31 December 2026 carries two GST deadlines. It is the due date for the FY 2025-26 annual return, and it is also the last day on which a pending FY 2022-23 annual return can be filed at all. This guide covers who has to file, what changed in the form, why this year's reconciliation is harder than usual, and what a late return actually costs.
Short answer
GSTR-9 for FY 2025-26 is due by 31 December 2026. It is mandatory if your aggregate turnover for the year exceeded ₹2 crore and optional below that. GSTR-9C, the reconciliation statement, is also required once aggregate turnover exceeds ₹5 crore, and it is self-certified. The late fee runs from ₹50 to ₹200 a day depending on turnover, subject to a cap. And because the portal refuses any return more than three years past its due date, 31 December 2026 is also the final day to file GSTR-9 for FY 2022-23.
| Item | FY 2025-26 position |
|---|---|
| Due date | 31 December 2026 |
| GSTR-9 mandatory | Aggregate turnover above ₹2 crore (optional up to ₹2 crore) |
| GSTR-9C required | Aggregate turnover above ₹5 crore; self-certified |
| Last date to claim FY 2025-26 input tax credit | 30 November 2026, or the date GSTR-9 is filed if earlier |
| Late fee | ₹50 to ₹200 a day by turnover slab, capped at 0.04% or 0.5% of turnover in the state |
| Last date for a pending FY 2022-23 GSTR-9 | 31 December 2026 (three-year bar) |
Who must file GSTR-9 and GSTR-9C
The ₹2 crore exemption comes from Notification 15/2025-Central Tax dated 17 September 2025, issued under Section 44 of the CGST Act. It applies from FY 2024-25 onwards, so it covers FY 2025-26 without a fresh notification. Below the limit, filing is optional; above it, GSTR-9 is compulsory.
The test uses aggregate turnover, which is calculated on your PAN across India, not per registration. A business with one GSTIN in Gujarat and another in Maharashtra adds both states' turnover to decide whether it crosses ₹2 crore or ₹5 crore, even though each GSTIN files its own GSTR-9.
- Regular taxpayers with aggregate turnover above ₹2 crore: GSTR-9 is compulsory.
- Above ₹5 crore: GSTR-9 plus GSTR-9C, the statement that reconciles the GST returns with the finalised books.
- Composition taxpayers: they file GSTR-4 instead, due by 30 June after the year.
- Not required: input service distributors, casual and non-resident taxable persons, OIDAR suppliers, and persons deducting or collecting tax at source (e-commerce operators file GSTR-9B for TCS).
31 December 2026: two deadlines on one day
The Finance Act 2023 amended Sections 37, 39, 44 and 52 of the CGST Act so that a return cannot be filed more than three years after its original due date. The change took effect from 1 October 2023 (Notification 28/2023-Central Tax), and the GST portal began enforcing it in 2025. Once the date passes, the portal does not accept the return: no late fee, application or appeal reopens it, and the tax liability behind it remains.
| Annual return | Original due date | Last date it can be filed |
|---|---|---|
| FY 2021-22 | 31 December 2022 | 31 December 2025 (now barred) |
| FY 2022-23 | 31 December 2023 | 31 December 2026 |
| FY 2025-26 | 31 December 2026 | 31 December 2029 |
There is a catch for anyone hoping to use the FY 2022-23 window. The portal opens GSTR-9 for a year only after every GSTR-1 and GSTR-3B for that year has been filed, and the monthly returns for FY 2022-23 have already passed their own three-year limits. In practice the window is open only to businesses whose monthly returns for that year are complete and only the annual return is missing.
Why FY 2025-26 is harder: the September rate change
FY 2025-26 is the first annual return to span the GST rate rationalisation. From 22 September 2025 most goods and services moved to a two-rate structure of 5% and 18%, with a 40% rate for a short list of luxury and sin goods, and the 12% and 28% slabs were folded into these. Compensation cess stopped applying to most goods from the same date. One year's return therefore carries two rate structures: the old slabs from 1 April to 21 September 2025, and the new ones from 22 September 2025 to 31 March 2026.
Where this shows up in the annual return:
- The HSN summary of outward supplies (Table 17): the same HSN code can appear twice, once at each rate, and both lines have to agree with what GSTR-1 reported.
- Supplies that spanned the change: where the invoice, the payment and the supply fell on different sides of 22 September 2025, the time-of-supply rules in Section 14 decide which rate applied. Errors made then surface now.
