In this note, the notion of integrability is defined for 1-forms defined in the time-delay context. While in the delay-free case, a set of 1-forms defines a vector space, it is shown that 1-forms computed for time-delay systems have to be viewed as elements of a module over a certain non-commutative polynomial ring. Two notions of integrability are defined, strong and weak integrability, which coincide in the delay-free case. Necessary and sufficient conditions are given to check if a set of 1-forms is strongly or weakly integrable. To show the importance of the topic, integrability of 1-forms is used to characterize the accessibility property for nonlinear time-delay systems. The possibility of transforming a system into a certain normal form is also considered.