GSTR-9 and GSTR-9C for FY 2025-26: Due Date, Limits, Late Fee

The annual return in Form GSTR-9 for FY 2025-26 is due on 31 December 2026. Filing is optional for taxpayers whose aggregate turnover for the year is up to ₹2 crore, and the reconciliation statement in Form GSTR-9C must also be filed where aggregate turnover exceeds ₹5 crore. GSTN enabled both forms on the GST portal from 8 October 2026.

What has changed for the FY 2025-26 annual return?

In its advisory of 13 October 2026, GSTN announced that GSTR-9 and GSTR-9C for FY 2025-26 are available on the portal from 8 October 2026. The tile appears only after all GSTR-1 and GSTR-3B returns for April 2025 to March 2026 have been filed. If even one month is pending, the annual return cannot be started.

FY 2025-26 is also the year in which the new GST rate structure (5%, 18% and 40%) applied from 22 September 2025. Many businesses therefore have the same item taxed at two rates within one year, and the HSN summary and tax-wise tables in GSTR-9 need to reflect both periods correctly.

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

Section 44 of the CGST Act requires every registered person to file an annual return, other than the categories excluded by the law. In practice:

Taxpayer	GSTR-9 for FY 2025-26
Normal taxpayer, aggregate turnover above ₹2 crore	Mandatory
Normal taxpayer, aggregate turnover up to ₹2 crore	Optional (exempt)
SEZ unit or SEZ developer	Same as normal taxpayer
Registration cancelled during the year	Covered for the period it was active
Composition taxpayer	Not GSTR-9; separate annual return
Input Service Distributor, casual or non-resident taxable person, OIDAR supplier	Not required
TDS deductor (section 51) or e-commerce operator collecting TCS (section 52)	Not required

The ₹2 crore exemption comes from Notification No. 15/2025-Central Tax dated 17 September 2025, which applies to the annual return for FY 2024-25 and later years. Aggregate turnover is computed on an all-India PAN basis, so a business with several GST registrations must add the turnover of all of them before deciding whether it is under the limit.

When is GSTR-9C required?

Rule 80(3) of the CGST Rules requires a self-certified reconciliation statement in Form GSTR-9C where aggregate turnover for the year exceeds ₹5 crore. It is filed along with GSTR-9 by the same due date. GSTR-9C reconciles turnover, tax paid and input tax credit (ITC) reported in the returns with the audited financial statements, so the books for FY 2025-26 should be finalised before it is prepared.

Aggregate turnover in FY 2025-26	GSTR-9	GSTR-9C
Up to ₹2 crore	Optional	Not required
Above ₹2 crore up to ₹5 crore	Mandatory	Not required
Above ₹5 crore	Mandatory	Mandatory (self-certified)

What is the late fee for filing GSTR-9 late?

Late fee is levied under section 47(2) of the CGST Act. Notification No. 07/2023-Central Tax dated 31 March 2023 reduced the rates for smaller taxpayers from FY 2022-23 onwards. The CGST late fee is:

Aggregate turnover	CGST late fee per day	Maximum (CGST)
Up to ₹5 crore	₹25	0.02% of turnover in the State/UT
Above ₹5 crore up to ₹20 crore	₹50	0.02% of turnover in the State/UT
Above ₹20 crore	₹100	0.25% of turnover in the State/UT

An equal amount is levied under the State or Union territory GST law, so the combined late fee is double the CGST figure (for example, ₹50 per day for a taxpayer with turnover up to ₹5 crore).

Circular No. 246/03/2025-GST dated 30 January 2025 clarifies that where GSTR-9C is required, the annual return is complete only when both forms are filed. Late fee therefore runs from 31 December until the date on which the later of GSTR-9 and GSTR-9C is filed. The portal calculates it automatically.

Why should GSTR-9 not be filed before reviewing ITC?

Section 16(4) of the CGST Act allows ITC on an invoice of FY 2025-26 to be claimed only up to 30 November 2026 or the date of filing the annual return, whichever is earlier. If GSTR-9 is filed in, say, early November, any credit not yet claimed in GSTR-3B is lost from that date. Before filing, match purchase records with GSTR-2B and the Invoice Management System and claim any missed eligible credit by 30 November 2026.

How long can an old GSTR-9 still be filed?

From 1 October 2023, section 44(2) bars filing of an annual return after three years from its due date. For example, a return that was due on 31 December 2023 (the normal due date for FY 2022-23) cannot be filed after 31 December 2026 unless the Government allows it by notification. Taxpayers with pending annual returns of earlier years should complete them before the window closes. The three-year bar on GST returns applies to monthly returns as well.

What should be checked before filing GSTR-9?

1. All GSTR-1 and GSTR-3B for FY 2025-26 filed, otherwise the tile stays disabled.
2. Outward supplies: compare GSTR-1 (including GSTR-1A amendments) with the sales register and books, rate-wise for the periods before and after 22 September 2025.
3. ITC: reconcile GSTR-3B claims with GSTR-2B (auto-populated in Table 8A), reversals under rules 37, 37A, 42 and 43, and blocked credits.
4. Credit claimed in the next year: ITC of FY 2025-26 claimed between April and November 2026 is reported separately and not as current-year credit.
5. Short payment: any tax found unpaid can be declared in GSTR-9 and paid through Form DRC-03 with interest.
6. HSN summary: prepare HSN-wise outward and inward details as required for your turnover.
7. Audited accounts: where GSTR-9C applies, reconcile with the audited financial statements and explain differences.

Because GSTR-9 cannot be revised, careful reconciliation before submission matters more than early filing. Our page on GST returns sets out the return cycle in more detail.

The information in this article reflects the law as on the date of publication and is for general guidance only.

CA. Kunal Darwani

Frequently asked questions