GSTR-9 and GSTR-9C for FY 2025-26: who must file and what to check
- November 13, 2026
- Posted by: kirit.topgstexperts
- Category: GST
A regular GST taxpayer whose aggregate turnover for FY 2025-26 is more than ₹ 2 crore must file the annual return in Form GSTR-9. If turnover is more than ₹ 5 crore, a self-certified reconciliation statement in Form GSTR-9C must be filed with it. Both are due by 31.12.2026, and the GST portal has enabled filing for FY 2025-26.
This guide explains who has to file, the prerequisites and late fee, the tables where errors usually creep in, and how to reconcile your returns with your books before you submit.
Who must file GSTR-9 for FY 2025-26
Section 44 of the CGST Act, 2017 requires every registered person to file an annual return, and rule 80 of the CGST Rules prescribes the forms. Some classes of persons are carved out, and the government can exempt others by notification.
The key relief for small businesses is Notification No. 15/2025-Central Tax dated 17.09.2025. It exempts a registered person whose aggregate turnover in a financial year is up to ₹ 2 crore from filing the annual return, for FY 2024-25 onwards. So for FY 2025-26, GSTR-9 is optional up to ₹ 2 crore and mandatory above it.
Aggregate turnover is computed on a PAN basis. It covers all GSTINs under the same PAN across India, and includes taxable, exempt and export supplies and inter-state stock transfers. A business with ₹ 1.2 crore in Maharashtra and ₹ 1.1 crore in Gujarat therefore crosses ₹ 2 crore, and each GSTIN must file its own GSTR-9.
Who files what
| Type of registered person | Annual return for FY 2025-26 |
|---|---|
| Regular taxpayer, aggregate turnover up to ₹ 2 crore | GSTR-9 optional |
| Regular taxpayer, aggregate turnover above ₹ 2 crore | GSTR-9 mandatory |
| Regular taxpayer, aggregate turnover above ₹ 5 crore | GSTR-9 and self-certified GSTR-9C |
| SEZ unit or SEZ developer | Same as a regular taxpayer, as per turnover |
| Composition taxpayer | GSTR-9A, not GSTR-9 |
| Opted in or out of composition during the year | GSTR-9 for the regular period, GSTR-9A for the composition period |
| Casual taxable person, non-resident taxable person, ISD, OIDAR supplier, TDS deductor or TCS collector | No GSTR-9 |
GSTR-9C is now self-certified
Until FY 2019-20, GSTR-9C had to be certified by a Chartered Accountant or Cost Accountant. Notification No. 30/2021-Central Tax dated 30.07.2021 substituted rule 80(3) with effect from 01.08.2021. Since then, a registered person with aggregate turnover above ₹ 5 crore files a self-certified GSTR-9C along with GSTR-9. The ‘self-certified’ label does not reduce the work: the statement still reconciles audited figures with the return, and any shortfall it shows must be paid.
Due date, prerequisites and late fee
Under section 44 and rule 80, the annual return and the reconciliation statement are due by 31 December after the end of the financial year. For FY 2025-26, that is 31.12.2026, unless the government extends it by notification. Per a GSTN advisory dated 13.10.2026, the portal enabled both forms for FY 2025-26 on 08.10.2026.
Before you start, two things must be in place:
- All GSTR-1/IFF and GSTR-3B returns for April 2025 to March 2026 must be filed. The GSTR-9 tile does not open until they are.
- GSTR-9 must be filed before GSTR-9C. The 9C tile becomes available only after the GSTR-9 for that year is filed.
Two more points from the portal FAQs matter in practice. First, GSTR-9 cannot be revised once filed, so every figure has to be right the first time. Second, GSTR-9 cannot be used to claim ITC that was not claimed in GSTR-3B. Extra tax you declare in GSTR-9 is paid separately through Form GST DRC-03.
