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GSTR-9 Annual Return Due Date 2026: What Businesses Must Know
Most businesses treat GSTR-9 the same way every year. It is the annual return that sits at the back of the compliance calendar, gets pushed to December, and gets filed in a rush just before the deadline.
This year, that approach carries a consequence it never carried before.
From FY 2025-26 onwards, if GSTR-9 is not filed by December 31, 2026, the GST portal will block all GSTR-3B filings for January 2027, February 2027, and every subsequent month until the annual return is filed. That means not being able to pay output tax, not being able to claim ITC, and not being able to generate e-way bills after the two-consecutive-default threshold. Normal monthly compliance grinds to a halt because of an annual return that was postponed.
This is new. Previous years allowed annual return delays with only the direct late fee consequence. FY 2025-26 added the monthly filing block on top. December 31, 2026 is now a genuinely hard deadline in a way it was not before.
What GSTR-9 Actually Is
GSTR-9 is the annual GST return filed under Section 44 of the CGST Act. It consolidates all the outward supplies, inward supplies, ITC availed, ITC reversed, and tax paid that were reported across the GSTR-1 and GSTR-3B filings for the entire financial year.
Think of it as the annual summary of your GST story. Every monthly or quarterly return filed during FY 2025-26 feeds into this one document. The department uses it to cross-verify the year’s compliance and identify mismatches between what was declared monthly and what the books show.
It is not a new return. The department cannot be told something in GSTR-9 that contradicts what was already filed in monthly returns without that discrepancy showing up. Which is why the reconciliation work that goes into preparing GSTR-9 matters as much as the filing itself.
Who Must File GSTR-9 for FY 2025-26
Filing is mandatory for all regular GST-registered taxpayers whose aggregate annual turnover exceeded Rs. 2 crore during FY 2025-26. This threshold was confirmed under CBIC Notification No. 15/2025.
Taxpayers below Rs. 2 crore are exempt from filing GSTR-9 for this year. But exempt does not mean the filing is impossible or that opting to file is penalised. Businesses below the threshold that want a consolidated annual record can still file voluntarily.
Who does not need to file GSTR-9 at all: composition scheme taxpayers, Input Service Distributors, casual taxable persons, non-resident taxable persons, TDS deductors under Section 51, and TCS collectors under Section 52. Composition dealers file GSTR-4 annually instead, due April 30.
Who must file GSTR-9 even if registration was cancelled during the year: anyone whose registration was active for even one day during FY 2025-26 and whose turnover exceeded the threshold must file for the period of active registration.
And who needs to file GSTR-9C alongside: businesses whose aggregate turnover exceeded Rs. 5 crore in FY 2025-26 must file GSTR-9C, the reconciliation statement that matches GSTR-9 figures with audited financial statements. Since FY 2020-21, GSTR-9C is self-certified and no longer requires a CA or CMA to certify it separately.
The Due Date and What Happens If It Is Missed
GSTR-9 due date for FY 2025-26: December 31, 2026.
GSTR-9C due date for FY 2025-26: December 31, 2026.
Both deadlines fall on the same date. The government has extended these deadlines in previous years through CBIC notifications and may do so again. But businesses should not plan around a possible extension. Planning for December 31 and receiving an extension is far better than planning for an extension that does not come.
The late fee structure for delayed GSTR-9 is tiered by turnover:
Annual Turnover | Late Fee Per Day | Maximum Cap |
Up to Rs. 5 crore | Rs. 50 per day (Rs. 25 CGST + Rs. 25 SGST) | 0.04% of turnover in the state or UT |
Rs. 5 crore to Rs. 20 crore | Rs. 100 per day (Rs. 50 + Rs. 50) | 0.04% of turnover |
Above Rs. 20 crore | Rs. 200 per day (Rs. 100 + Rs. 100) | 0.25% of turnover |
No late fee on IGST. The fee accumulates daily from January 1, 2027, and is automatically calculated and paid on the portal when filing.
But as noted above, the fee is now the smaller concern. The bigger consequence of missing December 31 is the monthly filing block that kicks in from January 2027.
What Changed in the GSTR-9 Form for FY 2025-26
Three changes to the form itself this year come from CBIC Notification No. 13/2025 and Notification No. 16/2025 and are worth knowing before starting preparation.
Related Post
IMS-linked ITC auto-population in Table 8A
Following the Invoice Management System that went live in October 2025, Table 8A in GSTR-9 now reflects only IMS-accepted invoices rather than the older GSTR-2B auto-population logic. Before preparing GSTR-9, review the IMS dashboard for any invoices left in pending status. Invoices not accepted in IMS may not appear in Table 8A and could create an ITC mismatch.
New Table 6A1 for ITC source bifurcation
Following Notification 13/2025, Table 6, which captures ITC availed, now includes Table 6A1, which requires ITC to be broken down by source: inputs, input services, capital goods, imports, ISD credits, and RCM credits separately. This is more granular than previous years and requires proper ledger-level data rather than a summary figure.
Unclaimed ITC deadline is November 30, 2026
ITC available in GSTR-2B for FY 2025-26 that was not claimed in GSTR-3B during the year can still be claimed in GSTR-3B filed on or before November 30, 2026. After November 30, that unclaimed ITC lapses permanently. GSTR-9 Table 8D shows unclaimed ITC and is a useful cross-check before the November window closes.
