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On June 1, 2020, the Cabinet Committee on Economic Affairs approved a revision in the definition of Micro, Small and Medium Enterprises (MSMEs).[1]  In this blog, we discuss the change in the definition as approved by the Cabinet, and examine some of the common criteria used for classification of MSMEs.

Currently, MSMEs are defined under the Micro, Small and Medium Enterprises Development Act, 2006.[2]  The Act classifies them as micro, small and medium enterprises based on: (i) investment in plant and machinery for enterprises engaged in manufacturing or production of goods, and (ii) investment in equipment for enterprises providing services.  As per the Cabinet approval, the investment limits will be revised upwards and annual turnover of the enterprise will be used as additional criteria for the classification of MSMEs (Table 1). 

Earlier attempts to amend the definition of MSMEs

The central government has sought to revise the definition of MSMEs in the Act on two earlier occasions.  The government introduced the MSME Development (Amendment) Bill, 2015 which proposed to increase the investment limits for manufacturing and services MSMEs.[3]  This Bill was withdrawn in July 2018 and another Bill was introduced.  The MSME Development (Amendment) Bill, 2018 proposed to: (i) use annual turnover as criteria instead of investment for classification of MSMEs, (ii) remove the distinction between manufacturing and services, and (iii) provide the central government with the power to revise the turnover limits, through a notification.[4]  The 2018 Bill lapsed with the dissolution of 16th Lok Sabha. 

Global trends in criteria for the classification of MSMEs

While India will now be using investment and annual turnover as the criteria to classify MSMEs, globally, the number of employees is the most widely used criteria for classifying MSMEs.  The Reserve Bank of India's Expert Committee on MSMEs (2019) cited a study by the International Finance Corporation in 2014 which analysed 267 definitions used by different institutions in 155 countries.[5],[6]  According to the study, countries used a combination of criteria to classify MSMEs.   92% of the definitions used the number of employees as one of the criteria.  Other frequently used criteria were: (i) turnover (49%), and (ii) value of assets (36%).  11% of the analysed definitions used alternative criteria such as: (i) loan size, (ii) years of experience, and (iii) initial investment. 

Evaluation of common criteria used to define MSMEs

Investment: The 2006 Act uses investment in plant, machinery, and equipment to classify MSMEs.  Some of the issues with the investment criteria include:

  • The investment criteria require physical verification and have associated cost overheads.[7]
  • The investment limits may need to be revised from time-to-time due to the impact of inflation.  The Standing Committee on Industry (2018) had observed that limits set under the Act in 2006 have become irrelevant due to the impact of inflation.7
  • Due to their informal and small scale of operations, firms often do not maintain proper books of accounts and hence find it difficult to get classified as MSMEs as per the current definition.5

  • The investment-based classification incentivises promoters to keep the investment size restricted to retain the benefits associated with the micro or small category.7

Turnover: The 2018 Bill sought to replace the investment criteria with annual turnover as the sole criteria for the classification of MSMEs.  The Standing Committee agreed with the proposal under the Bill to use annual turnover as the criteria instead of investment.7  It observed that this could overcome some of the shortcomings of classification based on investment.  While turnover based criteria will also require verification, the Committee noted that the GST Network (GSTN) data can act as a reliable source of information for this purpose.  However, it also observed that:7

  • With turnover as a criterion for classification, corporates may misuse the incentives meant for MSMEs.  For instance, there is a possibility that a multi-national company may produce a large quantity of products worth a high turnover and then market it through various subsidiaries registered as Micro or Small enterprise under GSTN. 

  • The turnover of some enterprises may fluctuate depending on their business, which may result in the change of classification of the enterprise during a year. 

  • The Committee noted that there is a wide gap in turnover limits.  For instance, an enterprise with a turnover of Rs 6 crore and an enterprise with a turnover of Rs 75 crore (as proposed in 2018 Bill) would both be classified as a small enterprise, which seems incongruous. 

The Expert Committee (RBI) also recommended using annual turnover as the criteria for classification instead of investment.5  It observed that turnover based definition would be transparent, progressive, and easier to implement through the GSTN.  It also recommended that the power to change the definition of MSMEs should be delegated to the executive as it will help in responding to changing economic scenarios.

Number of employees: The Standing Committee had highlighted that in a labour-intensive country like India, appropriate focus is required on employment generation and MSME sector is the most suitable platform for this.7  It had recommended that the central government should assess the number of persons employed in the MSME sector and also consider employment as a criterion while classifying MSMEs.  However, the Expert Committee (RBI) stated that while the employment-based definition is an additional feature preferred in some countries, the definition would pose challenges in implementation.5  According to the Ministry of MSME, employment as a criterion has problems due to: (i) factors such as seasonality and informal nature of engagement, (ii) similar to investment criteria, this would also require physical verification and has associated cost overheads.7  

Number of MSMEs

According to the National Sample Survey (2015-16), there were around 6.34 crore MSMEs in the country.  The micro sector with 6.3 crore enterprises accounted for more than 99% of the total estimated number of MSMEs.  The small and medium sectors accounted for only 0.52% and 0.01% of the estimated number of enterprises, respectively.  Another dataset to understand the distribution of MSMEs is Udyog Aadhaar, a unique identity provided by the Unique Identification Authority of India (UIDAI) to MSME enterprises.[8]  Udyog Aadhaar registration is based on self-declaration by enterprises.  Between September 2015 and June 2020, 98.6 lakh enterprises have registered with UIDAI.  According to this dataset, micro, small, and medium enterprises comprise 87.7%, 11.8% and 0.5% of the MSME sector respectively.

