GSTR-9 FY 2025-26: Due Date, Limits & Filing Checklist

GSTR-9 for FY 2025-26 is due on 31 December 2026. It's mandatory above ₹2 crore turnover, GSTR-9C applies above ₹5 crore, and neither can be revised.

Because it can't be revised, GSTR-9 isn't really a December job. The deadline that decides how good the return will be is 30 November 2026, and this year there's an extra complication: the GST rate changes of 22 September 2025 fall right in the middle of the financial year.

This is a working guide for CA firms: the rules at a glance, the dates that matter, a reconciliation checklist and a way to plan the season across your whole client list.

GSTR-9 for FY 2025-26 at a glance

Composition taxpayers don't file GSTR-9. Their annual return is GSTR-4, which was due on 30 April 2026. Input service distributors, casual and non-resident taxable persons, OIDAR suppliers, and those registered only to deduct or collect tax at source under GST don't file it either.

The date that matters more: 30 November 2026

Three things close for FY 2025-26 on 30 November 2026, or on the date the annual return is filed, whichever comes first:

• The time limit to claim input tax credit you missed during the year (Section 16(4))
• The last date to declare credit notes for supplies made in the year (Section 34)
• The last date to correct errors in that year's GSTR-1 (Section 37(3))

Two consequences follow. First, if your reconciliation starts in mid-December, you'll find the missing ₹4 lakh of ITC after the window has already shut. In practice, missed credit has to go into the October 2026 GSTR-3B, filed by 20 November. Second, filing GSTR-9 early closes these windows early. A client who is keen to "get it out of the way" in October should hear that from you first.

So the useful work happens in October and November. December is for preparing, reviewing and filing.

Why FY 2025-26 is fiddlier than usual

Two rate structures in one year

GST rates were rationalised with effect from 22 September 2025. Most goods and services moved into the 5% and 18% slabs, with a 40% rate for a short list of items. For FY 2025-26 that means the same HSN code can appear at one rate for April to 21 September and a different rate afterwards.

Check that the HSN-wise summary is split by rate and that the GSTR-1 data behind it was reported at the right rate for each period. Pay attention to invoices raised around the changeover, advances received before it, and credit notes issued after it against supplies made before it. That's where most of the mismatches will be.

ITC now runs through GSTR-2B and IMS

Table 8A of GSTR-9 is auto-filled from GSTR-2B. With the Invoice Management System in place, what reached 2B depended on how invoices were accepted, rejected or kept pending during the year. So the three-way match between books, GSTR-2B and ITC claimed in GSTR-3B deserves more time than it used to.

The form itself has changed

CBIC has revised the GSTR-9 format in recent years, including changes around IMS-based ITC and reversals. If your office is still using a working template from 2023, update it before the season starts.

A working GSTR-9 checklist

1. Confirm every return is filed. All GSTR-1 and GSTR-3B for April 2025 to March 2026. The portal won't let you file GSTR-9 otherwise.
2. Reconcile outward supplies. Books against GSTR-1 against GSTR-3B, month by month. Use e-invoice and e-way bill data where you have it.
3. Split turnover around 22 September 2025. Rate-wise, with the HSN summary matching.
4. Reconcile ITC. Books against GSTR-2B against GSTR-3B. List credit missed during the year and claim it before 30 November.
5. Check reversals. Blocked credits under Section 17(5), common credit under Rules 42 and 43, and Rule 37 reversals for suppliers not paid within 180 days.
6. Capture next-year entries. Credit notes, debit notes and amendments made between April and November 2026 that relate to FY 2025-26 go in their own tables.
7. Pay any shortfall. Additional liability found during reconciliation is paid through DRC-03, with interest where it applies, before you file.
8. Tie back to the financials. For GSTR-9C clients, reconcile against the audited accounts and explain every difference.
9. Get client sign-off on the draft. In writing. Then file, and save the ARN and the filed PDF to the client's file.

Planning the season across your client list

For a firm with, say, 150 GST clients, GSTR-9 is mostly a scheduling problem. A plan that works for many offices looks something like this:

• Early October: sort clients into three groups. Above ₹5 crore (GSTR-9 and 9C), ₹2 to 5 crore (GSTR-9 only), and up to ₹2 crore (optional, decided client by client).
• October: send document requests (sales and purchase registers, credit note lists, reversal workings, provisional or audited financials) and start with the ITC reconciliation, because that's the part with a hard cut-off.
• By 20 November: claim missed ITC in the October GSTR-3B and push through any GSTR-1 corrections.
• 1 to 20 December: prepare, review and file. Take the 9C clients first, since they depend on audited numbers and take longest.
• Internal deadline of 20 December. The portal tends to slow down in the last week, and one client always sends documents late.

Give each client one owner and one internal due date. The firms that struggle in December are usually not short of skill. They just can't see which of 150 returns are stuck, and why.

Should you file GSTR-9 when it's optional?

Practitioners genuinely disagree on this. The case for filing: it forces a proper year-end reconciliation and leaves a clean, filed record of the year. The case against: it's a declaration that can't be revised, and for a small client with untidy books it may just put errors on record.

A reasonable middle path is to file for clients whose books reconcile cleanly, especially those close to ₹2 crore who may cross it next year anyway, and make a considered call for the rest. Whatever you decide, note the decision and the reason on the client file.

Late fee for a delayed GSTR-9

The late fee depends on aggregate turnover. The amounts below are combined CGST and SGST, and the cap applies separately under each Act.

You can work out the exact figure for a client with our GST late fee calculator, and our guide to the GST late fee structure covers the other returns.

FAQs

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

31 December 2026. GSTR-9C for the same year is due on the same date, unless the government extends it.

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

No. It's optional for taxpayers with aggregate turnover up to ₹2 crore. They can still file it if they choose to.

Can GSTR-9 be revised after filing?

No. There's no revision facility, which is why the reconciliation has to be done before filing, not after.

Does GSTR-9C need to be certified by a CA?

Not any more. Since FY 2020-21 it has been self-certified by the taxpayer, although most businesses above ₹5 crore still have their CA prepare it.

Is it better to file GSTR-9 early?

Not before 30 November, usually. Filing the annual return closes the window to claim missed ITC, declare credit notes and fix GSTR-1 errors for that year, so an early filing can cost the client money.

Due dates and GST rules can change through notifications and extensions. Check the latest position on the GST portal and CBIC website before filing.