The GST portal has opened the annual return for FY 2025-26. GSTN has informed taxpayers that Form GSTR-9 (annual return) and Form GSTR-9C (reconciliation statement) can be filed from 8 October 2026, and the normal last date is 31 December 2026. FY 2025-26 is also the first full year reported in the revised forms, and it is a year in which GST rates changed midway. Starting in November rather than late December leaves time to resolve differences. This checklist covers what to look at.
Who has to file
Section 44 of the CGST Act and rule 80 of the CGST Rules require every registered person to file an annual return in Form GSTR-9, with some exceptions: Input Service Distributors, persons deducting or collecting tax at source under sections 51 and 52, casual taxable persons and non-resident taxable persons. Composition taxpayers use Form GSTR-9A instead.
- Turnover up to Rs 2 crore: Notification No. 15/2025-Central Tax (17 September 2025) exempts registered persons with aggregate turnover of up to two crore rupees in a year from filing the annual return, for FY 2024-25 onwards.
- Turnover above Rs 5 crore: Under rule 80(3), a self-certified reconciliation statement in Form GSTR-9C must be filed along with GSTR-9 by the same date.
- Aggregate turnover is worked out on an all-India basis for the PAN, so a business with several state registrations should check the combined figure before deciding which forms apply to each GSTIN.
If the GSTR-9 tile does not appear
In its advisory dated 13 October 2026, GSTN explained that the GSTR-9/9C option is enabled only after every GSTR-1 and GSTR-3B for FY 2025-26 has been filed. If the tile is missing, look first for a pending monthly or quarterly return. For portal problems, GSTN asks taxpayers to raise a ticket on its self-service helpdesk.
What is different in the forms this year
Notification No. 13/2025-Central Tax, dated 17 September 2025, revised the GSTR-9 and GSTR-9C formats for FY 2024-25 onwards. Taxmann’s summary describes the main areas affected: how input tax credit is disclosed, credit taken across years, reclaimed credit, reconciliation of tax liability, and supplies on which an e-commerce operator pays the tax. In practice, the points to note are:
- Table 6A1 shows credit that belongs to the previous year but was taken in this year’s returns. Credit that was reversed under rule 37 or 37A and later reclaimed is not reported here. It goes in Table 6H.
- Table 6B and Table 6H now separate credit taken for the first time (6B) from credit that was reversed and later reclaimed (6H). The reversal itself is shown in Table 7.
- Table 8H1 is a new row for IGST paid on imports of goods during the year where the credit was taken in the next year. Earlier, this credit could appear to have lapsed.
- Extra tax found during the annual exercise can now be paid from the electronic cash ledger or the electronic credit ledger. Earlier, cash was the only option.
- Optional reporting relaxations: the notification extended some long-standing relaxations (for example, for Tables 15 to 18) only up to FY 2024-25. Unless a fresh notification extends them, plan to fill every table that applies to you for FY 2025-26.
Two rate structures in one year
The revised GST rates under Notification No. 9/2025-Central Tax (Rate) took effect on 22 September 2025. For many businesses, supplies made before that date and supplies made after it carry different rates. Keep the two periods separate when you build the HSN-wise summaries and the tax reconciliation in GSTR-9C. Also check invoices issued around the changeover date.
Input tax credit: check this before 30 November
Section 16(4) of the CGST Act sets a deadline for claiming input tax credit for an invoice or debit note. It is 30 November following the end of the financial year, or the date you file the annual return, whichever is earlier. For FY 2025-26, this means 30 November 2026 at the latest, and earlier if GSTR-9 is filed before that. Two practical points follow:
- Compare your purchase register with GSTR-2B and act on any credit you missed through your October 2026 GSTR-3B before the cut-off. GSTN’s FAQs for the previous year explain that Table 8A of GSTR-9 is filled from GSTR-2B. Because only records accepted or deemed accepted in the Invoice Management System reach GSTR-2B, the figure in Table 8A depends on how invoices were handled in IMS.
- If you plan to claim any more credit for FY 2025-26, filing GSTR-9 before 30 November ends that window early. File the annual return only after the credit position is final.
Outward supplies and reconciliation with the books
The figures for outward supplies come from GSTR-1, any GSTR-1A amendments and GSTR-3B. Compare them with the sales ledger, credit notes and advances. GSTR-9C reconciles the turnover and tax in GSTR-9 with the audited financial statements. It is best finished after the accounts are final. Common reasons for differences include unbilled revenue, year-end provisions, transactions between branches in different states, and credit notes issued after the year ended.
Late fee and the outer time limit
Under Notification No. 07/2023-Central Tax, the late fee under the CGST Act for a delayed annual return is limited, from FY 2022-23 onwards, to Rs 25 per day for turnover up to Rs 5 crore and Rs 50 per day for turnover between Rs 5 crore and Rs 20 crore. In both cases, it is capped at 0.02% of turnover in the State or Union territory. A corresponding late fee also applies under the State GST law. Separately, section 44(2) does not allow an annual return to be filed after three years from its due date, unless the Government notifies otherwise.
What you should do
- Confirm aggregate turnover across all registrations under your PAN to decide whether GSTR-9, GSTR-9C or neither applies.
- Make sure every GSTR-1 and GSTR-3B for FY 2025-26 has been filed so that the annual return tile is enabled.
- Reconcile purchases with GSTR-2B and settle any pending credit claims through returns filed by 30 November 2026.
- Sort credit into the revised tables (6A1, 6B, 6H, 7 and 8H1) and keep working papers for each figure.
- Split HSN and tax data between the periods before and after 22 September 2025.
- Reconcile turnover and tax with the audited financial statements before preparing GSTR-9C.
- Pay any extra tax identified before filing, and aim to file well before 31 December 2026.
Source: Taxmann (link); GSTN advisory dated 13 October 2026 (link); CBIC, section 44 of the CGST Act (link), section 16 (link) and rule 80 (link)