GSTR-9 and GSTR-9C for FY 2025-26: Who Must File, What Changed, Table-by-Table Reconciliation and the 31 December Deadline

The GST annual return is where a year of monthly filings is reconciled against itself and against your books. Errors in GSTR-1 and GSTR-3B that nobody noticed during the year surface here — and once GSTR-9 is filed, it cannot be revised.

For FY 2025-26 the return is due on 31 December 2026. It is more demanding than last year’s for one reason: the GST rate overhaul of 22 September 2025 means the year straddles two rate structures, and the rate-wise tables have to show both.

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Who must file

GSTR-9 is filed per GSTIN. Whether it is required depends on aggregate turnover — the all-India turnover of all GSTINs under your PAN.

Aggregate turnover in FY 2025-26	GSTR-9	GSTR-9C
Up to ₹2 crore	Optional — exempt under Notification 15/2025-Central Tax	Not required
Above ₹2 crore, up to ₹5 crore	Mandatory	Not required
Above ₹5 crore	Mandatory	Mandatory — self-certified reconciliation statement

Not required at all: composition taxpayers (who file the annual GSTR-4 instead), input service distributors, casual and non-resident taxable persons, TDS deductors and TCS collectors (as such), and OIDAR suppliers.

Filing when optional is sometimes worth it — where the year has errors you would rather disclose and correct through the annual return than have found in a scrutiny.

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What changed for FY 2025-26

1. Two rate structures in one year. From 22 September 2025, most goods and services moved to 5% or 18%, a 40% rate applies to a narrow list of demerit goods, and the 12% and 28% slabs were removed (tobacco products followed a separate timeline). Table 9 (tax payable and paid) and Table 17 (HSN-wise outward supplies) are rate-wise, so for FY 2025-26 they will show supplies at the old rates up to 21 September and the new rates from 22 September. Check that every invoice issued around the changeover — and every credit note against a pre-change invoice — carries the rate that actually applied to it.

2. Table 8A comes from GSTR-2B. Since FY 2024-25, Table 8A (ITC as per the auto-drafted statement) is populated from GSTR-2B, not GSTR-2A. For FY 2025-26 it includes FY 2025-26 invoices appearing in GSTR-2B during the year, plus those your suppliers reported up to October 2026, and excludes FY 2024-25 invoices appearing in early FY 2025-26. The invoice-level detail is downloadable from the GSTR-9 dashboard.

3. Table 6A1 separates last year’s ITC. ITC of FY 2024-25 that you claimed in FY 2025-26 (within the time limit) is reported in Table 6A1, so that it does not distort the current year’s figures. ITC reclaimed under Rules 37 or 37A is the exception — it is treated as ITC of the year in which it is reclaimed and goes to Table 6H.

4. Late fee covers GSTR-9C too. Following Circular 246/03/2025-GST, the late fee under Section 47(2) applies to the complete annual return — GSTR-9 and GSTR-9C together. GSTR-9C now has a table for late fee payable and paid, and the portal computes it from the later of the due date and the GSTR-9 filing date.

5. Smaller changes carried forward from last year: amendments made through GSTR-1A flow into Tables 4 and 5; import ITC of the year availed in the next year goes to the new Table 8H1; and the 65% concessional-rate checkbox has been removed from Tables 17 and 18.

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The return, part by part

Part	Tables	What it captures	Main source
II — Outward supplies	4, 5	Taxable, exempt, nil-rated, export and reverse-charge supplies; credit and debit notes	GSTR-1, GSTR-1A, IFF
III — ITC	6	ITC availed, broken down by type (inputs, capital goods, services, imports, RCM, ISD)	GSTR-3B Table 4A
	7	ITC reversed — Rule 37 (unpaid suppliers), 37A, 39, 42, 43, Section 17(5)	GSTR-3B Table 4B
	8	ITC per GSTR-2B (8A) against ITC claimed (8B), and the difference (8D)	GSTR-2B
IV — Tax paid	9	Rate-wise tax payable and paid, in cash and through ITC	GSTR-3B
V — Next-year adjustments	10–14	FY 2025-26 transactions declared in returns filed between April and November 2026	Your records
VI — Other	15–19	Demands and refunds, HSN summaries of outward (17) and inward (18) supplies, late fee	Your records; HSN download

Tables 12 and 13 carry the ITC of FY 2025-26 that was reversed (12) or availed (13) in the next financial year. The time limit for availing FY 2025-26 ITC is 30 November 2026 under Section 16(4). Table 8C is narrower than it looks: it carries only ITC of the year that was claimed for the first time in the next year, not ITC claimed, reversed and reclaimed.

RCM paid late. Reverse-charge tax for FY 2025-26 paid in a FY 2026-27 return — and the ITC on it — is reported in the annual return of the year in which it was paid, not FY 2025-26.

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The reconciliation to do before filing

Most annual-return problems are discovered by doing this, not by the portal. Do it before opening the form.

