Opinion on CF‑001: The 15‑Day Pay Standard

To the members of the Cashflow Council

Who I am and what happened

My name is Harpreet Singh. I serve as Chair of the Cashflow Council, and I write from Manchester in the United Kingdom. I am writing in my capacity as a member and chair, not as a representative of any particular business. I will not name my business or describe what it does. The experience I can offer is the ordinary one shared by many small suppliers: work is completed, an invoice is issued, and the date when payment should arrive becomes uncertain.

That uncertainty is not just an accounting inconvenience. A small business must meet its own obligations while waiting: wages, rent, tax, supplier invoices and the costs of keeping work moving. When a larger buyer pays late, the smaller supplier may have little practical leverage. It may hesitate to ask questions, dispute a deduction or press for a clear date, because it worries that doing so will affect future work. A promise to pay is not the same as money available to run a business.

I do not suggest that every delay is deliberate, or that every buyer has the same systems or resources. Invoices can be unclear, goods or services can be disputed, and administrative errors do occur. That is why CF-001 is limited to undisputed invoices and why the standard is a proposed baseline, not a claim that every payment problem has one cause.

The Cashflow Council has gathered reports, tested whether the pattern is sufficiently consistent and widespread, drafted a response, and taken that response through public consultation. The draft 15-Day Pay Standard was published as RC/CF/2026/L.1 on 21 July. The consultation closed on 24

September after receiving 362 comments. The Assembly’s adoption ballot has not yet opened on the date of this letter. My purpose here is to set out the direction I believe the Council should recommend, and to make room for a serious disagreement before members cast their votes.

What the evidence shows

As of 18 October, Reseated had 1,733 members in 49 countries and had received 5,314 reports from 50 countries. The Cashflow Council had 419 members in 49 countries and 1,344 reports from 50 countries. The reports were not all from the same place or one kind of business. The countries with the highest report counts were Canada, 172; the United States, 166; the United Kingdom, 137; India, 103; South Africa, 58; Australia, 58; Spain, 57; and Italy, 51.

Within the Council’s reports, 1,089 described a client paying late and 255 described supplier terms. The distinction matters. A small supplier can face pressure both when a client delays payment for completed work and when the supplier itself is required to accept terms that stretch the time before it is paid. The reports describe different transactions, but share a practical consequence: the smaller party must carry the cost of time imposed by a more powerful counterparty.

The team-size figures also help explain why a uniform, predictable rule matters. Of reporting businesses, 37% were sole operators, 42% had 2–9 team members, 16% had 10–49, and 5% had 50–249. A delay can be difficult for a business of any size, but many respondents do not have a large finance department or spare capital to absorb a payment that arrives weeks late. The median amount at stake in the Cashflow Council reports was approximately US$4,296. That is not a measure of the full economic loss, and it should not be read as a typical invoice for every small business. It does show that the amounts at issue can be material to the firms reporting them.

There were 91 Cashflow reports filed in the 30 days before the 18 October data snapshot. A recent report count cannot by itself establish the scale of a problem; neither can an individual story. The Council’s case rests on the combined pattern: volume, frequency, consistency, spread and corroboration. The 1,344 reports are evidence supplied by members, not a census of all small businesses and not a finding against any particular buyer. Their value lies in the repeated shape of the difficulty across countries and business circumstances.

That distinction is important to me as chair. We should not turn the Council’s evidence into a general accusation that large buyers act in bad faith. We should also not dismiss a repeated pattern because each invoice dispute has its own facts. The evidence supports a practical standard that addresses the recurring imbalance without assuming that every delay is wrongful.

How the law in my country and elsewhere handles it

In the United Kingdom, the Late Payments Bill was introduced in the House of Lords on 19 May 2026. The provisions described in the available materials include a maximum payment term of 60 days, mandatory interest at 8% above the Bank of England base rate, and powers for the Small Business Commissioner to adjudicate and impose fines. Import and export contracts are exempt from the proposed cap.¹ This is a significant recognition that payment timing is a matter for public rules, not merely private bargaining. It is not, however, a 15-day standard, and the Bill’s introduction is not the same thing as its enactment.

In the European Union, the Commission proposed a Late Payment Regulation in September 2023, including a hard 30-day cap. The European Parliament adopted its position in April 2024, but the proposal has been blocked in the Council.² The continuing gap between a proposal and an agreed rule is a reminder that there is no single international timetable on which small suppliers can rely.

India has a different framework. Since 1 April 2024, section 15 of the Micro, Small and Medium Enterprises Development Act provides for payment to micro and small enterprises within 45 days where there is a written agreement, and within 15 days where there is no such agreement. Section 43B(h) of the Income-tax Act ties the deduction for qualifying payments to payment within the relevant period; the stated consequences also include compound interest at three times the Reserve Bank of India bank rate for delayed payment.³ This framework demonstrates that legislatures can connect payment obligations with consequences. Its terms and legal mechanisms are not identical to CF-001.

Australia’s Payment Times Reporting Scheme provides another kind of evidence. The regulator’s August 2026 update reports that 69.8% of small-business invoices were paid within 30 days, with an average payment time of 27.2 days, and identifies 96 “Fast Small Business Payers” paying within 20 days or less.⁴ Separately, the Australian Small Business and Family Enterprise Ombudsman reported that payment disputes represented approximately 26% of new managed cases in the June 2026 quarter.⁵ These figures do not prove that a 15-day rule would produce the same result everywhere. They do show that payment timing can be measured and reported, and that disputes over payment remain a real issue.

These cases are not a contest to identify one country’s law as the model for all others. Each framework has its own scope, institutions and enforcement choices. They show that governments have used payment caps, interest, reporting, adjudication, tax treatment and penalties in different combinations. CF-001 is a proposal from a global assembly, not a substitute for national law. Its purpose is to state a clear expectation that buyers can adopt and that members can advocate, while leaving public authorities to determine the legal instruments within their jurisdictions.

