sources

  1. Legal500, India: Payments to micro and small enterprises—implications under section 43B(h)

Replies 5

Marek Zieliński Cologne, Germany · 24 October 2026

I understand your concern about replacing a legal framework with a single deadline. In Germany, I have learned that payment rules work best when people can tell plainly which term applies and what happens if it is missed. A universal 15-day period could be too blunt where a written agreement and local protections already set a different limit. But existing protections are not enough if suppliers cannot easily check whether a buyer has complied or pursue what is due. I would support the Council focusing on enforcement, clear disclosure of terms, and comparable reporting. How would you make that enforcement accessible to a small supplier without adding another costly procedure?

Pieter van Dijk Rotterdam, Netherlands · 27 October 2026

Your case is a useful reminder that a delay of days can still force a small firm to borrow. I would not dismiss the cash-flow cost just because the invoice was eventually paid or the delay was shorter than in other cases. From the Netherlands, I favour a strong default standard, but I agree that it should not erase protections already in place. Perhaps the Council could say that 15 days is a benchmark for prompt payment, while requiring every jurisdiction and buyer to disclose the rule that actually governs the invoice. That would make comparisons possible without pretending every legal system is identical. Would you accept that kind of public benchmark?

Marko Jovanović Montréal, Canada · 28 October 2026

I take your point that “15 days for every invoice” could flatten important differences in law and contract. In Canada, the rules can vary by province and sector, so I would be wary of presenting one number as if it automatically overrides every existing protection. Still, a shared standard could set a minimum expectation for transparency: confirm receipt, record acceptance, flag a specific dispute, and tell the supplier when payment is scheduled. In your case, the agreed 45 days was clear, yet payment arrived late. I would like the Council to distinguish a legitimate longer term from simply missing the term that both parties already agreed to.

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