GSTR-9, the annual GST return, brings together an entire financial year of GSTR-1 and GSTR-3B filings into one consolidated statement. For FY 2025-26, the due date is 31 December 2026 — and this year, that date carries an extra deadline for anyone with an old pending annual return. Here is who must file, who is exempt, what it costs to be late, and why waiting until December is riskier than usual this time.
Quick Summary
- Due date (FY 2025-26): 31 December 2026
- GSTR-9 mandatory if: aggregate turnover exceeded ₹2 crore in FY 2025-26 (optional below that)
- GSTR-9C mandatory if: aggregate turnover exceeded ₹5 crore — self-certified, no CA/CMA certificate required
- Late fee: ₹200/day (₹100 CGST + ₹100 SGST), capped at 0.25% of turnover in the state/UT
- Exempt: composition taxpayers (file GSTR-4 instead), casual taxable persons, ISDs, non-resident taxable persons, TDS deductors (Sec 51), e-commerce TCS collectors (Sec 52)
Who Must File GSTR-9 for FY 2025-26?
Under Section 44 of the CGST Act, 2017, every registered person is required to file an annual return — but CBIC has, every year since the early years of GST, notified an exemption for smaller taxpayers. For FY 2025-26, that exemption continues via Notification No. 15/2025-Central Tax (17 September 2025):
| Aggregate Turnover (FY 2025-26) | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to ₹2 crore | Optional | Not applicable |
| Above ₹2 crore, up to ₹5 crore | Mandatory | Not applicable |
| Above ₹5 crore | Mandatory | Mandatory (self-certified) |
"Aggregate turnover" here is your PAN-level turnover across all GST registrations, all-India — not just the turnover under one GSTIN. A business with a smaller Ambala registration but a bigger combined PAN-level turnover across states can still cross these thresholds.
Who Is Exempt From GSTR-9 Regardless of Turnover?
A few categories of registered persons don't file GSTR-9 at all, no matter how large their turnover is — because their compliance track runs through a different return entirely:
- Composition scheme taxpayers — they file GSTR-4 as their annual return instead, due 30 June following the financial year (30 June 2026 for FY 2025-26). GSTR-9A, the older composition annual return form, was scrapped from FY 2019-20 onward.
- Casual taxable persons
- Input Service Distributors (ISD)
- Non-resident taxable persons
- Persons required to deduct TDS under Section 51 of the CGST Act
- E-commerce operators required to collect TCS under Section 52
GSTR-9C — The Reconciliation Statement
If your turnover crossed ₹5 crore, GSTR-9C reconciles the figures in your GSTR-9 against your audited (or otherwise finalised) financial statements — turnover, tax paid, and input tax credit. The rule most people get wrong here:
Myth: "GSTR-9C needs a CA's certificate"
Not since FY 2020-21. GSTR-9C is now self-certified by the taxpayer — the mandatory Chartered Accountant / Cost Accountant certification was removed by an amendment that took effect from FY 2020-21 onward. In practice, most businesses still engage a CA to prepare the reconciliation given how detailed it is, but the law no longer requires a third-party certificate.
Late Fee for Missing the GSTR-9 Due Date
Section 47 of the CGST Act prescribes a late fee of ₹100 per day under CGST plus ₹100 per day under SGST — ₹200 per day in total — from the day after the due date until the return is actually filed. This is capped at 0.25% of your turnover in the relevant state or Union Territory (so 0.25% under CGST and 0.25% under SGST — 0.5% of turnover in total, at the outer limit). No separate late fee is prescribed specifically for GSTR-9C — since it can only be filed alongside or after GSTR-9, the GSTR-9 late fee is what applies in practice.
Example
If your GSTR-9 (due 31 December 2026) is actually filed on 20 January 2027, that's 20 days of delay. Late fee = 20 × ₹200 = ₹4,000, subject to the 0.25%-of-turnover cap on each side (CGST and SGST).
Why 31 December 2026 Is a Double Deadline This Year
Since the GSTN portal began enforcing the GST return time-bar rule (from the July 2025 tax period, covering returns under Sections 37, 39, 44 and 52 of the CGST Act — GSTR-1, GSTR-3B, GSTR-9 and others), any return that crosses three years past its original due date becomes permanently blocked from filing on the portal. No exceptions are made after the window closes.