1. Books to GSTR-1. Turnover in the books, GSTIN by GSTIN, against GSTR-1 and GSTR-1A — including credit notes, advances, and the split at the 22 September rate change.
2. GSTR-1 to GSTR-3B. Tax declared against tax paid, month by month. A shortfall is paid through DRC-03 before or with the annual return; interest runs from the original due date.
3. GSTR-2B to books to GSTR-3B. ITC available against ITC in the books against ITC claimed. Explain every difference in Table 8D: supplier not filed, invoice in the wrong year, blocked credit, ineligible place of supply.
4. Reversals. Rule 37 (suppliers unpaid after 180 days), Rule 42 and 43 (exempt or non-business use), and Section 17(5) blocked credits — each in the right row of Table 7.
5. Next-year entries. FY 2025-26 ITC taken between April and 30 November 2026, and any FY 2025-26 supplies declared in FY 2026-27 GSTR-1s, for Tables 10 to 13.
6. HSN. Table 17 at the required digit level, using the HSN download from the dashboard, with the rate split at 22 September.
7. For GSTR-9C — reconcile the audited financial statements to GSTR-9: turnover, tax and ITC, with the reasons for each difference. GSTR-9C is self-certified; it does not need a separate GST audit.

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Late fee

The late fee runs from 31 December 2026 to the date the complete annual return (GSTR-9, and GSTR-9C where required) is filed. Combined CGST and SGST:

Aggregate turnover	Per day	Maximum
Up to ₹5 crore	₹50	0.04% of turnover in the State or UT
Above ₹5 crore, up to ₹20 crore	₹100	0.04% of turnover in the State or UT
Above ₹20 crore	₹200	0.5% of turnover in the State or UT

Interest on any tax short-paid during the year is separate, at 18% a year from the date the tax was originally due.

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Mistakes we correct most often

1. Filing GSTR-9 before reconciling — the return cannot be revised. Anything missed must be handled through DRC-03 or will be found in scrutiny.
2. Copying the auto-populated figures without checking them. The auto-fill is a starting point, not a reconciliation.
3. Reporting last year’s ITC as this year’s — it belongs in Table 6A1, not in the current-year breakdown.
4. Putting reclaimed ITC in Table 8C. Only first-time claims in the next year go there; reclaims go to Table 13.
5. Ignoring the rate split. Supplies around 22 September 2025, and credit notes on earlier invoices, reported at the wrong rate.
6. Treating a Table 8D difference as harmless. A large unexplained excess claim is a common trigger for a notice under Section 73.

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How we handle the annual return

We run the four-way reconciliation — books, GSTR-1, GSTR-3B and GSTR-2B — GSTIN by GSTIN, quantify differences before filing, settle any shortfall through DRC-03, and prepare GSTR-9 and GSTR-9C together so the late fee never splits across two dates. For clients on our monthly GST or accounting retainers, the reconciliation is already done as the year runs. See our GST compliance and reconciliation services or outsourced accounting.

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Frequently Asked Questions

What is the due date for GSTR-9 for FY 2025-26?

31 December 2026, for both GSTR-9 and GSTR-9C where it applies, unless the government extends it by notification. The return becomes available on the portal only after all GSTR-1 and GSTR-3B returns for the year are filed.

Is GSTR-9 mandatory for turnover below ₹2 crore?

No. Under Notification 15/2025-Central Tax, filing GSTR-9 is optional for registered persons whose aggregate turnover for the year is up to ₹2 crore. Above ₹2 crore it is mandatory, and above ₹5 crore GSTR-9C is also required.

Can GSTR-9 be revised after filing?

No. There is no facility to revise GSTR-9 once filed. Additional tax found after filing is paid through Form DRC-03 with interest; excess tax already paid cannot be claimed back through the annual return.

What is Table 6A1 in GSTR-9?

Table 6A1 captures ITC of the preceding financial year claimed in the current year within the time limit — for FY 2025-26, ITC of FY 2024-25 claimed during FY 2025-26. It is excluded from the current-year breakdown so the figures reconcile. ITC reclaimed under Rules 37 or 37A is not reported there; it is treated as ITC of the year of reclaim and goes to Table 6H.

What is the late fee for filing GSTR-9 late?

Combined CGST and SGST, ₹50 a day (capped at 0.04% of State turnover) for aggregate turnover up to ₹5 crore, ₹100 a day (capped at 0.04%) between ₹5 crore and ₹20 crore, and ₹200 a day (capped at 0.5%) above ₹20 crore. Since Circular 246/03/2025-GST, the fee runs until both GSTR-9 and GSTR-9C (where required) are filed.

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Related reading

• GST Compliance & Reconciliation Services
• GST Amnesty (Section 128A): What Still Works
• Compliance Calendar FY 2025-26
• GST-Compliant Invoice Format (Free Tool)
• Automated Compliance Monitoring