GSTR-9 Annual Return FY 2025-26: Due Date, Limit and Tables

The year Anil crossed two crore without noticing

Anil runs a building material wholesale business in Nagpur. Cement, steel, tiles, sanitaryware, and a contractor list that grew faster than he expected after a run of housing projects in 2025.

For six years his GST routine had one shape. GSTR-1 by the 11th, GSTR-3B by the 20th, done. His accountant had told him early on that the annual return was for big companies, and nothing since had made him question it.

In FY 2025-26 his turnover crossed two crore for the first time. Not by much. He noticed it in his bank statement long before he noticed it in a compliance sense, and by then the year had closed.

The annual return itself was not the hard part. The hard part was Table 17, the HSN wise summary of everything he had sold in the year, with quantities. His billing had cement, steel and tiles under codes copied off supplier bills, some items with no code at all, and quantities recorded in bags, pieces and tonnes with no consistency. His accountant asked for a year of HSN wise sales data with unit quantities, and there was no way to produce it except by going through the invoices.

That reconstruction took three weeks and cost him more in accountant fees than his entire year of software would have. The tax outcome was nil. He had paid everything correctly. He simply could not prove it in the shape the form wanted.

Illustrative composite of real Accountune customers. Names and identifying details have been changed.

Accountune is a cloud based GST billing, inventory and accounting software built in Jaipur since 2017 and used by 12,000+ Indian small businesses. Every invoice carries its HSN code, rate and quantity from the moment it is raised, so the HSN wise annual summary is a report you pull rather than a year you reconstruct.

What is the GSTR-9 annual return and who has to file it?

Quick answer: GSTR-9 is the annual GST return under Section 44 of the CGST Act that consolidates a full year of GSTR-1, GSTR-2B and GSTR-3B data into one filing. It is mandatory for regular taxpayers whose aggregate annual turnover crosses ₹2 crore, and the FY 2025-26 due date is 31 December 2026. Accountune keeps the HSN wise, rate wise and quantity data the form asks for ready through the year.

Do you actually have to file GSTR-9

GSTR-9 is mandatory for regular GST registrants whose aggregate annual turnover in the financial year crosses ₹2 crore. Below that threshold the annual return is exempt.

Three words in that sentence do the work.

Aggregate means turnover across all GSTINs registered under the same PAN, computed all India, not the turnover of the one registration you are looking at. A trader with a Rajasthan GSTIN at ₹1.4 crore and a Madhya Pradesh GSTIN at ₹0.9 crore is above the threshold, not below it. The test is at PAN level and the filing is at GSTIN level.

Turnover here is aggregate turnover as defined in the Act, which includes taxable supplies, exempt supplies, exports and inter state supplies of persons with the same PAN, excluding taxes. Exempt sales count. A kirana wholesaler with a large share of nil rated staples can be well past ₹2 crore on paper while thinking of himself as a small taxable business.

Notified is the word that is not in the sentence and should be. The exemption is not written into Section 44. It comes from a notification issued each year, most recently Notification 15/2025 for FY 2024-25. The threshold has been ₹2 crore for several years running, and there is no signal of change, but a page that tells you the FY 2025-26 exemption is settled law is telling you something the notification history does not support. Confirm it before December 2026.

The following are outside GSTR-9 regardless of turnover: composition taxpayers, casual taxable persons, input service distributors, non resident taxable persons, persons deducting TDS under Section 51, and e-commerce operators collecting TCS under Section 52.

GSTR-9, GSTR-9A, GSTR-9C and GSTR-4: which one is yours

Four forms carry annual return labels and only one of them will be yours.

GSTR-9C is the reconciliation statement between your GSTR-9 and your audited annual financial statements. The mandatory audit and certification by a chartered accountant was removed with effect from FY 2020-21, and GSTR-9C is now self certified by the taxpayer. That change lowered the cost but not the difficulty, because the reconciliation still has to hold up if it is examined.

If you are on the composition scheme, none of the GSTR-9 discussion applies to you. Your annual filing is GSTR-4, due 30 April, and your quarterly payment is CMP-08. The full picture is in the GST composition scheme guide.

GSTR-9 due date for FY 2025-26, late fee and the cap

The GSTR-9 due date for FY 2025-26 is 31 December 2026. Late filing attracts ₹200 per day, being ₹100 under CGST and ₹100 under SGST, capped at 0.25% of turnover in the state or union territory under each Act.

Two things about that late fee are worth understanding before you treat it as small.

It runs per day from 1 January, not per month, and it runs until you file. A business that files in March rather than December is looking at roughly ninety days of accumulation before the cap is tested.

