Who has to file GSTR-9 for FY 2025-26?

Every registered person other than an Input Service Distributor, a person paying tax under section 51 or 52, a casual taxable person and a non-resident taxable person, under section 44 of the CGST Act and rule 80. A person whose aggregate turnover in the year is up to ₹2 crore is exempt under Notification 15/2025-Central Tax of 17 September 2025, which applies to FY 2024-25 and onwards. A person paying tax under section 10 is dealt with separately in rule 80 and is outside this note.

When is GSTR-9C required, and is it still an audit?

It is required where aggregate turnover exceeds ₹5 crore (rule 80(3)). It is no longer an audit or a certification by a chartered accountant. Since 1 August 2021 it is a self-certified reconciliation of the value of supplies declared in the returns with the audited annual financial statement.

What is the due date, and has it been extended?

31 December 2026 for both, under rule 80(1) and (3). The portal enabled both forms for FY 2025-26 on 8 October 2026. We found no extension in the notifications and advisories we read; the date should be checked again before it is relied on.

How is the late fee worked out if the 9C is filed after the 9?

Section 47(2) charges the late fee for delay in the complete annual return, which the Board has said means both forms where the 9C is required (Circular 246/03/2025-GST). The fee runs from the due date until the later of the two filings and is not charged separately on each form. A 9 filed on time and a 9C filed seven days late costs seven days of late fee.

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Practice note · 2026-11-10 · By CA Arun Mehta

GSTR-9 and GSTR-9C for FY 2025-26: Who Must File, and Why a Late 9C Is a Late Annual Return

GSTR-9 for FY 2025-26 is due on 31 December 2026. Registered persons with aggregate turnover of up to ₹2 crore are exempt from filing it. GSTR-9C, a self-certified reconciliation of the return with the audited financial statements, is required where aggregate turnover exceeds ₹5 crore. Where it is required, the annual return is not complete until it is filed, so the late fee keeps running until then.

Two things have changed the practical meaning of the annual return in the last few years. GSTR-9C stopped being an audit, and the Board has said in terms that a return which needed a 9C is not complete without one. The first made the form lighter to file. The second made it costlier to forget.

Who files

Section 44(1) of the CGST Act requires every registered person to furnish an annual return, which may include a self-certified reconciliation statement reconciling the value of supplies declared in the returns for the year with the audited annual financial statement. The exclusions are the Input Service Distributor, persons paying tax under section 51 or section 52, casual taxable persons and non-resident taxable persons. Rule 80(1) prescribes FORM GSTR-9, due by 31 December following the end of the year.

The first proviso to section 44(1) lets the Commissioner exempt a class of registered persons on the Council's recommendation. Notification 15/2025-Central Tax, dated 17 September 2025, uses it to exempt persons with aggregate turnover of up to ₹2 crore in a financial year from GSTR-9, for FY 2024-25 and onwards. We have read the GST Council Secretariat's published summary of that notification and not the notification itself. On that reading it covers FY 2025-26 without a fresh notification. It exempts the person from GSTR-9 only; the ₹5 crore line for GSTR-9C is a different test.

GSTR-9C is a statement you certify yourself

Before 1 August 2021, accounts had to be audited under section 35(5) above a turnover threshold, and the 9C carried the auditor's certificate. The audit requirement was omitted. Rule 80(3), as substituted from that date, now requires a person whose aggregate turnover during the year exceeds ₹5 crore to furnish, along with the annual return and by the same date, a self-certified reconciliation statement in FORM GSTR-9C.

Self-certified does not mean informal. Section 44(1) describes it as reconciling the value of supplies declared in the returns with the audited annual financial statement, and the form also carries a reconciliation of credit. GSTN's FAQ says that reasons for an unreconciled difference in credit go in Table 13 of the form.

The date

Rule 80(1) and (3) fix 31 December 2026 for FY 2025-26. GSTN's advisory of 13 October 2026 says both forms have been enabled on the portal from 8 October 2026, and that the tile appears only once all GSTR-1 and GSTR-3B returns for the year have been filed. So an unfiled monthly return does not merely carry its own late fee; it also keeps the annual return from opening.

Past extensions have been made by amending the rule itself. Rule 80(1A) and (3A) fix 28 February 2022 for FY 2020-21. We found nothing of that kind for FY 2025-26 in what we read.

The late fee

Section 47(2) provides a late fee of ₹100 for every day of default, up to a maximum of a quarter per cent of turnover in the State or Union territory. Notification 07/2023-Central Tax of 31 March 2023 waives the part above the following, for FY 2022-23 onwards:

Aggregate turnover in the year	Late fee per day	Maximum
Up to ₹5 crore	₹25	0.02 per cent of turnover in the State or Union territory
Above ₹5 crore and up to ₹20 crore	₹50	0.02 per cent of turnover in the State or Union territory
Above ₹20 crore	₹100 (section 47(2) as it stands)	0.25 per cent of turnover in the State or Union territory

These are the amounts under the CGST Act. The corresponding provision of the State or Union territory Act is not covered by this note, and the portal computes the amount payable.