GSTR-9 for FY 2022-23 was due on 31 December 2023. Three years later — 31 December 2026 — is exactly when that window shuts. If you (or a business you advise) still has an unfiled GSTR-9 from FY 2022-23, this is genuinely the last opportunity to file it, on the very same date the new FY 2025-26 return falls due. If this applies to you, treat it as more urgent than the current year's filing and get it done first.
Getting Ready to File — What to Reconcile First
- Match your books' turnover against the total of all GSTR-1s and GSTR-3Bs filed for the year
- Reconcile input tax credit claimed in GSTR-3B against GSTR-2B / IMS-accepted invoices
- Capture any amendments made between April and November 2026 relating to FY 2025-26 supplies in the annual return's amendment tables
- Check HSN-wise summary requirements apply correctly at your turnover level
- If turnover crossed ₹5 crore, start the GSTR-9C reconciliation early — it takes longer than most people expect
- Don't wait for late December — a rushed filing close to the deadline is where most reconciliation errors happen
GSTR-9 Filing Help
Rajput Lalit & Associates handles GSTR-9 and GSTR-9C preparation and filing — reconciliation against books, GSTR-1/3B and GSTR-2B, amendment reporting, and the full annual return — for businesses across India, with in-person support for clients in Ambala. Book a consultation or see our GST Return Filing service.
Frequently Asked Questions
What is the due date for GSTR-9 for FY 2025-26?
31 December 2026. This is the annual return covering all outward and inward supplies, tax paid, and input tax credit claimed during FY 2025-26 (1 April 2025 to 31 March 2026).
Is GSTR-9 mandatory for my business?
It is mandatory only if your aggregate turnover in FY 2025-26 exceeded ₹2 crore. Below that, filing is optional — CBIC has continued this exemption for small taxpayers through Notification No. 15/2025-Central Tax, dated 17 September 2025, under the first proviso to Section 44(1) of the CGST Act. You can still file voluntarily even if you're below the threshold, and once you start filing GSTR-9 you generally shouldn't skip it in a later year without good reason, since it affects your compliance record.
Do I also need to file GSTR-9C?
Only if your aggregate turnover in FY 2025-26 exceeded ₹5 crore. GSTR-9C is a reconciliation statement matching your GSTR-9 figures against your audited financial statements. It is filed alongside GSTR-9, by the same 31 December 2026 due date.
Do I need a CA to certify GSTR-9C?
No — and this trips up a lot of taxpayers who remember the older rule. Since FY 2020-21, GSTR-9C is self-certified by the taxpayer, not certified by a Chartered Accountant or Cost Accountant. A CA can still prepare it for you (most businesses use one, given the reconciliation work involved), but the mandatory third-party certification requirement was removed years ago.
What is the late fee for missing the GSTR-9 due date?
₹200 per day of delay (₹100 under CGST plus ₹100 under SGST), capped at 0.25% of your turnover in the relevant state or Union Territory. There is no separate late fee prescribed for GSTR-9C itself — since it cannot be filed before GSTR-9, any delay effectively only accrues the GSTR-9 late fee.
Who is exempt from filing GSTR-9 altogether, regardless of turnover?
Composition scheme taxpayers (who file GSTR-4 instead, due 30 June following the financial year), casual taxable persons, input service distributors, non-resident taxable persons, persons paying TDS under Section 51 of the CGST Act, and e-commerce operators collecting TCS under Section 52.
What happens if I never filed GSTR-9 for an old financial year?
There is now a hard cut-off. Under the GST return time-bar rule (Sections 37, 39, 44 and 52 of the CGST Act, enforced on the portal from the July 2025 tax period), any return — including GSTR-9 — becomes permanently unfileable once three years pass from its original due date. For FY 2022-23, whose GSTR-9 was due 31 December 2023, that three-year window closes on 31 December 2026 — the same date the FY 2025-26 GSTR-9 is due. If you have a pending GSTR-9 from FY 2022-23, this is effectively your last chance.
Disclaimer: This article is for general information based on the CGST Act, 2017, related rules and CBIC notifications as of September 2026. Rules, thresholds and portal processes change from time to time, so please verify the latest position or consult a professional before acting.