GST Annual Return Guide for FY 2025-26

Last updated: 23 October 2026. Reference period: 1 April 2025 to 31 March 2026.

Quick Answer: The GST annual return for FY 2025-26, Form GSTR-9, is due by 31 December 2026. The GSTR-9 turnover limit is ₹2 crore of aggregate turnover, tested across all registrations under one PAN. Above ₹5 crore, a self-certified GSTR-9C reconciliation statement is also filed, and the late fee runs until both forms are filed.

This guide covers GSTR-9 and GSTR-9C for FY 2025-26: applicability, turnover limits, late fees and filing precautions.

What are GSTR-9 and GSTR-9C?

GSTR-9 is the annual return under section 44 of the CGST Act, 2017, read with rule 80 of the CGST Rules, 2017. It provides a comprehensive year-end consolidation of a taxpayer's GST transactions for a particular GSTIN, encompassing details of outward supplies, inward supplies, input tax credit (ITC), and tax discharged, as reported in the periodic returns filed during the relevant financial year, namely GSTR-1 and GSTR-3B.

While GSTR-9 provides an annual summary of GST transactions, GSTR-9C serves as the accompanying reconciliation statement for specified taxpayers. Its primary objective is to ensure consistency between the figures reported in the annual return and those disclosed in the entity's annual financial statements. Accordingly, it requires a reconciliation of turnover, tax liability, and input tax credit (ITC), along with explanations for any material differences. Notably, from FY 2020-21 onwards, GSTR-9C is required to be self-certified by the taxpayer, and the requirement for certification by a Chartered Accountant or Cost Accountant has been dispensed with.

What is the GSTR-9 applicability and turnover threshold?

Filing of GSTR-9 and GSTR-9C is not mandatory for all registered persons. The applicability depends upon the aggregate turnover of the taxpayer and the category of registration.

The old rule (before August 2021)

Before 1 August 2021, taxpayers with aggregate turnover exceeding ₹2 crore were required to get their accounts audited by a Chartered Accountant or Cost Accountant and furnish a certified reconciliation statement in Form GSTR-9C under Section 35(5) of the CGST Act. This requirement was popularly known as the "GST audit" and gave rise to the widely recognised ₹2 crore GST audit threshold.

Legislative changes effective from 1 August 2021

The government through the Finance Act, 2021 removed section 35(5) of the CGST Act. The change took effect from 1 August 2021. The following two notifications were issued:

1. Notification 29/2021-CT (30 July 2021): Brought into force the omission of section 35(5), which abolished the mandatory GST audit by a CA or CMA, and the substituted Section 44, which allows taxpayers to submit a self-certified reconciliation statement.
2. Notification 30/2021-CT (30 July 2021): Overhauled Rule 80 completely and introduced the limit of ₹5 crore for filing GSTR-9C.

The shift from auditor-certified GSTR-9C to self-certification places substantially greater responsibility upon management. Any inconsistency between financial statements, GST returns and reconciliation workings can be examined by the department during audit, scrutiny or assessment proceedings.

Current compliance position

While the turnover thresholds of ₹2 crore and ₹5 crore continue to remain relevant, their significance has changed following the amendments introduced by the Finance Act, 2021.

Important note

"No mandatory GST audit" does not mean "no checking." The GST department can still audit any registered business under section 65. So numbers must still be correct, because taxpayers are now vouching for themselves.

Specific exemption

Section 44 and Rule 80 exclude Input Service Distributors, persons deducting or collecting tax under sections 51 and 52, casual taxable persons and non-resident taxable persons from both forms. Section 44 also does not apply to departments of the Central or a State Government, or local authorities, whose books of account are audited by the Comptroller and Auditor General of India or an auditor appointed for local authorities.

GSTR-9 and GSTR-9C applicability for FY 2025-26

The ₹2 crore exemption from GSTR-9 comes from Notification 15/2025-Central Tax dated 17 September 2025, which applies from FY 2024-25 onwards.

How is aggregate turnover computed?

