GSTR-9: due date, applicability and what trips people up

GSTR-9 for financial year 2025-26 is due by 31 December 2026. It is the annual return consolidating a registered person’s outward supplies, input tax credit and tax paid for the year.

Filing is mandatory where aggregate turnover exceeds ₹2 crore. Below that it is optional, though there are good reasons to file voluntarily where your books and returns do not already agree.

Where turnover exceeds ₹5 crore, a self-certified reconciliation statement in GSTR-9C must also be filed, reconciling the annual return to the audited financial statements.

The following are outside GSTR-9 entirely: composition dealers, who file GSTR-9A where applicable; casual taxable persons; non-resident taxable persons; input service distributors; and persons deducting tax under section 51 or collecting under section 52.

Everyone else who was registered for any part of the year — including registrations cancelled mid-year — is potentially within it.

GSTR-9 is not a copy of your monthly filings. It requires four sets of numbers to be aligned:

• Your books of account
• GSTR-1, your reported outward supplies
• GSTR-3B, what you actually paid
• GSTR-2B, the credit available to you

Differences between these are normal and arise from timing, credit notes, amendments and suppliers filing late. The annual return is where they have to be explained rather than carried forward.

Where the reconciliation shows tax short-paid, it can be discharged through Form DRC-03 before filing. This is the mechanism that makes the annual return useful — it is an opportunity to correct the year cleanly rather than wait for a notice.

Late filing attracts ₹200 per day — ₹100 under CGST and ₹100 under SGST — capped at a percentage of turnover in the state or union territory. The cap sounds protective until you apply it to a business with meaningful turnover.

More practically, an unfiled annual return keeps the year open and is a standard trigger for departmental scrutiny.

The reconciliation takes longer than people expect, particularly where suppliers have filed late or credit notes were issued across period ends. Businesses that begin in December routinely file with unexplained differences simply to meet the date, which defeats the point.

Beginning the reconciliation in October leaves time to chase suppliers, obtain missing invoices and correct genuine errors through DRC-03 rather than discovering them in an assessment two years later. Forms and utilities are on the GST portal.