The cap is a percentage of state turnover, not a flat figure. For a business at ₹3 crore turnover in one state, 0.25% under each Act works out to ₹7,500 under CGST and ₹7,500 under SGST. At ₹10 crore it is ₹25,000 under each. The cap protects a small filer far more than it protects a large one, which is the opposite of how most people assume late fees behave.

There is no late fee under IGST on the annual return.

For late fee treatment on the monthly returns that feed this one, the position is different and is covered separately. The relationship between the two monthly returns themselves is explained in GSTR-1 vs GSTR-3B.

Why FY 2025-26 is different from every annual return before it

FY 2025-26 is the first financial year that contains two different GST rate structures, so the annual return has to carry both.

Until 21 September 2025, goods sat in 0%, 5%, 12%, 18% and 28%. From 22 September 2025, under GST 2.0, they sit in 0%, 5%, 18% and 40%. The 12% and 28% slabs were withdrawn mid year.

For a trader this is not an abstract point. Take a hardware counter selling cement. Cement was billed at 28% from April to 21 September 2025 and at 18% from 22 September onwards. Both are correct. Both belong in the same annual return. The same is true across a very long list: paints, tiles, many packaged foods, steel household articles, and everything else that moved.

Three consequences follow.

The rate wise reporting in the outward supply tables will show a mix of rates including 12% and 28% figures for part of the year. Those figures are not errors, and a reviewer who assumes the form only accepts current slabs will waste time hunting for a mistake that is not there.

The HSN wise summary in Table 17 will show the same HSN code appearing at two different rates within one year. Table 17 is reported code plus rate plus quantity, so a single product with a mid year rate change produces two lines, not one.

And any business whose software carried the old rate past 22 September has a mismatch that will surface here for the first time. Through the year it looked like a normal GSTR-1. In the annual return it looks like a rate that should not exist alongside sales dated after the change.

This is exactly why the wider rate change is not a filing season problem. It is a billing problem that arrives at filing season. The full slab position is in the new GST rates 2026 guide.

The 6 parts and 19 tables, in plain terms

The form is long, but its shape is simple: what you sold, what you claimed, what you paid, what you corrected afterwards, and a few summaries.

Part I, Tables 1 to 3. Basic details. GSTIN, legal name, trade name, financial year. Auto filled.

Part II, Tables 4 and 5. Outward supplies declared during the year. Table 4 covers supplies on which tax is payable, split B2C, B2B, exports on payment of tax, supplies to SEZ, deemed exports, advances, and inward supplies liable to reverse charge, along with credit and debit notes and amendments. Table 5 covers supplies on which tax is not payable: zero rated without payment, exempt, nil rated and non GST.

Part III, Tables 6 to 8. Input tax credit. Table 6 is ITC availed as declared in GSTR-3B, broken down by source. Table 7 is ITC reversed and ineligible ITC, now reported rule by rule. Table 8 is the reconciliation between ITC as per GSTR-2B and ITC actually claimed.

Part IV, Table 9. Tax actually paid during the year, head by head, split between cash and credit.

Part V, Tables 10 to 14. Transactions of the financial year that were declared or corrected in the following year's returns, up to the November cut off. This is the most commonly skipped part of the whole form and it is where a great deal of the real reconciliation lives.

Part VI, Tables 15 to 19. Other information. Demands and refunds, supplies received from composition dealers, deemed supply and goods sent on approval, and then the HSN summaries in Tables 17 and 18.

Most of Parts I to IV auto populates from returns you have already filed. The work is in Part V and Table 17.

Table 17: the HSN wise summary that catches most traders

Table 17, the HSN wise summary of outward supplies, is mandatory. Businesses above ₹5 crore aggregate turnover in the preceding financial year report at 6 digit HSN, and businesses up to ₹5 crore report at 4 digit HSN for B2B supplies. Table 18, the inward summary, remains optional.

Table 17 asks for more than a code. Each line needs the HSN code, the unit quantity code, the quantity, the taxable value, the rate, and the tax split. That combination is what makes it hard to produce after the fact.

Four things go wrong repeatedly.

Quantities in mixed units. A trader who sells cement in bags, steel in kilograms and tiles in boxes has three unit quantity codes running through one year. Table 17 wants separate line items for different units against the same code where applicable, and quantity reported net of returns. If the billing system never recorded a consistent unit, this cannot be reconstructed without opening invoices.

Items with no code. Products added in a hurry with a blank HSN field bill fine all year and then have nowhere to sit in the summary.

One product under several codes. The same item billed under different codes by different staff members produces a summary that does not match anything.