Employment in the MSME sector

The MSME sector employed nearly 11.1 crore people in 2015-16.  The sector was the second largest employer after the agriculture sector.  The highest number of employed persons were engaged in trade activity (35%), followed by persons engaged in manufacturing (32%).

Implications of change in the definition of MSMEs

The change in the definition of MSMEs may result in many enterprises which are currently classified as Small enterprises be reclassified as Micro, and those classified as Medium enterprises be reclassified as Small.  Further, there may be many enterprises which are not currently classified as MSMEs, which may fall under the MSME classification as per the new definition.   Such enterprises will also now benefit from the schemes related to MSMEs.  The Ministry of MSME runs various schemes to provide for: (i) flow of credit to MSMEs, (ii) support for technology upgrade and modernisation, (iii) entrepreneurship and skill development, and (iv) cluster-wise measures to promote capacity-building and empowerment of MSME units.  For instance, under the Credit Guarantee Fund Scheme for Micro and Small Enterprises, a credit guarantee cover of up to 75% of the credit is provided to micro and small enterprises.[9]  Thus, the re-classification may require a significant increase in budgetary allocation for the MSME sector. 

Other announcements related to MSMEs in the aftermath of COVID-19 

MSME sector accounted for nearly 33.4% of the total manufacturing output in 2017-18.[10]  During the same year, its share in the country’s total exports was around 49%.  Between 2015 and 2017, the contribution of the sector in GDP has been around 30%.  Due to the national lockdown induced by COVID-19, businesses including MSMEs have been badly hit.  To provide immediate relief to the MSME sector, the government announced several measures in May 2020.[11]  These include: (i) collateral-free loans for MSMEs with up to Rs 25 crore outstanding and up to Rs 100 crore turnover, (ii) Rs 20,000 crore as subordinate debt for stressed MSMEs, and (iii) Rs 50,000 crore of capital infusion into MSMEs.  These measures have also been approved by the Union Cabinet.[12]    

For more details on the announcements made under the Aatma Nirbhar Bharat Abhiyan, see here

[1] “Cabinet approves Upward revision of MSME definition and modalities/ road map for implementing remaining two Packages for MSMEs (a)Rs 20000 crore package for Distressed MSMEs and (b) Rs 50,000 crore equity infusion through Fund of Funds”, Press Information Bureau, Cabinet Committee on Economic Affairs, June 1, 2020.

[2] The Micro, Small and Medium Enterprises Development Act, 2006, https://samadhaan.msme.gov.in/WriteReadData/DocumentFile/MSMED2006act.pdf.

[3] The Micro, Small and Medium Enterprises Development (Amendment) Bill, 2015, https://www.prsindia.org/sites/default/files/bill_files/MSME_bill%2C_2015_0.pdf.

[4] The Micro, Small and Medium Enterprises Development (Amendment) Bill, 2018, https://www.prsindia.org/sites/default/files/bill_files/The%20Micro%2C%20Small%20and%20Medium%20Enterprises%20Development%20%28Amendment%29%20Bill%2C%202018%20Bill%20Text.pdf.

[5] Report of the Expert Committee on Micro, Small and Medium Enterprises, The Reserve Bank of India, July 2019, https://rbidocs.rbi.org.in/rdocs/PublicationReport/Pdfs/MSMES24062019465CF8CB30594AC29A7A010E8A2A034C.PDF.

[6] MSME Country Indicators 2014, International Finance Corporation, December 2014, https://www.smefinanceforum.org/sites/default/files/analysis%20note.pdf.

[7] 294th Report on Micro Small and Medium Enterprises Development (Amendment) Bill 2018, Standing Committee on Industry, Rajya Sabha, December 2018, https://rajyasabha.nic.in/rsnew/Committee_site/Committee_File/ReportFile/17/111/294_2019_3_15.pdf.

[8] Enterprises with Udyog Aadhaar Number, National Portal for Registration of Micro, Small & Medium Enterprises, Ministry of Micro, Small and Medium Enterprises, https://udyogaadhaar.gov.in/UA/Reports/StateBasedReport_R3.aspx.

[9] Credit Guarantee Fund Scheme for Micro and Small Enterprises, Ministry of Micro, Small and Medium Enterprises, http://www.dcmsme.gov.in/schemes/sccrguarn.htm.

[10] Annual Report 2018-19, Ministry of Micro, Small and Medium Enterprises, https://msme.gov.in/sites/default/files/Annualrprt.pdf.

[11] "Finance Minister announce measures for relief and credit support related to businesses, especially MSMEs to support Indian Economy’s fight against COVID-19", Press Information Bureau, Ministry of Finance, May 13, 2020.

