GSTR-9 and GSTR-9C for FY 2025-26: checklist before 31 December 2026
The annual return is where a year of monthly filings gets checked against your books. Filed carelessly, it becomes the starting point for scrutiny; filed well, it closes the year. Here is what applies for FY 2025-26 and how to prepare before 31 December 2026.
Who must file
- GSTR-9 (annual return) — regular taxpayers. In recent years, businesses with aggregate turnover up to ₹2 crore have been exempted from filing it; check the notification for your year before skipping it.
- GSTR-9C (reconciliation statement) — required where aggregate turnover exceeds ₹5 crore. It is self-certified by the taxpayer.
- Composition taxpayers file GSTR-4 instead, and some categories (such as casual taxable persons) are outside GSTR-9.
Due date and late fees
For FY 2025-26, both are due by 31 December 2026. Late fees for GSTR-9 depend on turnover: ₹50 a day for turnover up to ₹5 crore and ₹100 a day for ₹5–20 crore (each capped at 0.04% of turnover in the state), and ₹200 a day above ₹20 crore (capped at 0.5%).
Two dates that come before the annual return
Input tax credit for FY 2025-26 can be claimed only up to 30 November 2026 (or the annual return, if filed earlier), and corrections to FY 2025-26 invoices in GSTR-1 also close around that time. Credit you missed by then cannot be added through GSTR-9 — so the review should start in October, not December.
The reconciliation checklist
- Turnover in GSTR-1 and GSTR-3B agrees with your audited or final books, month by month.
- Tax liability declared equals tax actually paid; any shortfall is paid through DRC-03 with interest.
- ITC in GSTR-3B is matched with GSTR-2B and the purchase register (Table 8 of GSTR-9 shows the gap).
- Reversals are reported — Rule 42/43 for exempt supplies, and credit on invoices not paid within 180 days.
- Reverse charge liability and ITC on it are both reported.
- HSN-wise summary of outward and inward supplies is ready.
- Amendments made in later months are traced back to the right period.
Key takeaways
- FY 2025-26 annual returns are due by 31 December 2026.
- GSTR-9C applies above ₹5 crore turnover; GSTR-9 exemptions below ₹2 crore have been notified year by year.
- ITC for FY 2025-26 must be claimed by 30 November 2026 — GSTR-9 can’t revive missed credit.
- Start reconciling in October.
Our GST audit and annual-return service starts at ₹12,000 — full reconciliation, GSTR-9 and GSTR-9C where required, filed before the deadline.
General information, reviewed on 2 October 2026 — not advice for your specific case. Rules change; talk to us before acting.