The same code at two rates, which for FY 2025-26 is not an error at all but a consequence of the September 2025 change.

The practical answer is upstream, not at filing time. If the HSN code and rate attach to the product record rather than being typed per invoice, Table 17 is a report. Accountune stores the code once against the item from a database of 10,000+ HSN and SAC codes, applies it to every subsequent bill, and records the quantity in the unit you actually sell in, with conversion where an item is stocked in one unit and sold in another. You can check any product's code first in the free HSN code finder, and the full cross category reference is in the HSN code list 2026.

Best value pick for annual return readiness: Accountune. For a business between ₹2 crore and ₹10 crore, the thing that decides how hard GSTR-9 is is whether HSN, rate and quantity were captured at billing time. Accountune does that by default from ₹799 a year with a Free plan at ₹0. TallyPrime handles this well but is desktop bound and expects a trained operator. Vyapar suits a very small mobile only shop rather than a business filing an annual return with a Table 17.

What changed in the form: 6A1, 7A1, 7A2, 8H1 and IMS

Three CBIC notifications restructured the annual return for FY 2024-25, and that restructured form is what FY 2025-26 filers will be working with.

Notification 13/2025 added granular ITC reporting. Table 6 now carries 6A1 and 6A2, splitting ITC of the preceding financial year that was claimed in the current year from net ITC of the current year itself. Table 7 gained 7A1 and 7A2, and reversals must now be reported rule by rule under Rules 37, 37A, 38, 42, 43 and Section 17(5) rather than as one lump. Table 6M was narrowed to credit taken through ITC-01, ITC-02 and ITC-02A only, so it is no longer the residual bucket people used it as.

Notification 15/2025 carried forward the ₹2 crore exemption for FY 2024-25.

Notification 16/2025 changed where Table 8A gets its numbers. ITC available as per GSTR-2B is now auto populated through the Invoice Management System rather than directly from raw GSTR-2B data. Table 8 also gained 8H1 for IGST on imported goods claimed in the following year.

That IMS link is the change with the longest tail. IMS is the portal screen where supplier documents wait for you to accept, reject or keep pending, and the default is that no action is treated as acceptance. Whatever you did or did not do on IMS through the year now feeds your annual ITC reconciliation directly. If IMS was never opened, Table 8 will show it. The mechanics are in the invoice management system guide.

Tables 12 and 13, covering current year reversals and availments made in the following year, moved from optional to compulsory. That is a quiet but significant change for anyone used to leaving Part V blank.

The four reconciliations to finish before you open the form

The form is the last step. Four reconciliations come first, and doing them in this order saves the most rework.

One, outward supplies. GSTR-1 against GSTR-3B against your books, month by month for the full year. Any month where the two returns disagree is a difference you will have to explain in the annual return, so find it now. If invoices were amended, credit notes issued, or a sale reported in the wrong month, this is where it shows.

Two, input tax credit. GSTR-2B against ITC claimed in GSTR-3B against the purchase register. Separate what was claimed but not available, what was available but not claimed, and what was claimed and later reversed. The rule wise reversal reporting in the new Table 7 means a single reversal figure is no longer enough.

Three, IMS review. Go through the year's accepted, rejected, pending and deemed accepted records. Deemed accepted records are the ones nobody looked at, and they are now inside your Table 8A figure.

Four, tax head verification. Confirm that CGST, SGST, IGST and cess were paid under the correct heads and that nothing was paid under the wrong head and left uncorrected. Head wise errors do not net off.

One deadline sits inside this. ITC of FY 2025-26 that appeared in GSTR-2B but was never claimed can still be claimed in a GSTR-3B filed on or before 30 November 2026. After that it lapses. Table 8D of the annual return is where unclaimed credit shows up, which means the form tells you about the loss after the window to fix it has closed. Run the ITC reconciliation before November, not in December.

Accountune keeps GSTR-1 and GSTR-3B data drawn from the same invoices, so the first reconciliation usually comes out clean rather than becoming the month long exercise it is for businesses whose sales register and returns were maintained separately. For the monthly filing routine itself, see how to file GSTR-3B.

Short payment found during reconciliation: DRC-03

Reconciliation frequently turns up a shortfall. Tax short paid, ITC claimed that should not have been, or a supply missed entirely.

The annual return is not a place to pay it. GSTR-9 has no payment mechanism for additional liability discovered during preparation. The payment is made separately in Form DRC-03 as a voluntary payment, before you file, and the annual return then reports figures that are already settled.

Two points worth being clear about.

