Last updated: 26 August 2026. The GST annual return for FY 2025-26 is due on 31 December 2026. FORM GSTR-9 is compulsory for every regular registration whose PAN-level aggregate turnover for the year is more than ₹2 crore, and FORM GSTR-9C — the self-certified reconciliation statement — is added on top once that turnover exceeds ₹5 crore. Both go in on the same date, and since January 2025 a late GSTR-9C keeps the late fee running even where GSTR-9 was filed on time.
Applicability Note: This guide is based on GST provisions applicable as of 26 August 2026. Applicability turns on your own aggregate turnover figure for FY 2025-26 and on returns already filed against your GSTIN. Always verify the current position on gst.gov.in or with a GST professional before taking action.
Who Should Care?
This applies to:
- Regular GST registrations with FY 2025-26 turnover above ₹2 crore, who have a GSTR-9 to file whether or not they filed one last year
- Businesses that crossed ₹5 crore during FY 2025-26 and are in GSTR-9C territory for the first time
- Anyone holding several GSTINs on one PAN, because the turnover test is PAN-wide but the return is filed registration by registration
- Finance teams planning the December quarter, since GSTR-9 will not open until every GSTR-1 and GSTR-3B for the year is in
1. Who Files, and Who Is Left Out
Section 44 of the CGST Act and Rule 80 of the CGST Rules decide this between them. Rule 80(1) of the CGST Rules requires the annual return in FORM GSTR-9 from every registered person on or before 31 December following the end of the financial year, and then names the categories that sit outside it. Rule 80(3) adds FORM GSTR-9C for anyone whose aggregate turnover during the year exceeds ₹5 crore. Above both, the first proviso to Section 44(1) of the CGST Act gives the Commissioner power to exempt a class of registered persons — and that is the power the ₹2 crore exemption is issued under.
| You are | FY 2025-26 position |
|---|---|
| Regular taxpayer, aggregate turnover up to ₹2 crore | Exempt from GSTR-9 under Notification No. 15/2025-Central Tax |
| Regular taxpayer, turnover above ₹2 crore and up to ₹5 crore | GSTR-9 only |
| Regular taxpayer, turnover exceeding ₹5 crore | GSTR-9 and GSTR-9C, both by 31 December 2026 |
| Composition taxpayer under Section 10 | Outside GSTR-9 — the proviso to Rule 80(1) names FORM GSTR-9A, but the composition annual return is GSTR-4 under Rule 62, filed by 30 June |
| Input Service Distributor, TDS deductor (Section 51), TCS collector (Section 52), casual taxable person, non-resident taxable person, and government departments and local authorities audited by the CAG (second proviso to Section 44) | Excluded from both GSTR-9 and GSTR-9C by Rule 80(1) and Rule 80(3) |
| E-commerce operator collecting TCS under Section 52 | Rule 80(2) provides for an annual statement in FORM GSTR-9B |
The ₹2 crore exemption is Notification No. 15/2025-Central Tax dated 17 September 2025, issued under the first proviso to Section 44(1). It exempts registered persons whose aggregate turnover in a financial year is up to ₹2 crore from filing the annual return, for FY 2024-25 and onwards. That "and onwards" matters. Unlike the year-by-year notifications that preceded it, this one is standing, so FY 2025-26 does not wait on a fresh notification each July.
If you are a composition dealer reading this, your annual filing is the one that already went in on 30 June — see the guide to the GSTR-4 annual return.
2. Both Thresholds Read From One PAN-Wide Turnover Figure
Aggregate turnover is computed across every registration on your PAN, all-India. It is the same figure that decided your QRMP eligibility for the coming quarter, and for FY 2025-26 the window to have it amended closed at the end of July. The AATO amendment window ran from 1 to 31 July 2026, with jurisdictional officer review from 1 to 15 August 2026, per the GSTN advisory dated 1 July 2026. Whatever your dashboard shows now is the figure the portal will work from, and you can no longer amend it — but the statutory test in Section 44 and Rule 80 is your actual aggregate turnover for FY 2025-26 as defined in Section 2(6). Where the two differ, the law follows the turnover, not the dashboard.
Two details catch people out. First, the tests are PAN-level but the return is not: GSTR-9 is filed GSTIN by GSTIN, so a PAN at ₹6 crore with three registrations files three GSTR-9s and three GSTR-9Cs, even where one of those branches turned over ₹40 lakh. Second, Rule 80(3) says exceeds five crore rupees. A turnover of exactly ₹5 crore sits below the GSTR-9C line, not on it.