On the 9C, Circular 246/03/2025-GST of 30 January 2025 settles a question that had been put to the Board. Where a 9C is required, the annual return under section 44 is not furnished until both forms are, and the late fee is calculated from the due date to the date of the complete return, not separately for each form. GSTN has added a table for late fee payable and paid to the 9C for that reason, and works the position out automatically from the two filing dates.

The three-year bar

Section 44(2), in force from 1 October 2023, does not allow an annual return for a year to be furnished after three years from its due date, unless the Government notifies otherwise. For a year whose due date was 31 December 2023, that is 31 December 2026. We have not checked whether the date for that year was extended. A person with an old year still open should look at it now, not at the end of the month.

What the return is built from

GSTN's FAQ for FY 2024-25 describes how the form is populated, and the design carries into this year unless the portal says otherwise. We have not seen an FAQ for FY 2025-26.

Table 8A is the credit shown in GSTR-2B for the year, including invoices of the year that appeared in the 2B of April to October of the next year, and excluding invoices of the previous year that appeared in 2B in that window.
Table 6A1 carries credit of the preceding year that was claimed in this one.
Table 8C carries credit of this year that was first claimed in next year's GSTR-3B, within the time allowed.
Reclaims under rules 37 and 37A are reported in Table 6H of the year in which they are reclaimed.

Credit is claimed in GSTR-3B, not in the annual return. The return reports what was claimed, and where the 2B and the 3B disagree, Tables 8A to 8D are where the difference shows. See GSTR-2B and GSTR-3B: what the law lets you claim. Tax found short while preparing the return can be paid through DRC-03, to which the portal links after filing.

For FY 2025-26: Notification 05/2026

Notification 05/2026-Central Tax of 26 October 2026 amends the CGST Rules. Paragraphs 56 and 57 change the instructions to GSTR-9 and GSTR-9C by adding FY 2025-26 onwards to the years named against certain tables. In GSTR-9 the tables are 5D to 5F, 5H to 5K, 6B to 6D, 15, 16, 17 and 18; in GSTR-9C they are 5B to 5F, 5H to 5N and 14. The notification takes effect on 1 November 2026 under its general commencement clause.

The notification does not itself set out the relaxations. They sit in the instructions already printed in the forms, and the notification only extends the years to which they apply. Anyone relying on them for a table should read the instruction against that table, not this note.

Before 31 December

File every GSTR-1 and GSTR-3B for the year, or the forms will not open.
Tie Table 4 and Table 5 to the books, and Tables 6 to 8 to the 3B and the 2B.
Look at Tables 8D and 8C where the 2B and the 3B disagree, and settle them in the 3B for the year while that is still possible.
Decide at the start whether a 9C is needed, by aggregate turnover, and plan to file both on the same day.
Keep the explanation for any difference in the 9C, in the form, with the working behind it.

This note is general information drawn from the Act, the Rules, notifications and circulars as published on the CBIC and GST portals up to 10 November 2026. It is not advice on your matter, and it cites no decided case.

Questions this answers

Who has to file GSTR-9 for FY 2025-26?: Every registered person other than an Input Service Distributor, a person paying tax under section 51 or 52, a casual taxable person and a non-resident taxable person, under section 44 of the CGST Act and rule 80. A person whose aggregate turnover in the year is up to ₹2 crore is exempt under Notification 15/2025-Central Tax of 17 September 2025, which applies to FY 2024-25 and onwards. A person paying tax under section 10 is dealt with separately in rule 80 and is outside this note.
When is GSTR-9C required, and is it still an audit?: It is required where aggregate turnover exceeds ₹5 crore (rule 80(3)). It is no longer an audit or a certification by a chartered accountant. Since 1 August 2021 it is a self-certified reconciliation of the value of supplies declared in the returns with the audited annual financial statement.
What is the due date, and has it been extended?: 31 December 2026 for both, under rule 80(1) and (3). The portal enabled both forms for FY 2025-26 on 8 October 2026. We found no extension in the notifications and advisories we read; the date should be checked again before it is relied on.
How is the late fee worked out if the 9C is filed after the 9?: Section 47(2) charges the late fee for delay in the complete annual return, which the Board has said means both forms where the 9C is required (Circular 246/03/2025-GST). The fee runs from the due date until the later of the two filings and is not charged separately on each form. A 9 filed on time and a 9C filed seven days late costs seven days of late fee.

More practice notes

GSTR-2B and GSTR-3B: What the Law Lets You Claim, and the 30 November Cut-offSince 1 January 2022 the credit a recipient may take is the credit his GSTR-2B shows. The statute and the rule say so in terms, and the year-end adds two dates that fall in the next three weeks.
Tax Audit: Section 44AB Gives Way to Section 63, and the Penalty Becomes a FeeThe limits did not move when the Income-tax Act, 2025 replaced section 44AB with section 63. The consequence of default did, and the change matters more than the limits.
Cash Deposits and Section 69A: What the Tribunal RequiresNearly ten years on, the November 2016 deposits are still being decided - and the Tribunal does not agree with itself on whether the books must be rejected before section 69A can be invoked.

Holding one of these yourself?

Every assessment turns on its own record. A note like this one tells you what the tribunals have accepted; it cannot tell you whether your papers carry it. Bring the notice in before the reply is drafted, not after.

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