GSTR-9 for FY 2025-26 is due on 31 December 2026. If your aggregate turnover for the year was above ₹2 crore, you file it. Above ₹5 crore, you also file the self-certified reconciliation statement, GSTR-9C. GSTN opened both forms on the portal in October 2026.
The filing itself takes an afternoon. The work before it does not. FY 2025-26 is harder than most years for two reasons: GST rates changed midway on 22 September 2025, so many HSN codes carry two rates in the same year, and the last date to claim missed FY 2025-26 input tax credit, 30 November 2026, falls a month before the annual return is due.
This checklist is the order we work through for clients, with a worked reconciliation for a hypothetical Surat garments wholesaler. Every figure in it is illustrative, but the arithmetic is the same arithmetic you will run on your own books.
Who has to file GSTR-9 for FY 2025-26?
Notification No. 15/2025-Central Tax exempts registered persons with aggregate turnover up to ₹2 crore from filing the annual return for FY 2024-25 onwards. Rule 80 requires GSTR-9C along with the annual return once turnover crosses ₹5 crore.
Aggregate turnover in FY 2025-26 | GSTR-9 | GSTR-9C |
|---|---|---|
Up to ₹2 crore | Exempt (you may still file) | Not required |
Above ₹2 crore, up to ₹5 crore | Required | Not required |
Above ₹5 crore | Required | Required, self-certified |
Aggregate turnover is calculated on PAN basis across all your GSTINs in India, not per registration. A business with two GSTINs of ₹1.6 crore each has an aggregate turnover of ₹3.2 crore, and each GSTIN files its own GSTR-9.
Composition taxpayers report their year in GSTR-4 instead, and a few categories such as Input Service Distributors, casual taxable persons and non-resident taxable persons do not file an annual return at all.
Why should you finish ITC claims before you file GSTR-9?
Section 16(4) of the CGST Act lets you claim credit on a FY 2025-26 invoice only up to 30 November 2026 or the date you file the FY 2025-26 annual return, whichever is earlier. That second limb is the trap. File GSTR-9 on 25 November and the window closes on 25 November, not 30 November.
GSTR-9 is also not a place to claim credit. It reports what you claimed in GSTR-3B. Any FY 2025-26 bill missing from your books or from GSTR-2B has to be chased with the supplier and claimed in a GSTR-3B first. In practice, for a monthly filer, the October 2026 GSTR-3B due on 20 November is the last regular return in which that can happen.
Sellers have the same cut-off under section 34. A credit note for a FY 2025-26 supply must be declared in a return filed by 30 November 2026 to reduce your output tax. Our November 2026 compliance calendar sets out the week-by-week order for these two deadlines.
One more reason not to rush: once filed, GSTR-9 cannot be revised. A mistake stays on record and becomes the starting point for any scrutiny.
How do you reconcile outward supplies across books, GSTR-1 and GSTR-3B?
Three numbers should agree for the year: taxable turnover in your books, taxable value reported in GSTR-1 (including amendments), and taxable value declared in GSTR-3B. They rarely do on the first pass.
Worked example: a Surat garments wholesaler
Say you run a readymade garments wholesale business in Surat with a single GSTIN. Your FY 2025-26 figures look like this:
Source | Taxable value | Difference |
|---|---|---|
Books (sales register, net of returns) | ₹3,42,00,000 | - |
GSTR-1 for the year | ₹3,41,85,000 | ₹15,000 below books |
GSTR-3B for the year | ₹3,40,10,000 | ₹1,75,000 below GSTR-1 |
Tracing each difference to documents:
Books versus GSTR-1, ₹15,000. A sales return booked on 31 March 2026 whose credit note was never reported in GSTR-1. Because it is a FY 2025-26 credit note, it has to go into the October 2026 GSTR-1, due 11 November, or you lose the right to reduce tax on it.
