GSTR-9 and GSTR-9C for FY 2025-26: Who Must File, the 31 December Due Date and Late Fees

GST | RegisCorp Team

Checked on 24 October 2026. The GST annual return for FY 2025-26 is now open on the portal, and the normal due date is 31 December 2026. For many small businesses the answer is simple: if your aggregate turnover was Rs 2 crore or less, you do not have to file it. For everyone above that, the return is a one-time reconciliation that cannot be revised once filed, which makes the preparation more important than the filing. This post explains who has to file GSTR-9 and the reconciliation statement GSTR-9C, what the portal needs from you first, how the late fee works, what to reconcile before you file, and where the sources we read disagree. It does not replace your accountant. It tells you what to ask for.

RegisCorp Consultancy LLP is a digital-first legal and compliance firm in Kota, Rajasthan, working with businesses across India. We write these guides so you can check the rules before you pay anyone, including us.

Key takeaways

• Due date: 31 December 2026, for FY 2025-26 (1 April 2025 to 31 March 2026), unless the Government extends it. One page lists an extension as "TBD", which means undecided, not announced.
• Turnover up to Rs 2 crore: exempt. Several pages cite Notification No. 15/2025-Central Tax dated 17 September 2025. Filing is optional.
• Above Rs 2 crore: GSTR-9 is needed. Above Rs 5 crore, a self-certified GSTR-9C is also needed. One page says the certification was earlier done by a chartered accountant or cost accountant and is now self-certified.
• The form was reported open from 8 October 2026. The GST Network advised that all GSTR-1 and GSTR-3B returns for FY 2025-26 must be filed first, or the tile for the annual return will not show.
• One shot only. Pages say GSTR-9 cannot be revised after filing. Reconcile first.
• The late fee is reported at Rs 50 a day for turnover up to Rs 5 crore, Rs 100 a day for Rs 5 to 20 crore and Rs 200 a day above Rs 20 crore, with caps based on state turnover. One page gives a different figure of Rs 200 a day for everyone, so check the notification.
• Missed input tax credit cannot be added in the annual return. Pages say it must go through a later monthly return, subject to the time cut-off. The cut-off for FY 2025-26 credit is reported as 30 November 2026, or the date you file the annual return, whichever is earlier.
• Extra tax can be paid through Form DRC-03 before filing, according to one page, and interest at 18 percent a year applies to tax paid late.

The key numbers and dates in one place

Step 1: do you have to file at all

The turnover test uses your aggregate turnover for the financial year, across all your registrations under one PAN. Compare it with the three bands below.

1. Up to Rs 2 crore. You are exempt, according to pages citing Notification 15/2025-Central Tax. Filing is optional. Some taxpayers file anyway to put their figures on record.
2. Above Rs 2 crore and up to Rs 5 crore. You need GSTR-9. You do not need GSTR-9C.
3. Above Rs 5 crore. You need both GSTR-9 and a self-certified GSTR-9C.

If you are in the first band, check also that you are a regular taxpayer. One page says GSTR-9A, the form for composition taxpayers, has been discontinued and that composition taxpayers file a different return. We could not confirm the details.

What counts as turnover

Use your aggregate turnover, not just your sales. It includes taxable supplies, exempt supplies and exports, but excludes tax itself. Our post on GST return due dates and late fees explains the monthly and quarterly returns that feed into it. If you registered during the year, count only from the date you registered. Our post on GST registration covers who has to register and when.

Step 2: get the monthly returns right first

The portal asks for something before it shows the form. GSTN is reported to have said that all GSTR-1 and GSTR-3B returns for FY 2025-26 must be filed to enable the tile for GSTR-9 and GSTR-9C. If you cannot see the form, look first for a missing month or quarter. The annual return then pre-fills many tables from what you filed, which means any error in the monthly returns will show up again.

Typical gaps to look for:

• A GSTR-1 filed for a month but no GSTR-3B for the same month.
• A quarterly filer who missed the last quarter, January to March 2026.
• Amendments to earlier invoices that were not reported in time.
• Credit notes issued after the year end that were not adjusted.

Step 3: reconcile before you file

The common source of trouble is a mismatch between your books and the returns. Pages advise comparing the following.

1. Sales register against GSTR-1 and GSTR-3B. Include credit and debit notes. Differences are usually timing or a missed invoice.
2. Purchase register against GSTR-2B. Match supplier by supplier. Credit that you claimed in GSTR-3B but that does not appear in GSTR-2B has to be explained.
3. Reverse charge. Tax that you paid under reverse charge should match between the annual return and the monthly return.
4. Blocked and reversed credit. Ineligible credit under the blocked-credit list, and proportionate reversals where you make both taxable and exempt supplies, go in the reversal tables.
5. HSN summary. One page says the digit level depends on turnover, four digits up to Rs 5 crore and six digits above.
6. Turnover against your income-tax records. Pages advise that the turnover in the GST annual return should be consistent with your books and your income-tax return.

