GSTR-9 (the GST annual return for FY 2025-26) is due on 31 December 2026. Every GST-registered taxpayer who does not qualify for exemption must file it—and CA firms managing multiple clients must plan data collection, reconciliation, and GSTR-9C (for turnover above ₹5 crore) well ahead of December.

GSTR-9 Key Dates for FY 2025-26

ParticularsDate
GSTR-9 (Annual Return) due date31 December 2026
GSTR-9C (Reconciliation Statement) due date31 December 2026 (same)
Earliest date to file GSTR-9 (portal opens)Typically April 2026 for FY 2025-26
Turnover threshold for mandatory GSTR-9CAbove ₹5 crore
Late fee (after Dec 31)₹200/day (₹100 CGST + ₹100 SGST)
Maximum late fee cap0.25% of turnover in the state

Who Must File GSTR-9 for FY 2025-26?

All GST-registered taxpayers except:

  • Composition scheme dealers (they file CMP-08 quarterly)
  • Casual taxable persons
  • Non-resident taxable persons
  • Input Service Distributors
  • OIDAR service providers
  • Taxpayers with nil outward supplies throughout the year and nil ITC (government may issue a specific exemption; check GSTN portal)

What Information Goes Into GSTR-9?

SectionData RequiredSource
Outward suppliesTotal taxable, exempt, nil-rated, non-GST supplies; exports; advancesSales register + GSTR-1 filed returns
ITC claimedITC from B2B purchases, imports, reverse charge; ITC reversedGSTR-2B (auto) + purchase register
Tax paidComparison of tax paid in GSTR-3B vs. actual liabilityGSTR-3B filed + cash/ITC ledger
HSN summaryHSN-wise outward supply summary (mandatory for turnover > ₹5 crore)Itemised sales data
Late fees / penaltiesLate fees paid during the yearPayment challan records
Demands & refundsGST demands paid, refunds claimedGSTN compliance history

Common Reconciliation Issues CA Firms Find in GSTR-9

GSTR-9 requires reconciling the annual totals from the 12 months of GSTR-1 and GSTR-3B filed during the year. Common mismatches:

  • GSTR-1 vs. GSTR-3B difference: If sales were declared in GSTR-1 but tax was paid later in 3B, or if amendments were made—needs explanation
  • ITC in books vs. ITC in GSTR-3B: ITC claimed in 3B may differ from books if timing differences exist
  • Amendments not carried forward: Credit notes / amendments made in one period may affect annual totals
  • RCM payments not tracked: Reverse charge transactions often undercounted in annual summary

Planning the GSTR-9 Season: A CA Firm Timeline

MonthAction
May–June 2026Finalise FY 2025-26 books for all GST clients; begin annual reconciliation of GSTR-1 and GSTR-3B
July–August 2026Prepare GSTR-9 draft for each client; identify differences requiring amendment or explanation
September 2026Begin GSTR-9C preparation for clients above ₹5 crore turnover; coordinate with auditors
October–November 2026File GSTR-9 for straightforward cases; finalize GSTR-9C reconciliation statements
December 1–25, 2026File remaining GSTR-9 and GSTR-9C; never wait until Dec 31 (portal congestion risk)

TaxZeo tracks GSTR-9 filing status for every client and flags those requiring GSTR-9C based on turnover—so your team stays ahead of the December 31 deadline.

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Frequently Asked Questions

Has the GSTR-9 due date ever been extended past December 31?

Yes. CBDT/GSTN have extended GSTR-9 due dates in several years, including during the COVID pandemic and in years when the portal had technical issues. However, CA firms should always plan to file by December 25 to avoid portal congestion in the final days. Do not plan workloads assuming an extension will come.

Is GSTR-9 filing optional for small taxpayers?

The government has periodically made GSTR-9 optional for taxpayers with turnover below certain thresholds (most recently ₹2 crore in some years). However, this waiver is announced separately for each financial year and is not automatic. Check GSTN circulars after April 2026 for the official FY 2025-26 optionality notification.

What is the late fee if GSTR-9 is filed after December 31?

Late fee is ₹200 per day of delay (₹100 under CGST + ₹100 under SGST), subject to a maximum of 0.25% of turnover in the relevant state or UT. There is no interest charge separately for GSTR-9 non-filing, but if tax was underpaid during the year and is paid now, Section 50 interest at 18% per annum applies on the tax difference.