The strongest argument against my view and my answer

The strongest argument against CF-001 is that 15 days may be too short or too rigid. A buyer may have a large number of invoices, operations across several countries, different systems for checking delivery, or genuine questions about whether the invoiced work was completed as agreed. A smaller buyer may itself be waiting for funds. If a standard is designed without regard to those realities, it could add administrative costs, encourage rushed checks, or move cashflow pressure to another small business. Automatic interest could also be seen as punitive when a delay is caused by an honest error rather than a deliberate choice.

That argument deserves a respectful answer, not a dismissal. The proposal applies to undisputed invoices. A genuine dispute should be identified rather than concealed inside an indefinitely extended payment process. A clear standard can help both parties distinguish a specific problem with an invoice from a general delay in processing it. The draft also pairs a payment expectation with transparency about payment times; the purpose is not to shame buyers, but to make performance visible and comparable.

Nor do I believe that one standard can remove every risk of cashflow being shifted through a supply chain. That is a reason to implement the proposal carefully, explain it clearly and keep its effects under review. It is not a reason to accept an open-ended period in which the supplier finances the buyer without a clear, common expectation. The proposal can be a benchmark for adoption by buyers and a basis for discussion with lawmakers. Its adoption would not rewrite a country’s law or erase contractual and legal rights.

Automatic interest is the most contested part for some members and buyers. I support it because a payment deadline without a consequence can become only a request. Automatic interest makes the cost of lateness more predictable and reduces the need for a small supplier to make a separate, uncomfortable demand. The final standard should be clear about the trigger and the calculation, and it should not imply that every late payment is evidence of bad faith. A consequence can be proportionate and rule-based without being an accusation.

Some members may also prefer a 30-day or 45-day period because those figures appear in existing systems. I understand that preference. But CF-001 is intended to address the practical needs of small suppliers, not to reproduce the longest existing period. Fifteen days is a clear and demanding norm. If members conclude that the precise period should change, they should say so through the ballot and the formal process. I do not support weakening the principle that undisputed invoices should be paid promptly, and that payment performance should be visible.

My position clause by clause

I support the direction of CF-001 and ask members to consider the following position on its principal elements:

• “Large buyers pay small suppliers within 15 days of an undisputed invoice.”

  I support this clause. It sets a definite expectation and focuses on invoices for which no dispute has been raised. A prompt, stated deadline gives the supplier a date to plan around and the buyer a clear standard to meet. The word “undisputed” is essential: it recognizes that a real question about the invoice can arise, while preventing an unanswered or unexplained delay from being treated as if it were a dispute.

• “Automatic interest when late.”

  I support this clause. The payment obligation should not depend on whether a small supplier feels able to ask for interest. The standard should explain how interest is calculated and when it becomes due. Its purpose is to make timely payment the ordinary practice and to recognize that delayed access to money has a cost. It should be applied under the relevant law and should not be presented as a judgment about a buyer’s motives.

• “Publish payment times.”

  I support publication of payment-time information. Buyers, suppliers and the public need a way to assess whether the standard is being met. Publication should use understandable and comparable measures, with enough explanation to avoid misleading comparisons between unlike businesses or periods. Transparency is not a substitute for payment, but it gives the standard practical meaning and helps identify where improvement is needed.

Taken together, the clauses are more useful than any one in isolation. A deadline gives clarity; interest gives the deadline consequence; publication makes performance visible. None requires us to claim that all buyers behave alike. The standard addresses a practice, not a named company, and it does not require members to disclose their identities or business details.

What I ask

I ask members of the Cashflow Council to read the final ballot text with care and vote according to their judgment. Support for the standard should not require anyone to deny the complications raised in consultation. Nor should respectful disagreement be treated as disloyalty to the Council. Members may reasonably differ about timing, administration and the best route from a voluntary standard to wider adoption. We should preserve that disagreement in the record and make our decision through the process we agreed to follow.

If the Assembly adopts CF-001, I ask members to help explain its limited but important aim: a large buyer should pay a small supplier within 15 days of an undisputed invoice; late payment should carry automatic interest; and payment times should be published. I ask members to support practical adoption by buyers, to tell us where the wording is unclear, and to continue reporting relevant experiences without naming their businesses or making unsupported accusations about particular companies.

I also ask members to keep the evidence disciplined. Report what happened, when it happened, what was disputed, what was paid and what remains outstanding. A specific account is more useful than a broad allegation. Our credibility depends on being as careful with the evidence as we are determined about the standard we seek.

Notes and sources

1. UK Small Business Commissioner, “Late Payments Bill: What it could mean for your business”; UK Government, “Late payment consultation: Time to pay up — government response.” ↩

2. European Parliament, Legislative Train, “Late payments: revision of the Late Payment Directive.” ↩

3. Legal 500, “Payments to micro and small enterprises (MSEs): implications under section 43B(h) of Income-tax Act, 1961.” ↩

4. Payment Times Reporting Scheme, “Regulator’s update, August 2026.” ↩

5. Australian Small Business and Family Enterprise Ombudsman, “Productivity Commission inquiry into business reporting,” 30 September 2026. ↩

Sources

1. UK Small Business Commissioner, Late Payments Bill: What it could mean for your business
2. UK Government, Late payment consultation: Time to pay up — government response
3. European Parliament, Legislative Train: Late payments
4. Legal 500, Payments to micro and small enterprises: implications under section 43B(h)
5. Payment Times Reporting Scheme, Regulator's update, August 2026
6. Australian Small Business and Family Enterprise Ombudsman, Productivity Commission inquiry into business reporting