3. What the Two Forms Actually Reconcile
GSTR-9 is a consolidation, not a fresh return. Most of it is auto-populated from what you already filed, which is why the portal will not enable GSTR-9 or GSTR-9C for FY 2025-26 until every GSTR-1 and GSTR-3B for the year has been filed. Outward supplies in Tables 4 and 5 come from GSTR-1, GSTR-1A and the IFF; tax paid in Table 9 comes from GSTR-3B; and the credit side comes from two different places, which is where the real work lives.
Table 8A of GSTR-9 is populated from GSTR-2B, not from your books and not from GSTR-2A. It picks up the documents of the year that appeared in that year's GSTR-2B, adds invoices of the year that surfaced in the next year's GSTR-2B up to October, and drops the previous year's invoices that landed in your April-to-October statements. Source: GSTN's Consolidated FAQ on GSTR-9/9C for FY 2024-25 dated 17 December 2025.
Table 8A against Table 8B is the comparison a reviewer reads first, so the reconciliation you should have been running monthly is the one that decides how painful December is. If you have been reconciling GSTR-2B before filing GSTR-3B each month, Table 8D lands close to nil. If not, twelve months of drift shows up at once.
The other trap is credit that crosses the year boundary. ITC of FY 2025-26 that you availed in FY 2026-27 goes in Table 8C and Table 13, not in Table 6. ITC of FY 2024-25 that you claimed during FY 2025-26 belongs in Table 6A1, which exists so that earlier-year credit stops distorting Table 6J. And credit reversed under Rule 37 or 37A and later reclaimed counts as credit of the year in which it was reclaimed — it goes in Table 6H of that year's GSTR-9, which is worth reading next to the reversal-and-reclaim rules in Table 4 of GSTR-3B.
GSTR-9C then reconciles the turnover and the tax in GSTR-9 against your audited annual financial statements, and asks you to explain the gaps. Since 1 August 2021 it is self-certified: section 110 of the Finance Act, 2021 omitted the old Section 35(5) audit requirement and section 111 substituted Section 44 to allow a self-certified reconciliation statement, both brought into force on that date by Notification No. 29/2021-Central Tax dated 30 July 2021.
4. FY 2025-26 Is the Year the Rates Changed Mid-Stream
One thing makes this annual return different from last year's. The GST 2.0 rate restructure took effect on 22 September 2025, which falls inside FY 2025-26. Your outward supplies for the year were therefore taxed under two rate structures: the old slabs until 21 September 2025, the restructured ones from 22 September.
That surfaces in the HSN-wise summary at Table 17 of GSTR-9, which reports supplies by HSN and by rate. Expect the same HSN to appear on two rows at two different rates for the year, and expect your rate-wise totals to reconcile only when both halves of the year are picked up. Do not collapse them into one line to make the table tidier.
5. What 31 December 2026 Costs If You Miss It
Section 47(2) of the CGST Act is the charging provision: ₹100 per day per Act for as long as the failure continues, subject to a maximum of 0.25% of turnover in the State or Union territory per Act. That base figure is not what most taxpayers pay, because Notification No. 07/2023-Central Tax dated 31 March 2023 reduced it for FY 2022-23 onwards, on a turnover slab.
| Aggregate turnover, FY 2025-26 | Late fee per day (CGST + SGST) | Maximum |
|---|---|---|
| Up to ₹5 crore | ₹50 | 0.04% of turnover in the State/UT |
| More than ₹5 crore, up to ₹20 crore | ₹100 | 0.04% of turnover in the State/UT |
| More than ₹20 crore | ₹200 | 0.5% of turnover in the State/UT |
Every figure in that table is a CGST + SGST total; the per-Act figure is half of each. Note also that the cap is measured on turnover in the State or Union territory for that registration, while the slab you fall into is set by your PAN-level aggregate turnover. Two different bases in one calculation.
The part that surprises people is what "the annual return" means here. Circular No. 246/03/2025-GST dated 30 January 2025 settled it: where GSTR-9C is required, furnishing the annual return "may not be said to be complete, unless both return in FORM GSTR-9 and reconciliation statement in FORM GSTR-9C are furnished". The Section 47(2) fee therefore runs until both are in. GSTN gave that effect in the form itself, inserting a new Table 17 in GSTR-9C, "Late Fee Payable and Paid", below Part V, with the portal computing the amount: the fee runs from the due date to the date GSTR-9 is filed, then from the later of the due date or the GSTR-9 filing date until GSTR-9C is filed.
