September Chair’s Letter: From Evidence to the Next Decision

Letter from the Chair — 27 September 2026

Dear members,

This month we reached an important handover point. On 24 September, the public consultation on the draft 15-Day Pay Standard closed, with 362 comments received. That is not the end of the work. It is the point at which we must account for what people told us, make clear what the draft does and does not say, and prepare the proposal for the Assembly’s decision.

On the same day, the Cashflow Council sent a letter to the European Commission’s Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, urging agreement on the proposed Late Payment Regulation. The proposal’s progress has stalled in the Council. We have asked for a workable outcome that gives small suppliers a clear payment deadline, rather than leaving them to carry the cost of delay. The EU proposal is distinct from our own 15-day standard: it is a legislative process, while CF-001 is a proposed practice standard for large buyers and small suppliers.¹

Across Reseated, the Fair Play Council passed its pattern test on 8 September. That is a step in the Assembly’s wider work, but our attention in Cashflow remains on turning a well-evidenced problem into a clear, usable standard.

The numbers behind the work

As of 27 September, Reseated had 1,609 seated members in 49 countries and had received 4,925 reports from 50 countries. Cashflow accounts for 1,286 reports, submitted by 386 council members across 49 countries. The reports show the scale and spread of the issue; they are not a census of every small business or every buyer.

The median amount at stake in Cashflow reports is approximately US$4,296. In 1,042 reports, the situation is a client paying late; 244 concern supplier terms. In the last 30 days alone, members filed 152 reports. The pattern is not limited to a single market or one kind of business. The countries with the most Cashflow reports are Canada (166), the United States (157), the United Kingdom (133), India (102), Spain (55), Australia (55), South Africa (53), and Italy (49).

Our members’ businesses are small in very different ways. Among reporting Cashflow members, 37% work alone, 42% have teams of 2–9, 16% have teams of 10–49, and 5% have teams of 50–249. A delay that might look minor in a large buyer’s payment system can mean a missed supplier payment or a difficult decision about wages in a small firm. International estimates underline why this matters: MSMEs make up about 90% of businesses worldwide and account for roughly 60–70% of employment; the ILO also estimates that around 80% of MSMEs operate in the informal economy.^[2][3]

One account from the evidence

One member’s account makes the mechanics plain. The member had completed agreed work for a larger buyer and submitted an invoice. There was no dispute about the work or the amount. The invoice was moved to a later payment run, and then moved again. While waiting, the member had to review which of their own bills could be delayed and contact a supplier to ask for more time. The buyer’s process treated the delay as routine; for the small supplier, it meant managing a cash gap created after the work was already done.

We do not need to identify the member, their business, or the buyer to understand the issue. The proposed standard is intended to address precisely this kind of undisputed invoice: payment within 15 days, automatic interest when payment is late, and publication of payment times. The details matter. A standard must be clear about when an invoice is considered undisputed and must not let repeated internal processing steps quietly extend the clock.

What we learned—and what we still need to do

The reporting pattern gives us a firm basis for action: most Cashflow reports concern a client paying late, the amounts at stake are material to the businesses involved, and new reports continue to arrive. But evidence of a pattern does not mean every account is identical. Members face different contract terms, local rules, and routes to challenge a late payment. A useful standard must be simple enough to apply across those settings without pretending that one remedy replaces every national law.

The consultation closing with 362 comments is a responsibility, not a victory lap. We must distinguish support for the aim from suggestions about implementation, and we must not treat the number of comments as a vote. The Assembly ballot is the decision point. Before then, members should be able to see how the consultation has informed the text and where the final draft retains a firm requirement. We will carry that work forward through the established process: evidence, review, consultation, then a ballot.

There is also a wider lesson for buyers. A payment term written into a contract is not enough if the practical process allows undisputed invoices to wait without explanation. Timely payment, automatic consequences for delay, and published performance make the practice visible and give both sides a clearer basis for planning. This is why the proposal combines a deadline with interest and transparency.

What comes next

• From now through October, the Council will complete its review of the 362 consultation comments and prepare the material members need to assess the final proposal.

• The Assembly adoption ballot for CF-001 is scheduled to open on 26 October and close on 9 November 2026. Members will decide whether to adopt the 15-Day Pay Standard.

• After the ballot, the next steps depend on its result. If adopted, the Assembly’s process is to send letters to the chief executives who can adopt the standard and track each seat through the published stages. We will report those stages plainly; we will not imply a commitment where none has been made.

Thank you to Asha in Nairobi, David in Toronto, Lucía in Madrid, and Nikhil in Pune for choosing to be named in this month’s acknowledgment, and to every member who filed evidence, reviewed the draft, or took part in the consultation. Thank you as well to the members who remain anonymous. Your reports are treated as evidence, not as permission to expose you or your business.

Notes and sources

Sources

1. European Parliament Legislative Train — Late payments directive revision
2. United Nations — Micro-, Small and Medium-sized Enterprises Day
3. International Labour Organization — Micro, Small and Medium Enterprises