The tables people stumble over

Pages describe the structure like this. Tables 4 and 5 cover outward supplies. Table 6 covers credit availed as reported in GSTR-3B. Table 7 covers reversals. Table 8 compares credit with GSTR-2B: 8A is auto-filled from GSTR-2B, and one page says credit claimed in GSTR-3B but not shown in GSTR-2B has to be explained. Table 9 covers tax paid. We could not check these against the form. One page we read contradicts itself on what Table 8C means, so check the form's own instructions.

Rate changes during the year

One page says the HSN and rate-wise data cover two rate structures, effective from 22 September 2025. If your goods or services moved between rates in the year, make sure each invoice sits in the right rate bucket. A mistake here is hard to correct afterwards, because the return cannot be revised.

Step 4: file, pay and keep the record

1. File GSTR-9 with the reconciled figures. Do not accept pre-filled values without checking them.
2. If extra tax is due, one page says to pay it through Form DRC-03 before filing and enter the challan in the payment table. Interest at 18 percent a year applies to tax paid late.
3. If you are above Rs 5 crore, upload GSTR-9C after the GSTR-9 data is ready. It reconciles your audited financial statements with GSTR-9. It is reported as self-certified.
4. Download the filed return and keep it with your working papers.

What you cannot do in the annual return

• You cannot add credit that you forgot to claim. One page says missed credit has to be claimed through a later monthly GSTR-3B, within the time limit.
• You cannot revise a filed GSTR-9.
• You cannot ignore the credit cut-off. A page reports 30 November 2026, or the date you file the annual return, whichever is earlier, as the last date to claim credit for FY 2025-26.

Late fee: what the sources say and where they differ

A late fee applies if you file after 31 December 2026 and no extension has been granted. This is the area where the sources we read disagree.

• One page (dated 12 October 2026) gives a table: Rs 50 a day up to Rs 5 crore, Rs 100 a day for Rs 5 to 20 crore, and Rs 200 a day above Rs 20 crore, with caps of 0.04 percent of state turnover for the first two bands and 0.50 percent for the top band. It says this follows a CBIC notification, number 07/2023, from FY 2022-23.
• A second page (dated 10 July 2026) gives a flat Rs 200 a day for GSTR-9 and for GSTR-9C, capped at 0.25 percent of state turnover.
• A third page (dated 12 October 2026) gives Rs 50, Rs 100 and Rs 200 per day by turnover band, matching the first.

We think the tiered table is more likely to be the current rule, because two pages agree and one cites a notification number. We could not open the notification. Treat any figure as an estimate and check before you rely on it. One of the pages we read also contains an arithmetic slip in a worked example, which is a reason to check the numbers yourself.

A worked example: late by two months

A business with turnover of Rs 3 crore files its GSTR-9 on 28 February 2027, which is 59 days late. On the tiered table, the daily rate is Rs 50, so the fee is about Rs 2,950 (59 times Rs 50). The cap, 0.04 percent of state turnover, would be about Rs 12,000 if state turnover is Rs 3 crore. The fee is below the cap. On the flat Rs 200 table, the same delay would cost Rs 11,800, with a cap of Rs 75,000 at 0.25 percent. The gap between the two readings is about Rs 8,850 on a small return.

A second worked example: Rs 8 crore turnover

A trader with turnover of Rs 8 crore must file both GSTR-9 and GSTR-9C. Late by 20 days, the tiered fee would be about Rs 2,000 (20 times Rs 100), with a cap near Rs 32,000 at 0.04 percent. The more costly issue is not the fee but the effort: GSTR-9C ties your return to your audited accounts, and a mismatch can lead to questions.

A worked example: a small business that is exempt

A shop in Kota with turnover of Rs 1.8 crore in FY 2025-26 is below Rs 2 crore. It does not need GSTR-9. It still needs to have filed every GSTR-1 and GSTR-3B for the year, and it should keep its reconciliation of books and returns in case of an inquiry. If it grows past Rs 2 crore in FY 2026-27, the requirement will apply from that year.

Records worth keeping

• A sales and purchase register for the full year, tied to each GSTR-1 and GSTR-3B.
• The GSTR-2B statements for each month, downloaded and saved, because the portal view changes.
• Supplier-wise lists of credit claimed but not shown in GSTR-2B, with the reason and the follow-up.
• Copies of credit notes, debit notes and amendments, with the dates they were reported.
• Challans for any DRC-03 payment and the working for the interest.
• The filed GSTR-9, and the GSTR-9C if it applies, with the audited accounts they were reconciled to.
• A short note on why any figure differs from your income-tax return, if it does.