Worked example. A registration with FY 2025-26 aggregate turnover of ₹8 crore files GSTR-9 on 15 January 2027 and GSTR-9C on 25 January 2027. Its slab is ₹100 per day. GSTR-9 is 15 days late (1 to 15 January), which is ₹1,500, paid with GSTR-9. GSTR-9C adds the next 10 days (16 to 25 January), which is ₹1,000, auto-populated in Table 17 of GSTR-9C. Total ₹2,500 for 25 days — under the 0.04% cap unless turnover in that State is very small.
6. Three Years Is the Outer Limit, Not 31 December
Missing 31 December 2026 costs a late fee. It does not shut the door, but the door does shut eventually. Section 44(2) of the CGST Act, inserted by section 144 of the Finance Act, 2023 with effect from 1 October 2023, provides that a registered person "shall not be allowed to furnish an annual return under sub-section (1) for a financial year after the expiry of a period of three years from the due date". For FY 2025-26 that runs out on 31 December 2029.
The bar is not absolute. The proviso to Section 44(2) lets the Government, on the Council's recommendations, allow a registered person or a class of registered persons to file even after the three years, subject to conditions. But that is a relaxation someone else has to grant, and the late fee has been running the whole time.
Not sure which of the two forms your registration actually owes for FY 2025-26? Ask a question and we will look at your turnover figure with you.
Key Takeaways
- 31 December 2026 is the due date for both GSTR-9 and GSTR-9C for FY 2025-26, under Rule 80(1) and Rule 80(3).
- GSTR-9 is compulsory above ₹2 crore PAN-level aggregate turnover; the exemption up to ₹2 crore is standing from FY 2024-25 onwards under Notification No. 15/2025-Central Tax dated 17 September 2025.
- GSTR-9C is added where turnover exceeds ₹5 crore — exactly ₹5 crore is below the line — and has been self-certified since 1 August 2021.
- Both forms are filed GSTIN by GSTIN even though the thresholds are tested PAN-wide.
- Table 8A of GSTR-9 draws from GSTR-2B, so a year of unreconciled credit surfaces in Table 8D in one go.
- A late GSTR-9C keeps the Section 47(2) fee running per Circular No. 246/03/2025-GST — one fee on the complete annual return, not two — with the balance computed in Table 17 of GSTR-9C, even where GSTR-9 was on time.
Frequently Asked Questions
What is the GSTR-9 due date for FY 2025-26?
31 December 2026, under Rule 80(1) of the CGST Rules. GSTR-9C, where required, is due on the same date under Rule 80(3).
Is GSTR-9 mandatory if my turnover is below ₹2 crore?
No. Notification No. 15/2025-Central Tax dated 17 September 2025, issued under the first proviso to Section 44(1), exempts registered persons with aggregate turnover up to ₹2 crore in a financial year from filing the annual return, for FY 2024-25 and onwards.
Do I have to file GSTR-9C if my turnover is exactly ₹5 crore?
No. Rule 80(3) applies where aggregate turnover during the financial year exceeds five crore rupees, so ₹5 crore exactly falls below that requirement. You would still file GSTR-9, since ₹5 crore is above the ₹2 crore exemption.
What is the late fee if I file GSTR-9 after 31 December 2026?
Under Notification No. 07/2023-Central Tax dated 31 March 2023, ₹50 per day (CGST + SGST) capped at 0.04% of turnover in the State or Union territory where aggregate turnover is up to ₹5 crore, and ₹100 per day on the same cap where it is more than ₹5 crore and up to ₹20 crore. Above ₹20 crore there is no reduction and Section 47(2) applies in full — ₹200 per day, capped at 0.5% of turnover in the State or Union territory.
Can I still file GSTR-9 for an old year I never filed?
Only within three years of the original due date. Section 44(2) of the CGST Act, inserted with effect from 1 October 2023, bars an annual return furnished after that period, unless the Government allows it under the proviso to that sub-section.
Disclaimer: This article is for informational purposes only and does not constitute professional tax advice. GST rules are subject to frequent changes through notifications and circulars. Please consult a qualified tax professional or verify the current provisions on the official GST portal (gst.gov.in) before making any compliance decisions.
Have a specific question about your GSTR-9 or GSTR-9C for FY 2025-26? Our GST experts can help → gstconsultancy.com