Late fee
For FY 2022-23 onwards, Notification No. 07/2023-Central Tax dated 31.03.2023 reduced the late fee for GSTR-9. The figures below are the combined CGST and SGST amounts; the notification itself states the CGST half.
| Aggregate turnover in the year | Late fee per day (CGST + SGST) | Maximum late fee |
|---|---|---|
| Up to ₹ 5 crore | ₹ 50 | 0.04% of turnover in the State/UT |
| Above ₹ 5 crore, up to ₹ 20 crore | ₹ 100 | 0.04% of turnover in the State/UT |
| Above ₹ 20 crore | ₹ 200 | 0.5% of turnover in the State/UT |
Example: a trader with aggregate turnover of ₹ 3,00,00,000 files GSTR-9 on 20.01.2027, 20 days late. The late fee is ₹ 50 × 20 = ₹ 1,000 (₹ 500 CGST + ₹ 500 SGST). This is well below the cap of 0.04% × ₹ 3,00,00,000 = ₹ 12,000. The portal computes the late fee, and it must be paid before the return can be filed.
The late fee is the smaller risk. A late or careless annual return can prompt questions from the department, which take far more time to answer than the return takes to prepare.
Table-wise points and common mistakes
Much of GSTR-9 is auto-filled. Tables 4, 5, 6A and 9 draw on your filed GSTR-1, IFF and GSTR-3B. Table 8A draws on GSTR-2B, the static statement, for FY 2023-24 onwards. Auto-filled does not mean correct. These are the areas where mistakes usually happen.
| Table | What it captures | Common mistake |
|---|---|---|
| 4 and 5 | Outward supplies: taxable, exempt, nil-rated, non-GST, exports, credit and debit notes | Accepting auto-filled figures without matching the sales register, or leaving out amendments made in later months |
| 6 | ITC availed in GSTR-3B, split into inputs, capital goods and input services, and by source | Putting ITC on capital goods under inputs, or bundling import and RCM credit with domestic credit |
| 7 | ITC reversed during the year (rules 37, 37A, 38, 42, 43, section 17(5) and others) | Reporting the net figure only, so the reversal is invisible and Table 6 looks overstated |
| 8A to 8D | ITC as per GSTR-2B compared with ITC claimed | Not explaining a large positive 8D (credit available but not claimed, which lapses), or a negative 8D (more claimed than appears in GSTR-2B) |
| 8H1 | IGST on imports of FY 2025-26 claimed in the next year | Leaving it blank, so import credit claimed in 2026-27 looks unexplained |
| 9 | Tax payable and tax paid, rate-wise | Missing rows for the period before and after the 22.09.2025 rate changes |
| 10, 11, 14 | Supplies, amendments and tax for FY 2025-26 declared in returns of April to October 2026 | Leaving these blank when corrections were made in the following year |
| 12 and 13 | ITC reversed, or claimed, in the next year that relates to FY 2025-26 | Reporting the same credit in both Table 6 and Table 13 |
| 17 | HSN-wise summary of outward supplies | Wrong number of HSN digits (6 digits if aggregate turnover is above ₹ 5 crore; otherwise 4 digits, which are mandatory for B2B supplies), or one row for an HSN whose rate changed mid-year |
Three mistakes deserve special attention for FY 2025-26:
- Mid-year rate changes. GST rates on a large number of goods changed with effect from 22.09.2025. If an item moved from 12% to 5% or 18%, Tables 9 and 17 should show the old-rate and new-rate supplies in separate rows. A single row hides tax paid at the old rate and can look like a short payment.
- ITC cut-off. Under section 16(4), ITC on an FY 2025-26 invoice must be claimed by 30.11.2026 or the date of filing GSTR-9, whichever is earlier. Filing GSTR-9 early, before you have claimed all eligible credit, can bring that deadline forward.
- Treating GSTR-9 as a correction return. It is not. A missed liability must be paid through DRC-03 with interest. Credit you did not claim in GSTR-3B cannot be claimed here at all.
Reconciling the returns with your books
GSTR-9 summarises what you reported month by month. GSTR-9C tests that summary against your audited accounts. Do the reconciliation even if 9C does not apply to you: it is the only way to know that the annual return is right. It covers three areas.
- Turnover: turnover in the financial statements compared with turnover declared in GSTR-9.
- Tax: tax payable at each rate compared with tax paid.
- ITC: ITC in the books compared with ITC claimed in the returns.
