GSTR-9 and 9C for FY 2025-26: who files what, by 31 December

The GST annual return for FY 2025-26 is due on 31 December 2026. It sounds far away in September. It isn't, because the annual return is only as good as twelve months of reconciliation behind it — and this year has an extra complication built in.

Who files what

  • Aggregate turnover up to ₹2 crore: GSTR-9 is optional.
  • Above ₹2 crore: GSTR-9 is mandatory.
  • Above ₹5 crore: GSTR-9C as well — the reconciliation between your annual return and your audited financial statements. It has been self-certified since FY 2020-21, so no separate professional certificate is needed, but the taxpayer signs off on every difference.

Turnover is aggregate and PAN-wise across India, while the return is filed GSTIN-wise. Composition dealers, input service distributors, casual and non-resident taxable persons, and TDS/TCS registrants are outside GSTR-9.

Below ₹2 crore and thinking of skipping it? Filing voluntarily is often worth it. GSTR-9 is the one place you can formally line up a year of GSTR-1, GSTR-3B and 2B differences, and departmental systems increasingly compare your GST turnover with the turnover in your income-tax return.

The FY 2025-26 special: the rate change

GST rates changed with effect from 22 September 2025, which means this financial year has two rate regimes inside it. In practice:

  • Split outward supplies and the HSN summary at the changeover date and report each rate on its own line — don't merge the year into one rate.
  • A credit note issued after the change for a supply made before it carries the original rate.
  • Check that advances and the invoices adjusted against them sit on the right side of the date.

This is the single biggest source of mismatch in this year's annual return, and it's much easier to sort out now than in the last week of December.

What to reconcile before you start

  1. Books vs GSTR-1 vs GSTR-3B for outward supply and tax. List each difference with a reason — amendments, credit notes, timing.
  2. ITC claimed vs GSTR-2B, including credit that belonged to FY 2025-26 but was claimed in the following year, and credit reversed and reclaimed.
  3. Reverse charge — liability paid and the corresponding credit taken.
  4. Turnover vs financial statements, which is exactly what 9C asks for. If the tax audit is done, this reconciliation is half-built already.
  5. HSN summary, at the rate-wise detail your turnover bracket requires.

Late fee

Late filing of GSTR-9 runs from ₹50 to ₹200 a day depending on turnover, subject to a cap set as a percentage of turnover in the state. The fee is calculated on the portal when you file. The deadline has been extended in some past years, but planning for 31 December and getting an extension is a much better position than the reverse.

How Vitt-Marg helps

We do the twelve-month reconciliation first and the form afterwards — outward supply, ITC against 2B, reverse charge and the rate split — and hand you a working file that stands up if the department asks later. If your monthly returns were filed by someone else, or 2B was never reconciled during the year, tell us early; that's the case that takes time. See also our note on reconciling GSTR-2B month to month and our GST services.

General information, current as of September 2026, not advice for a specific case. GST and income-tax rules change often — check with us before acting on it.