None of this is exciting, but it is what an officer or an auditor asks for. A return that cannot be revised is only as good as the papers behind it.

When to ask for help

Ask an accountant early if any of these apply: you have more than one registration under the same PAN, you changed rates or classification during the year, you have large credit that does not match GSTR-2B, you crossed Rs 5 crore during the year, or you missed returns for any month. These are the cases where a December rush costs the most.

Common mistakes

• Assuming the exemption removes monthly duties. It does not. Only the annual return is optional.
• Filing before reconciling. The return cannot be revised.
• Claiming credit that is not in GSTR-2B without an explanation.
• Forgetting the credit cut-off. A page reports 30 November 2026 or the annual return date, whichever is earlier.
• Treating the pre-filled data as correct. It reflects what you filed, including your mistakes.
• Ignoring GSTR-9C above Rs 5 crore.
• Leaving the work for December. The portal is busy and the form needs time.
• Mixing up turnover and taxable value. The threshold uses aggregate turnover.
• Not keeping working papers. Auditors and officers ask for the reconciliation.

Frequently asked questions

Do I have to file GSTR-9 for FY 2025-26?

If aggregate turnover is above Rs 2 crore, yes. Up to Rs 2 crore, you are exempt, according to pages citing Notification 15/2025-Central Tax.

What is the due date?

31 December 2026, unless extended.

When did the form open?

One page reports 8 October 2026, with a GSTN advisory dated 13 October 2026. Another says mid-October.

Why can I not see the GSTR-9 tile?

Pages say the portal requires all GSTR-1 and GSTR-3B for the year to be filed first.

Who needs GSTR-9C?

Taxpayers with aggregate turnover above Rs 5 crore. It is reported as self-certified.

Can I revise GSTR-9?

No. Pages say it cannot be revised after filing.

Can I claim missed input credit in GSTR-9?

No. A page says it must go through a later monthly return, subject to the time limit.

Which credit cut-off applies?

A page reports 30 November 2026 or the date of the annual return, whichever is earlier, for FY 2025-26.

What is the late fee?

Reported as Rs 50, Rs 100 or Rs 200 a day by turnover band, with caps. One page gives Rs 200 a day for all. Check the notification.

How do I pay extra tax?

One page says to pay it through Form DRC-03 before filing.

What if I filed all returns but still owe tax?

Pay with interest. Pages mention 18 percent a year on late tax.

Can I file late after the due date?

Yes, with a fee. One page says an annual return cannot be filed more than 3 years after the due date.

Do composition taxpayers file GSTR-9?

One page says the form for composition taxpayers is discontinued. Check the current requirement with your adviser.

Is the GSTR-9 the same as my income-tax return?

No. They are separate. But your turnover figures should be consistent across both.

What to do next

1. Work out your aggregate turnover for 1 April 2025 to 31 March 2026.
2. If it is above Rs 2 crore, put a working date in your calendar well before 31 December 2026.
3. Check that every GSTR-1 and GSTR-3B for the year is filed.
4. Reconcile your sales and purchase registers with the returns and with GSTR-2B.
5. Claim any missed credit before 30 November 2026 where the rules allow, through your monthly return.
6. Ask your accountant to confirm the late fee rule before you decide to wait.

If you want help with the reconciliation, GSTR-9 or GSTR-9C, contact RegisCorp.

This post is general information, not legal or tax advice. Rules change, so check your facts with a qualified professional before you act.

Sources and what we could not verify

Sources used

• Taxscan, GST portal enables GSTR-9 and 9C for FY 2025-26: opening date, GSTN advisory and prerequisite. Dated 14 October 2026.
• StudyCafe, GST portal opens GSTR-9 and GSTR-9C: due date, thresholds, tiered late fee, credit cut-off and rate structures. Dated 12 October 2026.
• Fermor, GSTR-9 annual return: late fee table, table notes, GSTR-9C and the three-year limit. Dated 12 October 2026.
• IncorpX, GSTR-9 annual return guide 2026: reconciliation, DRC-03, table 8 notes and a different late fee figure. Dated 10 July 2026.

All of these are secondary or commercial sources, and several promote the publisher's own services. We did not open the GST Acts, the notifications or the GST portal.

What we could not verify

• The late fee amounts and caps, where sources conflict, and the notification that sets them.
• Whether the due date will be extended.
• The exact opening date of the form on the portal.
• The credit cut-off for FY 2025-26 and how it works with the annual return.
• The table-by-table instructions in the form, including the meaning of Table 8C where a page contradicts itself.
• Whether the exemption up to Rs 2 crore applies to every category of taxpayer.
• The treatment of composition taxpayers for this year.
• The three-year limit for late filing, which comes from one page.
• Any change after 24 October 2026.