GSTR-1 versus GSTR-3B, ₹1,75,000. A February 2026 invoice for garments taxed at 5% was reported in GSTR-1 but left out of the February GSTR-3B. Tax short-paid: ₹1,75,000 × 5% = ₹8,750.
The ₹8,750 is payable with interest at 18% a year from the day after the February GSTR-3B due date. If you pay on 10 December 2026, that is 265 days: ₹8,750 × 18% × 265 ÷ 365 = ₹1,143 (rounded). You report the additional tax in GSTR-9 and pay it through Form DRC-03. Paying it before filing is cleaner than leaving it for a notice.
A difference that runs the other way, where GSTR-3B shows more tax than GSTR-1, cannot be adjusted downward through GSTR-9. It needs an explanation on file, not a correction.
How do you read Tables 8A, 8C and 8D for ITC?
Table 8A is auto-populated from GSTR-2B and cannot be edited. Table 6B shows the credit you claimed in GSTR-3B. Table 8C is where you report FY 2025-26 credit that you claimed in the following year within the time limit, and Table 8D is the difference left over.
On the pattern GSTN used for FY 2024-25, Table 8A picks up current-year invoices from the year's GSTR-2B plus those that surfaced in GSTR-2B of the following months up to the ITC cut-off. It excludes previous-year invoices that came in late. Download the invoice-wise Excel from the portal rather than working from the summary.
Continuing the example:
Table 8A, ITC as per GSTR-2B: ₹14,40,000
Table 6B, ITC claimed in GSTR-3B during FY 2025-26: ₹13,95,000
A supplier bill dated 28 March 2026 appeared in your April 2026 GSTR-2B, and you claimed its ₹27,000 in the April 2026 GSTR-3B. That goes in Table 8C, and the same amount in Table 13.
Table 8D: ₹14,40,000 − (₹13,95,000 + ₹27,000) = ₹18,000
The ₹18,000 is GST on a ₹1,00,000 bill for repairs to the proprietor's car. That credit is blocked under section 17(5), you correctly never claimed it, and a positive 8D for this reason is fine. What you should not see in 8D is eligible credit you simply forgot. If you find any, claim it in GSTR-3B before 30 November, not in GSTR-9.
Two related tables catch people out. Table 6A1 reports FY 2024-25 credit that you claimed during FY 2025-26, so it is not counted as current-year credit. Credit reclaimed under rules 37 or 37A, after paying the supplier or after the supplier files, is reported in Table 6H of the year you reclaim it, not in 6A1 or Table 13.
How does the 22 September 2025 rate change affect Table 17?
Table 17 is the HSN-wise summary of outward supplies. From 22 September 2025, the restructured rates moved many goods to a new slab. Readymade garments priced up to ₹2,500 a piece, for example, are now taxed at 5%. Before the change, garments priced above ₹1,000 a piece were taxed at 12%. The same HSN code therefore appears at two rates in FY 2025-26.
In the example, the wholesaler's shirts in the ₹1,001 to ₹2,500 range were sold for ₹18,00,000 from 1 April to 21 September 2025 and ₹21,00,000 from 22 September 2025 to 31 March 2026. Table 17 should show two rows for that HSN:
Period | Taxable value | Rate | Tax |
|---|---|---|---|
1 Apr to 21 Sep 2025 | ₹18,00,000 | 12% | ₹2,16,000 |
22 Sep 2025 to 31 Mar 2026 | ₹21,00,000 | 5% | ₹1,05,000 |
Total | ₹39,00,000 | - | ₹3,21,000 |
A single row at 5% for ₹39,00,000 would show tax of ₹1,95,000 and understate the year's liability on paper by ₹1,26,000, even though GSTR-3B was correct. That kind of mismatch is exactly what system-generated scrutiny picks up. The portal offers an Excel download of GSTR-1 Table 12 HSN data in the Table 17 format, so start there and check invoices dated around 22 September for the wrong rate.
The GSTR-9 checklist: what to close before 31 December
File every GSTR-1 and GSTR-3B for FY 2025-26. GSTN has said the GSTR-9 tile appears only once all of them are filed.
