Letter from the table: Keep the 15‑day promise, close the loopholes

RC/CF/2026/T.20 · 12 October 2026

To the Cashflow Council,

I am writing from Ahmedabad as a small-business owner who wants the 15-Day Pay Standard to succeed. I am asking you to amend it before adoption. A clear deadline can help a supplier plan wages, rent and tax payments. But a standard that does not say precisely when the clock starts, or what happens when only part of an invoice is disputed, could give a large buyer new ways to delay the part it does not dispute.

On 3 June this year, I sent an invoice for ₹1,80,000 to a large buyer. The work had been accepted on 5 June. The purchase order set a 30-day payment term, so I marked 5 July as the expected payment date. The invoice was not disputed. I followed up by email before the due date, then again after it passed. The payment arrived on 21 July: sixteen days after the date I had been working toward.

Those dates mattered in my office. I had a smaller supplier to pay and wages to meet. I moved money between accounts and postponed one purchase I had planned. None of that was dramatic enough to make a case file by itself. It was still my time, my attention and my money being used to finance somebody else’s payment cycle.

I am registered as a micro enterprise. Under section 15 of India’s Micro, Small and Medium Enterprises Development Act, where a written agreement sets a payment period, that period cannot exceed 45 days from acceptance or deemed acceptance. Without a written agreement, payment is due within 15 days. Section 16 provides for compound interest, with

monthly rests, at three times the RBI bank rate when payment is late. Section 43B(h) of the Income-tax Act can defer a buyer’s deduction for a payment to a micro or small enterprise until the buyer actually pays, if it pays beyond the section 15 limit.¹

I knew those protections existed. I also knew that invoking them would mean more correspondence and possibly a reference to the state Micro and Small Enterprises Facilitation Council. I did not pursue interest on this invoice. I wrote to the accounts-payable desk, sent the invoice and acceptance record again, and asked for a payment date. I kept the exchange factual. I wanted the money, and I wanted to keep the working relationship possible. The buyer paid, but the delay had already made me its temporary lender.

This is why I support the draft’s direction and still ask for amendments. A 15-day standard should not become a reason for a buyer to say, “The clock has not started,” whenever its internal system has not completed a step. Nor should a disagreement over one line hold up the rest of an invoice.

My amendment is simple: make the payment clock objective, require prompt and specific notice of a genuine dispute, and require payment of the undisputed amount on time.

I ask the Council to make four changes:

• Define receipt and acceptance. The clock should begin when an invoice is received through the buyer’s stated channel, or when the goods or services are accepted, whichever event the standard identifies. A buyer should not be able to restart the clock through an internal approval step or an unannounced change in its invoicing system.

• Set a short deadline for raising a dispute. A notice should identify the specific amount and reason in writing. A general “invoice under review” should not suspend payment of the whole invoice indefinitely.

• Protect the undisputed portion. If a buyer challenges ₹10,000 of a ₹1,80,000 invoice, the remaining ₹1,70,000 should not be held back while the parties resolve that one item.

• State that the standard is a floor, not a replacement for stronger local rights. In India, the 15-day statutory period applies where there is no written agreement; an agreed period is subject to the 45-day ceiling. The standard should encourage faster payment without implying that other statutory protections, including applicable interest, disappear.

Automatic interest is important, but it needs a workable process. The standard should tell buyers to calculate and pay interest without making a supplier submit repeated requests. It should also make clear that interest is not permission to hold the principal, and that a buyer cannot avoid the standard merely by disputing an invoice after its payment deadline.

Notes and sources

Sources

1. India: Payments to micro and small enterprises; sections 43B(h) and 15