Section 2(6) of the CGST Act defines aggregate turnover as the PAN-India value of taxable supplies, exempt supplies, exports and inter-State supplies of every registration under the same PAN, excluding GST, inward supplies on which tax is paid by the company under reverse charge (RCM), and cess. Three points change the result:

1. PAN-level total. A company with registrations in several states adds up every registration's turnover. This changes the entire basis of the applicability of the annual return, because there could be a situation where a particular GSTIN, or every GSTIN, does not cross the threshold limit individually, but when combined on a PAN-India basis, filing of the annual return becomes applicable.
2. Exempt supplies and exports count. Zero-rated exports and exempt sales are added to taxable sales, so an exporter can cross ₹5 crore sooner than its domestic sales suggest.
3. Reverse charge purchases are left out. Inward supplies on which the company pays tax under reverse charge are excluded.

Though applicability is considered on a PAN-level basis, GSTR-9 is to be filed for each GSTIN separately, reporting the figures of that GSTIN, because section 25(4) treats every registration of the company as a distinct person.

Illustration: A company having three GST registrations with turnovers of ₹1.75 crore, ₹1.80 crore and ₹2.10 crore respectively would have an aggregate turnover of ₹5.65 crore on a PAN basis. Accordingly, GSTR-9 and GSTR-9C would become applicable for all registrations, notwithstanding that none of the GSTINs individually crosses ₹5 crore.

What is the GSTR-9 due date and other important dates?

These dates sit alongside the other year-end filings in the annual compliance package for a private limited company.

What changed from FY 2024-25 onwards?

Form GSTR-9 has undergone significant changes from FY 2024-25 pursuant to Notification No. 13/2025-Central Tax, dated 17 September 2025, particularly in relation to reporting and reconciliation of Input Tax Credit (ITC). The revised format introduces separate disclosures for prior-year ITC claimed in the current year, detailed reporting of ITC reversals and reclaims, enhanced reporting of import-related credits, and greater alignment with GSTR-3B and GSTR-2B. These amendments are intended to improve transparency and strengthen data validation by the tax authorities.

While these changes enhance the quality of GST reporting, they also require taxpayers to undertake more detailed reconciliations and maintain robust documentation. Consequently, the annual return has evolved from being a simple summary statement into a comprehensive year-end reconciliation exercise.

Key challenges faced by taxpayers due to the revamping of GSTR-9:

1. Complexities in cross-year ITC tracking. Taxpayers must separately identify and report prior-year ITC claimed, reversed, or reclaimed during the current financial year. This requires careful tracking of historical records and increases reconciliation efforts.
2. Increased reconciliation and verification burden. Greater alignment between GSTR-9, GSTR-3B, and GSTR-2B necessitates detailed reconciliation to identify and resolve discrepancies. This increases the time and effort required for annual return preparation.
3. Detailed reporting of ITC reversals and reclaims. Separate reporting of ITC reversals and reclaims under relevant statutory provisions requires provision-wise classification and adequate documentation. Taxpayers must maintain systematic records and strengthen internal controls.
4. Increased risk of reporting errors. Additional reporting fields and detailed classifications increase the risk of inadvertent errors, particularly for businesses with high transaction volumes or multiple GST registrations. Such discrepancies may lead to further scrutiny and clarification requirements.

What are the GSTR-9 late fee, interest and consequences of non-compliance?

Late fees

Section 47(2) governs the levy of late fee for non-filing or delayed filing of the annual return. The amount is calculated at ₹100 per day under each Act, from the due date of filing of the return till the annual return is filed, with a maximum cap.

Notification 07/2023-Central Tax dated 31 March 2023 has rationalised the late fee for smaller taxpayers. We have provided below a tabulated summary of late fees based on the turnover:

*The maximum cap of late fee is calculated on the turnover of the GSTIN for which the annual return is being filed, not on PAN-level turnover.

Illustration: A company with ₹10 crore turnover in a State files 30 days late. The late fee under section 47(2), read with Notification 07/2023-CT, is 30 x ₹100 = ₹3,000, which is below the cap of 0.04% x ₹10 crore = ₹40,000.

