MSME Online Mediation Under the 2026 Amendment Act: 90-Day Timeline and Evidence Checklist
By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026
The amended section 18 provides a 90-day mediation period from the date fixed for first appearance and enables an online mechanism, but these new timelines should be treated as enacted-not-yet-commenced until the commencement notification applies.
Finin2min 2-Minute Summary
- Mediation status note: the 90-day first-appearance clock is in the enacted amendment, yet it should not be presented as a currently running statutory deadline until the amended section commences.
- The amended section 18(3A) sets 90 days from the date fixed for first appearance for completion of mediation.
- The Central Government may establish an online mediation/arbitration mechanism and prescribe procedure.
- Supplier jurisdiction is linked to the official registration address under the amended framework.
- Businesses should prepare an invoice-to-dispute chronology so mediation can focus on the actual payment issue.
Start the dispute file before mediation
Keep purchase order/contract, invoice, delivery/acceptance, credit notes, payment terms, ledger, statutory MSME status and correspondence. Identify principal, interest claim and any quality/set-off dispute separately.
A 90-day clock will be difficult to use effectively if parties spend the first weeks reconstructing records.
First-appearance date becomes critical
Once the amended provision commences, the mediation period is tied to the date fixed for first appearance. Record service, appearance and adjournments precisely.
Do not confuse referral date with first-appearance date.
Online process readiness
Prepare searchable PDFs, authorised representative details, video-hearing access, electronic-signature/filing capability and a settlement-authority matrix.
Confidentiality and settlement approvals should remain controlled even in a digital workflow.
90-day mediation case: first appearance is adjourned
A reference is listed for first appearance, but one party seeks adjournment. The amended clock is tied to the date fixed for first appearance, so process records should preserve the original fixed date and subsequent adjournment orders. Parties should not restart the internal clock simply because the substantive discussion began later.
This makes document readiness essential before the first listed date. A party that spends several weeks assembling invoices and ledger evidence can consume a material part of the future statutory period.
- Record the first fixed appearance date.
- Do not reset the clock informally after adjournment.
- Prepare evidence before the first listing.
Mediation checklist
- Supplier registration/jurisdiction.
- Invoice/payment chronology.
- Principal/interest calculation.
- First-appearance date.
- Authority to settle.
- Digital evidence bundle.
- Commencement/online rules verified.
Questions readers commonly ask
Is the 90-day period already operative on 5 October 2026?
Treat it as pending the relevant commencement notification unless a later official notification is verified.
When does the 90 days run from under the amended text?
From the date fixed for first appearance.
Can mediation be online?
The amended Act empowers an online mechanism subject to notification/rules.
What should be prepared first?
A clean invoice and payment evidence chronology.
Official / primary sources
- Ministry of MSME - Amendment Act listing - Official ministry listing of MSMED Amendment Act 2026
- PIB - Parliament passage of MSMED Amendment Bill 2026 - Official background and enactment history
- PIB - MSMED Amendment 2026 backgrounder - Official summary of changes
- eGazette recent uploads - Act No. 16 of 2026 Gazette publication
Disclaimer
Important: General educational and professional-reference material. Verify the current operative law, commencement notification, portal version and exact facts before acting. Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.