Letter from the table: The problem is not only the number of days

To the Cashflow Council,

I oppose CF-001 as drafted. I do not oppose paying small suppliers promptly. I oppose making 15 days the universal standard for large buyers without first fixing the machinery that is supposed to make payment rules work. My experience in Jaipur is that a term printed on paper does not put money in my account. A shorter term can still leave a small supplier carrying the cost, while making every ordinary invoice feel like a dispute.

The invoice that kept my month from closing

On 12 January 2026, a large buyer acknowledged an invoice of ₹2,40,000 from me. The written terms allowed 30 days, and the stated due date was 11 February. The work had been completed and there was no dispute over the amount. I expected the money to cover ordinary costs that I had already paid: wages, rent, and a payment on my working-capital borrowing.

On 12 February I wrote to ask when the transfer would be made. I followed up again on 20 February, then on 3 March. Each time I sent the invoice and the acknowledgement again. I was not told that the work was defective or that any part of the bill was disputed. I received no definite payment date. I had to keep the people I owed waiting, and I used more of my overdraft to meet costs that could not wait.

The money arrived on 6 April. That was nearly eight weeks after the agreed due date. By then, the cost to me was not just the delay on a screen: I had paid borrowing charges and spent time chasing money instead of doing paid work. I did not make a formal claim for statutory interest. I needed the relationship to continue, and I did not know whether asserting the claim would make the next invoice harder to collect.

Indian law already gives a micro or small enterprise important protections. Under section 15 of the Micro, Small and Medium Enterprises Development Act, a written payment agreement cannot extend beyond 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 also affects a buyer’s deduction for sums owed to micro and small enterprises if they are not paid within the time set by section 15.¹ My experience was not that there was no rule. It was that knowing a rule existed did not make the money arrive, or make it easy for me to enforce the rule without risking a commercial relationship.

Why I do not support a blanket 15 days

A 15-day limit would have helped me with that January invoice if the buyer had followed it. But it would also treat every undisputed invoice as if the time needed to verify, record and schedule it were the same. In my own work, I have seen a smaller invoice paid 22 days after acknowledgement, with no disagreement about the amount or the work. That payment was within the written 30-day term. Under CF-001, it would be late. I understand why a supplier wants those six days back. I also know that a rule that labels routine processing as late may encourage buyers to delay acknowledgement, question an invoice, or move the argument from “when will you pay?” to “when did the clock start?”

That is not a theoretical concern for someone small. I cannot assign a person to chase every acknowledgement or take every buyer to a forum. I need a standard that improves the chance of getting paid, not only one that gives me another deadline to point to after the money is late. The January invoice was already beyond the Indian statutory maximum for a written term of 30 days. A new 15-day promise would not, by itself, have answered why it remained unpaid or helped me recover the interest without fear of losing future work.

I support automatic interest in principle. Where the law already provides for it, interest should not depend on a supplier being brave enough to ask. I also support publishing payment performance, provided the figures use clear definitions: when the invoice was received, when it was accepted, which invoices were genuinely disputed, and how long payment took after resolution. A single average can hide the invoices that matter most to a small supplier.

What I ask the Council to change

Please do not adopt a universal 15-day deadline as the central fix. Keep the focus on prompt payment, but make the standard require buyers to acknowledge invoices quickly, state any specific dispute promptly, and pay the undisputed part on time. Require a clear, dated record of acceptance and dispute so that a buyer cannot quietly restart the clock. Make statutory interest

visible on late payments and create a practical route for a small supplier to claim it without having to risk the whole relationship. Publish comparable payment data, including the share of invoices paid within the agreed term and the share paid after it.

For buyers that can pay within 15 days, I welcome that commitment. I would rather see it as a pledge or a performance measure than as a universal rule that replaces the work of enforcing the protections already on the books. My invoice was not late because India lacked a 15-day phrase. It was late because the agreed date passed, the statutory limit passed, and I had no simple way to make either one matter.

Notes and sources

1. India’s section 15 and section 43B(h) framework, including the interest provision under section 16, is summarized in the cited legal reference. ↩

Sources

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