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GSTR-9 and GSTR-9C for FY 2025-26: Due Date, Who Must File and a Pre-Filing Checklist

GSTR-9 and GSTR-9C for FY 2025-26 are due on 31 December 2026. Who must file, the ₹2 crore and ₹5 crore limits, the ITC trap and a pre-filing checklist.

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GSTR-9 and GSTR-9C FY 2025-26 annual return checklist with the 31 December 2026 due date

GSTR-9 for FY 2025-26 is the GST annual return that summarises a GSTIN's outward supplies, input tax credit and tax paid for the year, and it is due on 31 December 2026, together with the GSTR-9C reconciliation statement where that applies. The forms are already enabled on the GST portal. Because GSTR-9 cannot be revised once filed, the work that matters is the reconciliation before you file, not the filing itself.

This guide covers who must file, the turnover limits, why filing early can cost you input tax credit, and a GSTIN-level checklist for finance teams and CA firms.

Who must file GSTR-9 and GSTR-9C

Aggregate turnover in FY 2025-26GSTR-9GSTR-9C
Up to ₹2 crore Exempt (optional) Not required
Above ₹2 crore up to ₹5 crore Mandatory Not required
Above ₹5 crore Mandatory Mandatory, self-certified

The ₹2 crore exemption applies from FY 2024-25 onwards under Notification No. 15/2025-Central Tax. GSTR-9C is a self-certified reconciliation statement; it no longer needs certification by an external auditor.

Composition taxpayers, Input Service Distributors, non-resident taxable persons, casual taxable persons and those deducting or collecting tax at source under GST do not file GSTR-9; some of them have separate annual or periodic returns.

Key rules before you file

  • All GSTR-1 and GSTR-3B returns for the year must be filed first. The portal will not let you file GSTR-9 for FY 2025-26 until every applicable monthly or quarterly return for that year is filed.
  • GSTR-9 cannot be revised. Errors found later can only be dealt with in later returns where the law allows, or explained in proceedings. Reconcile first.
  • Late filing attracts a daily late fee, with a cap linked to turnover, from 1 January 2027 until the return is filed. Use the GST late fee calculator to work out the amount.
  • The ITC cut-off is the earlier of 30 November 2026 and the date you file GSTR-9. This is the trap explained below.

The ITC trap: don't file GSTR-9 too early

Under section 16(4) of the CGST Act, input tax credit on FY 2025-26 invoices can be claimed only until 30 November 2026 or the date of filing the FY 2025-26 annual return, whichever is earlier. A business that files GSTR-9 on, say, 15 November closes its own ITC window that day.

The safe order is:

  • Finish all FY 2025-26 ITC claims in GSTR-3B (the October 2026 return for monthly filers, filed by 30 November).
  • Then prepare and file GSTR-9 and GSTR-9C before 31 December 2026.

Our guide on the GST ITC deadline of 30 November 2026 covers the ITC close-out in detail.

What GSTR-9 brings together

GSTR-9 is not a fresh calculation. It pulls together what you already reported, and asks you to explain the differences:

  • Outward supplies reported in GSTR-1 and the tax paid on them through GSTR-3B.
  • Input tax credit availed during the year, reversals, and a comparison with the ITC shown in the auto-generated statements.
  • Tax paid in cash and through credit.
  • Transactions of FY 2025-26 reported in the next year's returns (amendments, credit notes and ITC claimed up to the cut-off), shown separately so the year's position is complete.
  • HSN-wise summaries of outward and inward supplies.

GST rates on many goods and services changed from 22 September 2025, so FY 2025-26 sits on both sides of that change. Reconcile turnover and the HSN summary rate by rate across the year, not just in total.

Pre-filing checklist (run for each GSTIN)

#CheckWhy it matters
1 All GSTR-1 and GSTR-3B for April 2025 – March 2026 filed GSTR-9 cannot be filed otherwise
2 Turnover in books = GSTR-1 = GSTR-3B (after amendments) Differences need an explanation or a payment
3 Tax liability in GSTR-1 vs tax paid in GSTR-3B Short payment must be paid with interest before filing
4 ITC claimed in GSTR-3B vs GSTR-2B for the year Excess claims will be questioned
5 Ineligible and blocked ITC (section 17(5)) reversed Reported reversals should match the books
6 Rule 37 / 37A reversals and reclaims recorded These show up as ITC movements in the year
7 FY 2025-26 credit notes, amendments and ITC claimed in April–November 2026 identified They belong in the separate part of GSTR-9
8 HSN summary reconciled, including the rate change from 22 September 2025 Mismatched HSN data is a common query
9 Turnover above ₹5 crore: GSTR-9C reconciliation with audited financial statements 9C reconciles the books with the annual return
10 All FY 2025-26 ITC claimed in GSTR-3B before GSTR-9 is filed Filing GSTR-9 closes the ITC window

For the monthly ITC side, our GSTR-2B reconciliation guide explains the invoice-level process, and the GST ITC calculator gives a quick estimate of eligible credit.

GSTR-9C: reconciling books with the return

For GSTINs with turnover above ₹5 crore, GSTR-9C reconciles the figures in the audited financial statements with GSTR-9:

  • turnover as per books vs turnover declared in GSTR-9, with reasons for each difference;
  • taxable turnover and tax payable, rate by rate;
  • ITC as per books vs ITC claimed.

Start 9C work early: it needs final, audited numbers at state level, which multi-state businesses often have to split out from consolidated accounts.

Common mistakes

  • Filing GSTR-9 before 30 November and losing FY 2025-26 ITC still to be claimed.
  • Copying auto-populated figures without checking them against the books.
  • Ignoring credit notes and amendments made after March 2026 that relate to FY 2025-26.
  • Treating the rate change of 22 September 2025 as a single-rate year in the HSN summary.
  • Leaving 9C until the last week, when audited state-wise figures are not ready.

How GSTCPC handles the annual return

GSTCPC is Figment's GST compliance software for enterprises and CA firms. For GSTR-9 and GSTR-9C, the relevant features listed on the product page are:

  • GSTR-1, GSTR-1A, GSTR-3B, GSTR-9 and GSTR-9C filing, with role-based filing controls.
  • GSTR-2A and GSTR-2B reconciliation against the purchase register, with ITC tracking and ITC mismatch reports.
  • A temporary ITC reversal and reclaim ledger.
  • Multiple GSTINs under one organisation, with centralised reports and period-wise comparisons.

Key takeaways

  • GSTR-9 and GSTR-9C for FY 2025-26 are due on 31 December 2026.
  • GSTR-9 is optional up to ₹2 crore turnover; GSTR-9C is required above ₹5 crore and is self-certified.
  • File all GSTR-1 and GSTR-3B first, and claim all FY 2025-26 ITC before filing GSTR-9.
  • GSTR-9 cannot be revised, so reconcile at GSTIN level before you file.

Frequently Asked Questions

31 December 2026, for both GSTR-9 and GSTR-9C. No extension had been announced as of 24 October 2026.

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