Finish FY 2025-26 ITC and credit notes by 30 November. Chase missing supplier invoices, report pending credit notes in the October GSTR-1, and claim remaining credit in the October GSTR-3B.
Reconcile turnover three ways. Books, GSTR-1 and GSTR-3B, month by month, with each difference traced to a document.
Split exempt, nil-rated and non-GST supplies correctly. They go in separate rows of Table 5 and feed the turnover figure.
Reconcile ITC. Table 8A against Table 6B, identify 8C items, and confirm that 8D holds only ineligible or blocked credit.
Check reversals. Rule 42 and 43 reversals, section 17(5) items and rule 37 reversals for unpaid suppliers should match what went into GSTR-3B Table 4B.
Build Table 17 by HSN and rate. Pay special attention to codes that changed rate on 22 September 2025.
Pay any short-paid tax through DRC-03 with interest before you file, and keep the working.
For turnover above ₹5 crore, finish GSTR-9C with the audited financial statements and file it with GSTR-9.
If you run this across many client GSTINs, file the simple ones in early December and leave room for the two or three that always turn up a surprise.
What is the late fee if you miss 31 December?
Under Notification No. 07/2023-Central Tax, the late fee for GSTR-9 from FY 2022-23 onwards is:
Turnover up to ₹5 crore: ₹50 a day (₹25 CGST plus ₹25 SGST), capped at 0.04% of turnover.
Above ₹5 crore, up to ₹20 crore: ₹100 a day, capped at 0.04% of turnover.
Above ₹20 crore: ₹200 a day, capped at 0.5% of turnover.
For the ₹3.42 crore wholesaler, filing 15 days late costs ₹50 × 15 = ₹750. The cap is ₹3,42,00,000 × 0.04% = ₹13,680, which would be reached after 274 days.
If you also file GSTR-9C, the clock runs until both forms are filed. CBIC Circular No. 246/03/2025-GST clarifies that the annual return is complete only when GSTR-9C is furnished, so filing GSTR-9 on time and GSTR-9C late still attracts late fee from 31 December to the GSTR-9C date. It is one late fee, not two.
Where hisabkitab fits in
Most of this checklist is reconciliation, and it goes faster when the data already sits in one place. hisabkitab's AI GST accounting software files GSTR-1 and GSTR-3B, matches GSTR-2B against your purchase register with AI reconciliation, and gives you ITC and liability reports for the year. It flags wrong GSTINs and duplicate invoices, which are the usual causes of a stubborn Table 8D difference.
For practices, the CA module gives one login across client companies and multiple GSTINs, with roles, an audit trail and the option to freeze books once a year is finalised.
Frequently asked questions
What is the due date for GSTR-9 for FY 2025-26?
31 December 2026, unless the government extends it. GSTR-9C, where applicable, has the same due date.
Is GSTR-9 mandatory for turnover below ₹2 crore?
No. Notification No. 15/2025-Central Tax exempts taxpayers with aggregate turnover up to ₹2 crore from FY 2024-25 onwards. You can still file voluntarily.
Can I claim missed ITC in GSTR-9?
No. GSTR-9 only reports credit already claimed in GSTR-3B. Missed FY 2025-26 credit must be claimed in a GSTR-3B by 30 November 2026, or earlier if you file GSTR-9 before that date.
Can GSTR-9 be revised after filing?
No. There is no revision facility, so reconcile fully before you submit.
How do I pay extra tax found while preparing GSTR-9?
Report it in the return and pay it through Form DRC-03 with interest at 18% a year from the original due date.
Who needs to file GSTR-9C for FY 2025-26?
Taxpayers whose aggregate turnover in FY 2025-26 exceeded ₹5 crore. It is self-certified, so no separate auditor certification is required.
Want your FY 2025-26 reconciliation built from your own books before December? Start a free trial or compare plans.
Continue Reading