- Credit notes issued after 22 September 2025 on goods sold before it carry the original rate, a common mismatch between the books and GSTR-1.
A practical approach is to split the year's books at 21 September 2025 before starting the reconciliation, so that each half can be matched to the returns filed for that period.
Finish your ITC review before you file
Section 16(4) of the CGST Act sets the last date to claim input tax credit for a year: 30 November of the following year, or the date the annual return is filed, whichever is earlier. For FY 2025-26 that is 30 November 2026. Filing GSTR-9 early closes the window early.
GSTR-9 itself cannot be used to claim credit that was never taken in GSTR-3B. Credit missed for FY 2025-26 has to be claimed in a GSTR-3B filed by 30 November 2026, after which it is lost. Output tax found short during the reconciliation is paid through Form DRC-03 with interest before the annual return is filed.
The order that avoids both problems:
- October to mid-November 2026: reconcile purchases in the books with GSTR-2B for the whole year, including FY 2025-26 invoices that appeared in GSTR-2B between April and October 2026.
- Claim any missed credit in a GSTR-3B filed on or before 30 November 2026. Monthly filers can use the October 2026 return; quarterly filers need the July to September return.
- Pay any shortfall in output tax through DRC-03 with interest.
- File GSTR-9, and GSTR-9C where it applies, in December and well before the 31st.
The tables that cause most errors
The GSTR-9 format was revised by Notification 13/2025-Central Tax in September 2025 with effect from FY 2024-25, so FY 2025-26 is its second year. The tables that need the most care:
| Table | What it captures | Where it goes wrong |
|---|---|---|
| 6A1 | Credit of the previous year (FY 2024-25) claimed in this year's GSTR-3B. It sits inside 6A and is separated out so that only this year's credit is analysed in 6B to 6H. | Including credit reclaimed under Rules 37 or 37A, which belongs in 6H instead. |
| 8A | Credit on FY 2025-26 invoices as they appear in GSTR-2B, including those appearing between April and October 2026. Auto-populated. | Treating 8A as the credit you are entitled to. It is a comparison figure, and differences with 8B and 8C have to be explained. |
| 8C | FY 2025-26 credit claimed in GSTR-3B returns filed between April and 30 November 2026. | Leaving it blank, which makes the 8D difference look like lapsed credit. |
| 8H1 | Import IGST of FY 2025-26 claimed in the next year, compared with customs (ICEGATE) data. | Reporting it in 6E instead. |
| 12 and 13 | FY 2025-26 credit reversed, or availed, in returns filed between April and November 2026. | Figures that do not agree with 8C, or with next year's 6A1. |
| 17 | HSN-wise summary of outward supplies with quantity, value and rate. | For FY 2025-26, missing the second line when an HSN changed rate on 22 September 2025. |
GSTN's own FAQ on the revised format confirms that 8A is built from GSTR-2B, and that actions on the Invoice Management System affect GSTR-9 only through what they put into GSTR-2B.
Late fee, with worked examples
The late fee for a delayed annual return is charged under Section 47(2), at the reduced rates notified in Notification 07/2023-Central Tax for FY 2022-23 onwards. It runs per GSTIN from 1 January 2027 until the return is filed, and the cap is a percentage of the turnover in the state or union territory of that registration.
| Aggregate turnover | Late fee per day (CGST + SGST) | Maximum |
|---|---|---|
| Up to ₹5 crore | ₹50 (₹25 + ₹25) | 0.04% of turnover in the state |
| ₹5 crore to ₹20 crore | ₹100 (₹50 + ₹50) | 0.04% of turnover in the state |
| Above ₹20 crore | ₹200 (₹100 + ₹100) | 0.5% of turnover in the state |
| Business (all turnover in Gujarat) | Days late | Per day | Cap | Late fee |
|---|---|---|---|---|
| Trader, ₹3 crore turnover | 60 | ₹50 | ₹12,000 | ₹3,000 |
| Trader, ₹3 crore, filed a year late | 365 | ₹50 | ₹12,000 | ₹12,000 (capped) |
| Manufacturer, ₹12 crore | 90 | ₹100 | ₹48,000 | ₹9,000 |
| Distributor, ₹40 crore | 45 | ₹200 | ₹20,00,000 | ₹9,000 |
Where GSTR-9C is required, the fee is for furnishing the complete annual return, so it keeps running until GSTR-9C is filed as well (Circular 246/03/2025-GST). Non-filing can also bring a notice in Form GSTR-3A under Section 46, asking for the return within 15 days.