Worked example: turnover
An LLP in Thane has a single GSTIN, and its audited turnover for FY 2025-26 is above ₹ 5 crore, so it must file GSTR-9C. Its reconciliation of turnover looks like this.
| Particulars | Amount (₹) |
|---|---|
| Turnover as per audited Profit and Loss Account | 6,80,00,000 |
| Less: unbilled revenue at 31.03.2026, invoiced in April 2026 | (4,50,000) |
| Add: unbilled revenue at 31.03.2025, invoiced during FY 2025-26 | 3,20,000 |
| Add: commercial credit notes reducing sales in the books, with no GST credit note issued | 1,10,000 |
| Adjusted turnover | 6,79,80,000 |
| Turnover declared in GSTR-9 | 6,79,80,000 |
| Unreconciled difference | Nil |
Each adjustment has a reason that can be documented. Had the difference come to, say, ₹ 2,00,000 of missed taxable sales, the LLP would pay the tax on it through DRC-03, with interest, and disclose it in the return.
Worked example: ITC (Table 8)
The same LLP’s ITC on domestic purchases, excluding imports, RCM and ISD credit, compares as follows.
| Table 8 row | Amount (₹) |
|---|---|
| 8A: ITC as per GSTR-2B | 42,60,000 |
| 8B: ITC claimed in GSTR-3B (from Table 6B and 6H) | 40,95,000 |
| 8C: FY 2025-26 ITC claimed in returns of 2026-27 filed up to 30.11.2026 | 1,20,000 |
| 8D: difference, 8A minus (8B + 8C) | 45,000 |
The ₹ 45,000 is credit shown in GSTR-2B that was never claimed. Break it down before filing: blocked credit under section 17(5), invoices not received, or credit missed by mistake. Credit missed by mistake can still be claimed in a GSTR-3B filed by 30.11.2026. After that date it lapses.
You can check rate-wise tax figures quickly with our GST calculator.
Practical checklist before you file
- Confirm aggregate turnover on a PAN basis for all GSTINs, to see whether GSTR-9 and GSTR-9C apply.
- Make sure every GSTR-1/IFF and GSTR-3B for April 2025 to March 2026 is filed.
- Claim any remaining eligible FY 2025-26 ITC in a GSTR-3B filed by 30.11.2026.
- Match the sales register with GSTR-1, including credit notes and amendments.
- Match the purchase register with GSTR-2B, and explain every 8D difference.
- List ITC reversals by rule (37, 37A, 38, 42, 43) and blocked credit under section 17(5) for Table 7.
- Split supplies before and after 22.09.2025 for items whose rate changed.
- Prepare the HSN summary for Table 17 with the correct number of digits.
- Reconcile turnover, tax and ITC with the audited accounts, and pay any shortfall through DRC-03.
- Download the draft, review it, and file GSTR-9 first, then GSTR-9C.
Frequently asked questions
My turnover for FY 2025-26 was ₹ 1.8 crore. Do I need to file GSTR-9? No. Turnover up to ₹ 2 crore is exempt from the annual return under Notification No. 15/2025-Central Tax. You may still file it voluntarily.
Can I correct a mistake after filing GSTR-9? No. The portal does not allow a filed GSTR-9 to be revised. Pay any extra tax through DRC-03 and keep a note of the reason.
Does GSTR-9C still need a Chartered Accountant’s certificate? No. Since 01.08.2021, GSTR-9C is self-certified by the taxpayer. Many businesses still have a professional prepare it, because it reconciles audited accounts with the returns.
Can I claim missed ITC through GSTR-9? No. ITC can be claimed only in GSTR-3B, and for FY 2025-26 only up to 30.11.2026 or the date of filing GSTR-9, whichever is earlier.
I have two GSTINs. Do I file one annual return or two? Two. GSTR-9 is filed separately for each GSTIN. The ₹ 2 crore and ₹ 5 crore limits, however, are tested on aggregate turnover across all GSTINs under your PAN.
Getting it done
The annual return is easiest when the monthly returns were reconciled during the year. If they were not, start now. Leave enough time to claim missed credit before 30.11.2026 and to settle differences before the due date. For a broader view of GST compliance, see our GST services page.
For help with GSTR-9 or GSTR-9C, you can write to advisory@topgstexperts.com.
This article reflects the law as on 06.11.2026 and is general information, not professional advice. Rates, limits and due dates change; verify them with the official source before acting.