GSTR-9 and GSTR-9C for FY 2025-26
Who has to file the GST annual return and reconciliation statement for FY 2025-26, the 31 December 2026 due date, the late fee, the input tax credit cut-off and the checks to run before filing.
Published by SKAG and Associates · Page maintained by CA Gaurav Singh (ICAI M.No. 539050) · Last updated: 30 October 2026
Note: General information on the law as at 30 October 2026. Check the current notifications on cbic-gst.gov.in and the advisories on gst.gov.in before filing; this is not a substitute for professional advice.
The annual return brings together a year’s GSTR-1 and GSTR-3B figures, the input tax credit claimed, and the tax paid, and it is the last chance to report what was missed in the monthly or quarterly returns. GSTN made the FY 2025-26 forms available on the portal in October 2026 and asked taxpayers to complete all GSTR-1 and GSTR-3B returns for the year first, because the annual return cannot be filed until they are in.
Who files what for FY 2025-26
| Aggregate turnover in FY 2025-26 | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to ₹2 crore | Optional | Not required |
| Above ₹2 crore, up to ₹5 crore | Required | Not required |
| Above ₹5 crore | Required | Required (self-certified) |
Aggregate turnover is computed on an all-India PAN basis, across every GSTIN under the same PAN. Input Service Distributors, TDS and TCS registrants, casual and non-resident taxable persons do not file GSTR-9; composition taxpayers file GSTR-4. Confirm the text of Notification 15/2025-Central Tax on cbic-gst.gov.in.
Checks to run before filing
- Outward supplies (Tables 4 and 5): match the books with GSTR-1 and GSTR-3B, including amendments and credit notes made in FY 2026-27 for FY 2025-26 supplies (Part V).
- Input tax credit (Tables 6 and 8): compare the ITC in GSTR-3B with Table 8A, which is drawn from GSTR-2B. Explain the gap and reverse ineligible credit.
- ITC claimed in FY 2026-27 for FY 2025-26 invoices: report it in Table 8C and Part V. The last date to claim it is 30 November 2026 or the date of filing GSTR-9, whichever is earlier (Section 16(4)). Filing GSTR-9 early closes the window.
- Tax shortfall: pay any short-paid tax through Form DRC-03 with interest before filing, and report it in Table 14.
- HSN summary (Tables 17 and 18): check the HSN codes and quantities against the books.
- GSTR-9C (above ₹5 crore): reconcile turnover, tax and ITC with the audited financial statements and explain each difference.
GSTR-9 cannot be revised once filed, so these checks matter more than speed. The return is filed on the GST portal under Returns → Annual Return, with GSTR-9C filed after GSTR-9 where it applies.
Late fee
Section 47(2) of the CGST Act charges a late fee for each day the annual return is late. Notification 07/2023-Central Tax reduced it for FY 2022-23 onwards. CBIC Circular 246/03/2025-GST clarifies that where GSTR-9C is required, the return is complete only when both forms are filed, so the fee runs until GSTR-9C is in. No interest is charged on the annual return itself, because it carries no tax payment.
| Aggregate turnover | Late fee per day (CGST + SGST) | Maximum |
|---|---|---|
| Up to ₹5 crore | ₹50 | 0.04% of turnover in the State |
| Above ₹5 crore, up to ₹20 crore | ₹100 | 0.04% of turnover in the State |
| Above ₹20 crore | ₹200 | 0.5% of turnover in the State |
Rates as reduced by Notification 07/2023-Central Tax dated 31 March 2023 (CGST ₹25 or ₹50 a day, capped at 0.02% of turnover in the State, with an equal SGST amount). Above ₹20 crore the full amount under Section 47(2) applies.
Worked examples
1. A Delhi trader with ₹3.4 crore turnover. GSTR-9 is required, but not GSTR-9C. If it is filed on 15 January 2027, it is 15 days late: 15 × ₹50 = ₹750. The cap of 0.04% of ₹3.4 crore is ₹13,600, so the fee is ₹750.
2. A manufacturer with ₹6 crore turnover. Both GSTR-9 and GSTR-9C are required. GSTR-9 is filed on 28 December 2026, but GSTR-9C only on 9 February 2027. The return is complete only on 9 February, so the fee runs for 40 days: 40 × ₹100 = ₹4,000 (cap: 0.04% of ₹6 crore = ₹24,000).
The GST late fee calculator works out the fee and cap for any filing date, and the GST due-date calendar lists the other returns due this quarter.
Frequently Asked Questions
What is the due date for GSTR-9 for FY 2025-26?
GSTR-9, and GSTR-9C where required, for FY 2025-26 are due by 31 December 2026 under Section 44 of the CGST Act and Rule 80 of the CGST Rules. No extension had been announced as at 30 October 2026.
Is GSTR-9 compulsory for turnover up to ₹2 crore?
No. Notification 15/2025-Central Tax dated 17 September 2025 exempts registered persons whose aggregate turnover in the financial year is up to ₹2 crore from filing the annual return, from FY 2024-25 onwards. Such taxpayers may still file it voluntarily.
Who must file GSTR-9C for FY 2025-26?
A registered person whose aggregate turnover for the financial year exceeds ₹5 crore must file GSTR-9C, a self-certified reconciliation statement between the annual return and the audited financial statements, along with GSTR-9 (Rule 80(3)). Since 1 August 2021 it does not need certification by a Chartered Accountant or Cost Accountant.
What is the late fee for GSTR-9?
For FY 2022-23 onwards the late fee is ₹50 a day (₹25 CGST and ₹25 SGST) for aggregate turnover up to ₹5 crore and ₹100 a day for ₹5 crore to ₹20 crore, capped at 0.04% of turnover in the State, and ₹200 a day capped at 0.5% above ₹20 crore (Notification 07/2023-Central Tax). Where GSTR-9C is required, the fee runs until both are filed.
Who does not file GSTR-9?
Input Service Distributors, persons deducting or collecting tax at source under Sections 51 and 52, casual taxable persons and non-resident taxable persons do not file GSTR-9. Composition taxpayers file the annual return in GSTR-4 instead.
Can GSTR-9 be revised after filing?
No. There is no facility to revise GSTR-9 once filed. Tax found short while preparing it can be paid through Form DRC-03 with interest, and further input tax credit for FY 2025-26 cannot be claimed after 30 November 2026 or the date the annual return is filed, whichever is earlier.