Point to be noted: Circular 246/03/2025-GST dated 30 January 2025 treats the annual return as complete only when both forms are filed, i.e., GSTR-9 and GSTR-9C (wherever applicable). The late fee therefore runs until GSTR-9C is filed, and is not charged separately for each form.

Illustration: Filing GSTR-9 in December and GSTR-9C in January will therefore cost a late fee from the due date of filing of the return till the date when GSTR-9C is filed.

Interest

Levy of interest is governed by Section 50 of the CGST Act, which prescribes a rate of 18% per annum on the tax paid late, under each of the CGST, SGST and IGST Acts, and is calculated from the day after the due date of payment of tax till the date of payment.

It means that even if the annual return has been filed within the timeline, but the taxpayer has declared any additional outward supply on which tax was to be paid during the financial year for which the annual return is filed, interest would still be required to be paid. Where additional tax liability pertaining to FY 2025-26 is identified during annual reconciliation and discharged subsequently, interest under section 50 may become payable. Taxpayers should evaluate the nature of the liability and the mode of discharge while determining the applicable interest implications.

Practical Precautions and Key Reconciliations Before Filing

Key reconciliations:

• Books vs GSTR-1 turnover
• Books vs GSTR-3B liability
• GSTR-2B vs ITC availed
• E-invoice turnover vs return turnover
• E-way bill turnover vs outward supplies
• DRC-03 payments vs annual return disclosures

Precautions:

1. File every GSTR-1 and GSTR-3B first. The annual return tile does not open until all returns for FY 2025-26 are filed on the GSTIN.
2. Claim ITC before 30 November 2026. After that date, ITC of FY 2025-26 cannot be claimed.
3. Reconcile before you file. Tally books with GSTR-1, GSTR-3B, GSTR-2B, e-way bills and the e-invoice data. Differences are visible to the department.
4. Do not force tables to zero. A real difference, such as previous-year ITC, should be documented rather than adjusted in unrelated rows.
5. Pay short-paid tax before filing. Use Form GST DRC-03 for tax missed in GSTR-3B, with interest.
6. Test turnover at PAN level. A depot in another state can take the company above ₹5 crore even when each registration is below it.
7. Check HSN-wise details and rate splits. FY 2025-26 covers two rate structures because of the rate changes effective 22 September 2025.
8. Remember there is no revision. No revision is allowed after GSTR-9 is filed, so preview the draft, download the summary, and file only when you are fully ready.
9. File GSTR-9 and GSTR-9C together. Late fee runs until both are filed, so do not leave GSTR-9C for a later month.
10. Use the right signatory. File through the authorised signatory with a DSC (mandatory for companies under rule 26 of the CGST Rules) or EVC where allowed, and keep a signed working file.
11. Do not wait for an extension. Earlier years had extensions, but none has been notified for FY 2025-26.

Key Takeaways

• GSTR-9 is exempt where aggregate turnover does not exceed ₹2 crore.
• GSTR-9C is mandatory where aggregate turnover exceeds ₹5 crore.
• GSTR-9C continues to be self-certified by the taxpayer.
• Due date for filing GSTR-9 and GSTR-9C is 31 December 2026.
• No revision can be made after filing.

Plan your GST compliance review before 31 December 2026

A GST compliance review before filing helps you catch ITC mismatches, Table 6 differences and turnover errors while the 30 November ITC window is still open. Given the enhanced disclosure requirements and reconciliation obligations, taxpayers may benefit from undertaking a comprehensive GST annual compliance review prior to filing GSTR-9 and GSTR-9C. Such a review can help identify reporting gaps, ITC inconsistencies and turnover mismatches before the filing deadline.

To scope a review before your FY 2025-26 annual return is filed, leave your details on the contact page and the HSAG Consulting team will contact you.

Disclaimer: This blog is general information and not legal or tax advice. Check the latest notifications, circulars and GSTN advisories before filing.