[12] "Cabinet approves additional funding of up to Rupees three lakh crore through introduction of Emergency Credit Line Guarantee Scheme (ECLGS)", Press Information Bureau, Ministry of Finance, May 20, 2020.

Recently, there have been multiple Naxal attacks on CRPF personnel in Chhattisgarh.  Parliamentary Committees have previously examined the working of the Central Armed Police Forces (CAPFs).  In this context, we examine issues related to functioning of these Forces and recommendations made to address them.

What is the role of the Central Armed Police Forces (CAPFs)?

Under the Constitution, police and public order are state subjects.  However, the Ministry of Home Affairs (MHA) assists state governments by providing them support of the Central Armed Police Forces.  The Ministry maintains seven CAPFs: (i) the Central Reserve Police Force, which assists in internal security and counterinsurgency, (ii) the Central Industrial Security Force, which protects vital installations (like airports) and public sector undertakings, (iii) the National Security Guards, which is a special counterterrorism force, and (iv) four border guarding forces, which are the Border Security Force, Indo-Tibetan Border Police, Sashastra Seema Bal, and Assam Rifles.

What is the sanctioned strength of CAPFs personnel compared to the actual strength?

As of January 2017, the sanctioned strength of the seven CAPFs was 10,78,514 personnel.  However, 15% of these posts (1,58,591 posts) were lying vacant.  Data from the Bureau of Police Research and Development shows that vacancies in the CAPFs have remained over the years.  Table 1 shows the level of vacancies in the seven CAPFs between 2012 and 2017. Nov 2The level of vacancies is different for various police forces.  For example, in 2017, the Sashastra Seema Bal had the highest level of vacancies at 57%.  On the other hand, the Border Security Force had 2% vacancies.  The Central Reserve Police Force, which account for 30% of the sanctioned strength of the seven CAPFs, had a vacancy of 8%.

How often are CAPFs deployed?

According to the Estimates Committee of Parliament, the number of deployment of CAPFs battalions has increased from 91 in 2012-13 to 119 in 2016-17.  The Committee has noted that there has been heavy dependence by states on central police forces even for day-to-day law and order issues.  This is likely to affect anti-insurgency and border-guarding operations of the Forces, as well as curtail their time for training.  The continuous deployment also leaves less time for rest and recuperation.

The Estimates Committee recommended that states must develop their own systems, and augment their police forces by providing adequate training and equipment.  It further recommended that the central government should supplement the efforts of state governments by providing financial assistance and other help for capacity building of their forces.

What is the financial allocation to CAPFs?

Under the Union Budget 2018-19, an allocation of Rs 62,741 crore was made to the seven CAPFs.  Of this, 32% (Rs 20,268 crore) has been allocated to the Central Reserve Police Forces.  The Estimates Committee has pointed out that most of the expenditure of the CAPFs was on salaries.  According to the Committee, the financial performance in case of outlays allocated for capacity augmentation has been very poor.  For example, under the Modernization Plan-II, Rs 11,009 crore was approved for the period 2012-17.  However, the allocation during the period 2013-16 was Rs 251 crore and the reported expenditure was Rs 198 crore.

What are the working conditions for CAPFs personnel?

The Standing Committee on Home Affairs in the year 2017 had expressed concern over the working conditions of personnel of the border guarding forces (Border Security Force, Assam Rifles, Indo-Tibetan Border Police, and Sashastra Seema Bal).  The Committee observed that they had to work 16-18 hours a day, with little time for rest or sleep.  The personnel were also not satisfied with medical facilities that had been provided at border locations.

In addition, the Standing Committee observed that personnel of the CAPFs have not been treated at par with the Armed Forces, in terms of pay and allowances.  The demand for Paramilitary Service Pay, similar to Military Service Pay, had not been agreed to by the Seventh Central Pay Commission.  Further, the Committee observed that the hard-area allowance for personnel of the border guarding forces was much lower as compared to members of the Armed Forces, despite being posted in areas with difficult terrain and harsh weather.

What is the status of training facilities and infrastructure available to CAPFs?

The Estimates Committee has noted that all CAPFs have set up training institutions to meet their training requirements and impart professional skills on specialised topics.  However, the Committee noted that there is an urgent need to upgrade the curriculum and infrastructure in these training institutes.  It recommended that while purchasing the latest equipment, training needs should also be taken care of, and if required, should be included in the purchase agreement itself.  Further, it recommended that the contents of training should be a mix of conventional matters as well as latest technologies such as IT, and cyber security.

According to the Estimates Committee, the MHA has been making efforts to provide modern arms, ammunition, and vehicles to the CAPFs.  In this regard, the Modernization Plan-II, for the period 2012-17, was approved by the Cabinet Committee on Security.  The Plan aims to provide financial support to CAPFs for modernisation in areas of arms, clothing, and equipment.

However, the Committee observed that the procurement process under the Plan was cumbersome and time consuming.  It recommended that the bottlenecks in procurement should be identified and corrective action should be taken.  It further suggested that the MHA and CAPFs should hold negotiations with ordnance factories and manufacturers in the public or private sector, to ensure an uninterrupted supply of equipment and other infrastructure.