The Three-Year Filing Cap: Old Returns That Can No Longer Be Filed
One more critical update from 2026 that affects businesses with pending annual returns from earlier years.
From January 2026, the GST portal permanently blocks filing any return that is more than three years past its original due date. This means GSTR-9 for FY 2022-23, due December 31, 2023, can only be filed until December 31, 2026. After that, the portal will not accept it at any cost.
If there are any unfiled GSTR-9 returns for FY 2022-23 or later years, they must be filed before December 31, 2026. This window closes on the same date as the FY 2025-26 annual return.
Common Mistakes That Create Problems in GSTR-9
- Missing Tables 10 and 11 amendment entries. Amendments made to FY 2025-26 invoices in GSTR-1 or GSTR-3B filed between April and November 2026 go into Tables 10 and 11. Most preparers focus only on the April 2025 to March 2026 filing period and miss the post-year-end amendment window entirely.
- Wrong HSN digit level in Table 17. Businesses with a turnover above Rs. 5 crore are required to use 6-digit HSN codes. Using 2-digit codes creates a validation mismatch that the portal flags.
- ITC claimed in GSTR-3B exceeding the GSTR-2B availability. Table 8 in GSTR-9 compares these figures. A negative figure here is an automatic scrutiny trigger. Reconcile GSTR-2B against the purchase ledger before finalising the form.
- Not reporting DRC-03 payments. Any voluntary tax payments made via DRC-03 during the year must be captured in Table 9. Omitting these creates a tax payment mismatch between GSTR-9 and the department’s records.
- Filing GSTR-9 before completing all GSTR-3B filings for the year. GSTR-9 cannot be revised once filed. All monthly GSTR-1 and GSTR-3B returns for FY 2025-26, including any pending April to June 2026 QRMP quarterly returns, must be complete before the annual return is submitted.
A Pre-Filing Checklist for GSTR-9 FY 2025-26
Before opening the portal, go through these steps:
Confirm all GSTR-1 and GSTR-3B returns for FY 2025-26 are filed and there are no pending monthly returns. Reconcile GSTR-2B ITC with the purchase ledger and identify any discrepancies. Review the IMS dashboard and ensure no relevant invoices are sitting in pending status. Check GSTR-1 and GSTR-3B filed between April and November 2026 for any FY 2025-26 amendment entries that need to go in Tables 10 and 11. Confirm whether aggregate turnover exceeds Rs. 5 crore, triggering GSTR-9C. Pay any short payment of tax or excess ITC identified through DRC-03 before filing. Download the GSTR-9 summary draft from the portal and preview it before final submission.
GSTR-9 cannot be revised once filed. Getting it right before submission is not optional.
FAQs
- Who is required to file GSTR-9 for FY 2025-26?
All regular GST-registered taxpayers with aggregate annual turnover exceeding Rs. 2 crore during FY 2025-26 must file GSTR-9 under CBIC Notification No. 15/2025. Taxpayers below Rs. 2 crore are exempt but can file voluntarily. Composition scheme taxpayers, ISDs, casual taxable persons, non-resident taxable persons, TDS deductors under Section 51, and TCS collectors under Section 52 are not required to file GSTR-9. Businesses with turnover above Rs. 5 crore must additionally file GSTR-9C, the self-certified reconciliation statement, by the same December 31, 2026 deadline.
- What happens if GSTR-9 for FY 2025-26 is not filed by December 31, 2026?
From FY 2025-26 onwards, missing the GSTR-9 deadline triggers two consequences instead of one. The first is the late fee: Rs. 50 per day for turnover up to Rs. 5 crore, Rs. 100 per day for Rs. 5 to 20 crore, and Rs. 200 per day above Rs. 20 crore, each capped at a percentage of state turnover. The second consequence is new for this year: the GST portal blocks all GSTR-3B monthly filings from January 2027 onwards until the annual return is filed, preventing normal tax payment, ITC claims, and e-way bill generation after the two-consecutive-default threshold.
- Can GSTR-9 be revised after filing?
No. GSTR-9 cannot be revised once it is submitted on the GST portal. This makes pre-filing reconciliation critical. All monthly GSTR-1 and GSTR-3B returns for FY 2025-26 must be complete, all ITC mismatches identified and addressed through DRC-03 payments, and the full draft GSTR-9 must be previewed and verified before the final submission is made. Any error discovered after filing must generally be addressed through the subsequent year’s GSTR-9 or through other available GST correction mechanisms.
- What is the difference between GSTR-9 and GSTR-9C and who needs both?
GSTR-9 is the annual return consolidating all GST activity for the year, mandatory for regular taxpayers above Rs. 2 crore turnover. GSTR-9C is the reconciliation statement that compares GSTR-9 figures with the audited financial statements, mandatory for taxpayers with turnover above Rs. 5 crore. Both are due December 31, 2026 for FY 2025-26. Since FY 2020-21, GSTR-9C is self-certified by the taxpayer and no longer requires separate certification by a CA or CMA, though the figures must still reconcile with the audited accounts.