GST Annual Return FY 2025-26: Due Date, Late Fee, Checklist

GST annual return FY 2025-26 at a glance

Who must file GSTR-9 and GSTR-9C?

GSTR-9 is the yearly summary of everything you reported in your monthly or quarterly returns: outward supplies, input tax credit (ITC), tax paid and refunds. GSTR-9C is a reconciliation between GSTR-9 and your audited annual financial statements.

• Regular taxpayers with aggregate turnover above ₹2 crore must file GSTR-9.
• Taxpayers with aggregate turnover up to ₹2 crore are exempt from filing; for FY 2025-26 filing is optional.
• Taxpayers with aggregate turnover above ₹5 crore must also file GSTR-9C along with GSTR-9. It is self-certified, so a CA certificate is not required, but the reconciliation must be prepared and signed off carefully by you.
• Not covered by GSTR-9: composition taxpayers (they file their own annual return), Input Service Distributors, casual and non-resident taxable persons, and TDS/TCS deductors and collectors.

Even if your turnover is below ₹2 crore, filing GST annual return voluntarily can still be useful. It gives you one clean year-end check of ITC and liability before the department raises a query.

GST annual return, What is different this year?

1. Two rate regimes in one return. The GST rate rationalisation took effect on 22 September 2025, in the middle of FY 2025-26. Your GSTR-9 therefore covers supplies at old rates (April to 21 September 2025) and new rates (from 22 September 2025). Check that every invoice, credit note and HSN line was reported at the rate applicable on its date, and that your books split the two periods cleanly.

2. More detailed ITC reporting. The annual return form has been reworked in recent years. It now asks for ITC of the previous year claimed in the current year (Table 6A1), import ITC reconciled with ICEGATE data (Table 8H1), and compulsory reporting in Tables 12 and 13. Open the live form on the portal and map your working papers to it before you start; do not reuse last year’s template blindly.

3. ITC must tie back to GSTR-2B. Table 8 compares ITC claimed in GSTR-3B with ITC available in GSTR-2B. Credit claimed on invoices that never appeared in your GSTR-2B, or that were not accepted on the Invoice Management System (IMS), is the single most common source of a mismatch.

GST annual return-Late fee and interest if you miss 31 December

Late fee for GSTR-9 is charged per day from the day after the due date until the day you file, under Section 47(2) of the CGST Act as reduced by Notification No. 07/2023-Central Tax. It depends on your aggregate turnover, and the cap is a percentage of turnover in the State or Union Territory of the registration.

• GSTR-9C has no separate late fee, but where it is required the return is treated as complete only when both forms are filed, so file them together.
• Late fee is separate from interest at 18% a year under Section 50, which applies to any tax you pay late, including additional liability discovered while preparing GSTR-9.
• Additional tax found at this stage has to be paid in cash; ITC cannot be used to settle it. Many such differences can be avoided by correcting them in your GSTR-1 and GSTR-3B filings up to November, before the 30 November cut-off.

GST annual return- Six mistakes that invite GST notices

• Filing GSTR-9 straight from auto-populated data. The portal fills tables from your GSTR-1 and GSTR-3B. If those were wrong, GSTR-9 repeats the error. Reconcile to your books first.
• Claiming ITC that is not in GSTR-2B. Credit on invoices missing from GSTR-2B, or not accepted on IMS, shows up as a mismatch in Table 8 and is a classic trigger for a query.
• Ignoring the September 2025 rate change. Invoices raised or credit notes issued around 22 September 2025 are often reported at the wrong rate or in the wrong period.
• Turnover that does not match the books. GSTR-9 turnover should reconcile to the profit and loss account, and to the income tax return and tax audit report where applicable. Differences need a reason on record.
• Mishandling ITC reversals and reclaims. Rule 37 and Rule 37A reversals, and credit reclaimed later, are reported in specific tables. A single reversal figure is not enough.
• Treating GSTR-9C as a formality. It is self-certified, which puts the accuracy on you. Reconcile turnover, tax paid and ITC to audited financials and explain every difference.

A 10-step checklist to file GST annual return by 31 December

1. 1Confirm every GSTIN under your PAN and total the aggregate turnover to decide: GSTR-9 only, or GSTR-9 plus GSTR-9C.
2. 2Make sure all GSTR-1 and GSTR-3B for April 2025 to March 2026 are filed; the annual return tile opens only after that.
3. 3Reconcile GSTR-1 and GSTR-3B with your books, month by month, and with the sales register and e-invoice / e-way bill data.
4. 4Reconcile ITC: GSTR-2B against books and against GSTR-3B; resolve pending IMS items.
5. 5Before 30 November 2026, claim eligible ITC and make remaining invoice amendments and credit notes for FY 2025-26.
6. 6Split April to 21 September 2025 and 22 September 2025 to March 2026 supplies and check rates.
7. 7Match turnover and ITC with the audited financial statements.
8. 8Download the auto-populated draft from the portal and compare it line by line with your workings.
9. 9Pay any additional tax and interest in cash, then file GSTR-9 and GSTR-9C together.
10. 10Keep the working papers, filing acknowledgement and reconciliation file for your records.

Frequently asked questions