Updated 5 November 2026. A plain-language guide for business owners, not legal or tax advice. Confirm the details with your CA and on the GST portal before you file.
Short answer: the annual return GSTR-9 and the reconciliation statement GSTR-9C for FY 2025-26 are due on 31 December 2026. GSTR-9 is compulsory if your aggregate turnover for the year was above ₹2 crore and optional up to ₹2 crore. GSTR-9C is needed when turnover is above ₹5 crore. GSTN enabled both forms on the portal from 8 October 2026, and the tile only appears once all GSTR-1 and GSTR-3B returns for the year are filed.
Key dates and limits at a glance
| Item | FY 2025-26 position |
|---|---|
| Forms available on portal | From 8 October 2026 (GSTN advisory of 13 October 2026, as reported by Taxscan) |
| Last date to claim FY 2025-26 ITC and correct returns | 30 November 2026, or the date you file GSTR-9 if that is earlier (section 16(4) CGST Act) |
| Due date for GSTR-9 and GSTR-9C | 31 December 2026, unless the government extends it |
| GSTR-9 required | Aggregate turnover above ₹2 crore (up to ₹2 crore exempt under Notification 15/2025-Central Tax) |
| GSTR-9C required | Aggregate turnover above ₹5 crore; self-certified by the taxpayer |
Aggregate turnover is counted across all GSTINs registered on the same PAN, so a business with branches in several states should add them together before deciding whether the forms apply.
Who does not file GSTR-9
Composition taxpayers file their own annual return instead. Input service distributors, casual and non-resident taxable persons, OIDAR suppliers and persons who only deduct TDS or collect TCS under GST are also outside GSTR-9, as summarised by Pujara & Co.
What is different for FY 2025-26
Two rate structures in one year
The GST rate changes that took effect on 22 September 2025 mean FY 2025-26 has two periods: 1 April to 21 September 2025 at the old rates, and 22 September 2025 to 31 March 2026 at the new rates. Commentators including TaxGuru and A R Dhorajiya & Co point out that an HSN code whose rate changed during the year will show on two lines in the HSN summary (Table 17), one for each rate. Those lines must agree with what you reported in GSTR-1.
HSN summary needs care
Table 17 is pre-filled from GSTR-1. TaxGuru warns that some entries may not load fully and that businesses with a large number of HSN lines may need the offline utility. Download the pre-filled data and compare it with your own sales register before filing.
Table 8A and the ITC download
Table 8A is built from GSTR-2B and is a comparison figure, not your legal entitlement. The downloadable file shows, invoice by invoice, which credit was counted and why some was left out (for example late filing by the supplier or a wrong place of supply). Use it to explain any gap between Table 8A and the credit you actually claimed.
Reporting relaxations continue
Published commentary says the relaxations seen in recent years carry over: exempt and nil-rated supplies can be shown together, input and input-service credit can be combined, and some tables (such as 15, 16 and 18) may be left blank. ITC reversals still have to be shown rule by rule. Check the current form instructions on the portal before relying on any relaxation.
Late fee if you miss 31 December
Late fee runs per day from 1 January 2027 for each GSTIN until the return is filed. As summarised by Pujara & Co and A R Dhorajiya & Co, the combined CGST and SGST rate is:
- Turnover up to ₹5 crore: ₹50 per day, capped at 0.04% of turnover in the state
- Turnover from ₹5 crore to ₹20 crore: ₹100 per day, capped at 0.04%
- Turnover above ₹20 crore: ₹200 per day, capped at 0.5%
Some websites claim that an unfiled FY 2025-26 GSTR-9 will block your monthly GSTR-3B. We have not found a notification or GSTN advisory that says this, and Pujara & Co reached the same view in September 2026. Treat it as unconfirmed, but do not let it become a reason to delay.
Step-by-step checklist
- Confirm every return is filed. All twelve GSTR-1 and GSTR-3B returns (or quarterly returns for QRMP filers) for FY 2025-26 must be filed before the GSTR-9 tile appears.
- Finish ITC work by 30 November. Any missed credit, credit note or correction for FY 2025-26 has to go into a GSTR-3B filed by 30 November 2026. Our post on the ITC last date for FY 2025-26 explains this in detail. Do not file GSTR-9 before you have finished, because filing it early closes the window.
- Reconcile sales. Match your books, e-invoices, e-way bills and GSTR-1 (including GSTR-1A amendments) month by month, with sales split before and after 22 September 2025.
- Reconcile purchases. Compare your purchase register with GSTR-2B and the Table 8A download. List invoices you did not claim and the reason.
- Check the HSN summary. Make sure each HSN line and rate in Table 17 matches GSTR-1 and your sales.
- Review reversals. Show reversals under Rules 37, 37A and 38 and any reclaimed credit in the correct rows.
- Pay any shortfall. If reconciliation shows tax underpaid, pay it with interest through DRC-03 before filing.
- Prepare GSTR-9C if turnover is above ₹5 crore. Reconcile GSTR-9 with your audited financial statements and file both together.
- File early. The portal usually slows down in the last week of December. Aim to file by mid-December.
Why year-end is hard and how software helps
Most of the effort in GSTR-9 is reconciliation, and it is painful only when it has been left for the end of the year. A billing or ERP system that keeps HSN-wise sales, imports GSTR-2B every month and flags mismatches before each GSTR-3B turns the annual return into a review instead of a rescue. See our GST billing software checklist and our November 2026 compliance calendar. Nextinera builds GST-ready ERP software with built-in reconciliation reports. Book a free call if you want to see how it would work for your business.