Does a missing GSTR-9 block GSTR-3B?
Several websites now say that if the FY 2025-26 annual return is not filed by 31 December 2026, the portal will stop you filing GSTR-3B from January 2027. As on 27 September 2026 we could not trace any notification, rule or GSTN advisory that says so. The Finance Act 2025 did give the government power to prescribe conditions for filing GSTR-3B, so a link of this kind could be notified later; if it is, this guide will be updated.
The link that does exist runs the other way: the portal does not open GSTR-9 for a year until every GSTR-1 and GSTR-3B for that year has been filed. Separately, e-way bill generation is blocked once GSTR-3B is missed for two consecutive tax periods.
Filing checklist for FY 2025-26
- Confirm aggregate turnover on your PAN for FY 2025-26 to decide between GSTR-9 alone, GSTR-9 with GSTR-9C, or voluntary filing.
- Check that every GSTR-1 and GSTR-3B from April 2025 to March 2026 is filed; GSTR-9 will not open otherwise.
- Split sales and purchases at 21 September 2025 and reconcile each half with the returns filed for it.
- Reconcile purchase credit with GSTR-2B for the full year, including invoices appearing up to October 2026, and claim missed credit by 30 November 2026.
- Match the HSN summary with GSTR-1, rate by rate.
- Pay any shortfall through DRC-03 with interest.
- Above ₹5 crore, finalise the books first and prepare GSTR-9C from them.
- File by mid-December rather than on 31 December, and if a FY 2022-23 annual return is pending, file that before 31 December 2026 too.
Ahmedabad businesses with more than one registration, for example a head office in Gujarat and a branch in another state, file a separate GSTR-9 for each GSTIN but apply the ₹2 crore and ₹5 crore tests to their combined turnover.
Frequently Asked Questions
What is the due date for GSTR-9 for FY 2025-26?
31 December 2026, for both GSTR-9 and, where it applies, GSTR-9C. As on 27 September 2026 no extension has been notified. The late fee starts running from 1 January 2027.
Is GSTR-9 mandatory if my turnover is below ₹2 crore?
No. Notification 15/2025-Central Tax exempts registered persons whose aggregate turnover for the year is up to ₹2 crore from filing the annual return, from FY 2024-25 onwards. Filing is optional. The test is on aggregate turnover across all GSTINs on your PAN.
Who needs to file GSTR-9C, and does a CA have to certify it?
GSTR-9C is required when aggregate turnover exceeds ₹5 crore. It has been self-certified by the taxpayer since FY 2020-21, so a CA's certification is no longer mandatory, but it must reconcile the GST returns with the finalised financial statements.
What is the late fee for filing GSTR-9 late?
₹50 a day for aggregate turnover up to ₹5 crore and ₹100 a day between ₹5 crore and ₹20 crore, each capped at 0.04% of turnover in the state; ₹200 a day above ₹20 crore, capped at 0.5%. These are combined CGST and SGST amounts. Where GSTR-9C is required, the fee runs until it is filed too.
Can I claim missed input tax credit in GSTR-9?
No. GSTR-9 reports credit already taken in GSTR-3B; it cannot be used to claim new credit. Missed FY 2025-26 credit has to be claimed in a GSTR-3B filed by 30 November 2026, or before the annual return if that is filed earlier.
Can GSTR-9 be revised after filing?
No. Once filed, GSTR-9 cannot be revised. Additional liability found later can still be paid through DRC-03 with interest, but reporting errors in the return itself stay on record, which is why reconciliation before filing matters.
Can I still file GSTR-9 for FY 2022-23?
Only until 31 December 2026, which is three years from its original due date of 31 December 2023. After that the portal will not accept it. The portal also requires every GSTR-1 and GSTR-3B for FY 2022-23 to be on record first, and those monthly returns are already past their own three-year limit.
Will a missing GSTR-9 block my GSTR-3B from January 2027?
As on 27 September 2026 we could not trace any notification or GSTN advisory that blocks GSTR-3B for a missing GSTR-9, although some websites say so. The block that exists is the reverse: GSTR-9 opens only after every GSTR-1 and GSTR-3B for the year is filed. Filing by 31 December avoids the question entirely.
GSTR-9 and GSTR-9C for FY 2025-26, reconciled before 30 November
Year-long GSTR-2B reconciliation, the 22 September rate split, DRC-03 where needed and filing well before 31 December. Fee confirmed in writing before we start.
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