Quick answer: Not from your invoice date. The clock starts from the date of ‘acceptance’ of your goods or services — and if the buyer raises no written objection within 15 days of delivery, the law treats the delivery date itself as the date of acceptance. Getting this date right decides when payment is due and from when your interest is calculated.

Why is the invoice date not the starting point?

Because an invoice is just your demand for payment — it says nothing about whether the buyer actually received and accepted what you supplied. The MSMED Act ties the payment timeline to acceptance, which is about the goods or services themselves. In most routine transactions the two dates are close together, but in disputes, the difference of even a couple of weeks changes the interest calculation — so it pays to understand the rule precisely.

How does ‘acceptance’ work in practice?

There are two scenarios. Scenario one: the buyer receives your goods or services and says nothing. If no written objection comes within 15 days of delivery, the law deems the delivery accepted — and here is the crucial detail: the day of deemed acceptance is the day of actual delivery itself, not the 15th or 16th day. The 15 days is only the buyer’s window to object. So your payment clock (15 or 45 days, depending on whether there is a written agreement) runs from the delivery date.

Scenario two: the buyer raises a genuine written objection within those 15 days — say, a quality issue. If you then resolve the issue, acceptance happens on the date the objection is resolved, and the payment clock starts from that later date.

Why does this rule actually favour suppliers?

Two reasons. First, a buyer who stays silent after delivery cannot come back months later and manufacture a quality dispute just to dodge payment — their window to object was 15 days. Second, silence is not a bad sign; it is your countdown quietly starting. Many suppliers wait anxiously for a buyer’s “confirmation” that never comes, not realising that once 15 days pass silently, the law treats the delivery date itself as the accepted date.

What records should you keep to prove the acceptance date?

Everything that fixes dates: delivery challans or proof of delivery, service completion emails, the buyer’s acknowledgements, and any objection correspondence with its resolution. In MSME Facilitation Council proceedings, cases are frequently won or lost on exactly this — not on whether money was owed, but on proving when the clock started. A simple habit of filing delivery proof against every invoice puts you in a strong position before any dispute even begins.

A quick example

You deliver goods on 1 June. The buyer says nothing for 15 days. Deemed acceptance is then treated as 1 June — the delivery date itself, not 16 June. With a written agreement (45-day term), payment is due within 45 days of 1 June, i.e., by around 16 July; without any written agreement, within 15 days of 1 June, i.e., by around 16 June. Interest starts the day after the applicable deadline — not from your invoice date of, say, 25 May.

Frequently Asked Questions

Q. What if the buyer verbally complained but never put it in writing?

A. The law looks at written objections raised within 15 days. Verbal grumbling that was never documented generally does not stop deemed acceptance.

Q. Does the rule apply to services as well as goods?

A. Yes. The same acceptance / deemed-acceptance logic applies to services rendered.

Q. What if I delivered in instalments?

A. Each delivery and its acceptance can carry its own timeline. Keep proof for every lot, not just the final one.

Q. Can the buyer extend the 15-day objection window by agreement?

A. The 15-day deemed-acceptance mechanism is set by the statute. Practical arrangements vary, but you should not assume the window can be stretched against you.

About the author: Advocate Praveen Siinghhal is a Delhi-based lawyer with 25+ years of experience in MSME payment recovery, commercial disputes and business legal protection. He advises MSMEs and business owners on unpaid dues, legal notices, MSME Facilitation Council claims and recovery strategy.

Disclaimer: This article is for general information only and is not legal advice. Laws, RBI bank rate, tax treatment, portal procedures and case law may change from time to time. Please verify the current position or consult a professional before acting on any specific claim.