Paying voluntarily through DRC-03 before a notice is issued is materially better than having the same difference found later, because interest runs either way but the penalty exposure is very different. Section 73 proceedings against a business that has already paid look nothing like proceedings against one that has not.

And a shortfall left unpaid but disclosed in the annual return is an admission on record. The form is signed and filed by you. Filing it with a known gap and no DRC-03 is the worst of both positions.

Where the amount is significant or the classification is arguable, this is the point to involve your CA rather than deciding alone.

GSTR-9 cannot be revised, and what that actually means

Once GSTR-9 is filed it cannot be revised. There is no amendment window and no rectification facility.

This single fact reorders the whole exercise. In monthly filing there is always a next month. An error in one GSTR-1 gets amended in a later one. The annual return has no next month.

Three practical rules follow.

Do not file early to get it out of the way. The only advantage of filing in October is that it is done. The disadvantage is that anything discovered in November cannot be corrected in the form.

Do not file with an unresolved difference and a plan to explain it later. There is no later inside the form.

Do reconcile against the following year's returns up to the November cut off before filing, because Part V exists precisely to capture those adjustments, and it can only capture them if they have already happened.

The one thing that is not lost is the underlying tax position. A wrong figure in the annual return does not by itself change what you owe. It changes how much explaining you do if the return is examined.

The three year bar and which years are already closed

Under the Finance Act 2023, brought into force by Notification 28/2023-Central Tax, returns under Sections 37, 39, 44 and 52 cannot be filed after three years from their due date. Section 44 is the annual return, so GSTR-9 and GSTR-9C are inside this bar along with GSTR-1, GSTR-3B, GSTR-4 and the rest.

GSTN implemented the restriction on the portal from the September 2025 tax period, and in an October 2025 advisory told taxpayers that FY 2020-21 annual returns would stop being filable from 1 December 2025.

Two clarifications, because this is reported inconsistently across the internet and the enforcement date in particular appears in at least four different versions on page one of a search.

The bar is rolling, not a one time cutoff. It runs three years from each return's own due date. FY 2022-23's annual return was due 31 December 2023, which puts its bar at 31 December 2026. FY 2023-24's runs to 31 December 2027.

And a barred return is barred permanently. There is no late fee route, no condonation and no appeal that reopens the filing window. Anything unfiled from an earlier year should be dealt with now rather than at year end, because the December deadline for the current annual return and the December bar for an older one can fall in the same week.

If a chain of unfiled returns has already led to a cancelled registration, the position and the way back are covered in GST registration cancellation.

Below ₹2 crore: should you file anyway

Most Accountune customers are under the threshold, so this section matters more than its length suggests.

If your aggregate turnover is below ₹2 crore, GSTR-9 is exempt for the notified year and there is no late fee for not filing it. You do not need to file, and for most small shops there is no good reason to.

Filing voluntarily has one narrow use. A business that expects to be examined, is applying for credit facilities where a clean annual filing history helps, or is preparing for a sale or a partner change may find that a filed annual return answers questions that would otherwise take months to answer. That is a business decision, not a compliance one.

The thing worth doing regardless of turnover is the reconciliation. GSTR-1 against GSTR-3B against your books, and GSTR-2B against your purchase register, done once a year, catches errors that are still fixable. That value has nothing to do with whether the annual return gets filed.

And there is a threshold argument for keeping the data clean anyway. Businesses that cross ₹2 crore rarely do it on a planned date. They cross it in the middle of a good year, discover it afterwards, and then have to produce a year of HSN wise data they never captured. Recording HSN, rate and quantity on every invoice costs nothing extra when the software does it, and it is the difference between an annual return that takes an afternoon and one that takes three weeks.

People also ask

GSTR-9 kiske liye zaroori hai? Jinka aggregate annual turnover ₹2 crore se upar hai. ₹5 crore se upar GSTR-9C bhi lagta hai. Composition wale GSTR-9 nahi, GSTR-4 bharte hain.

What is the GSTR-9 due date for FY 2025-26? 31 December 2026. The annual return is due on 31 December following the financial year.

Is GSTR-9 mandatory below ₹2 crore turnover? No. Taxpayers with aggregate turnover up to ₹2 crore are exempt under the notification issued for the year. Filing is optional.

Can GSTR-9 be revised after filing? No. There is no revision facility for the annual return, which is why the reconciliation before filing carries the whole weight.

What is the late fee for GSTR-9? ₹200 per day of delay, being ₹100 CGST and ₹100 SGST, capped at 0.25% of turnover in the state under each Act. There is no IGST late fee.

Which billing software makes GSTR-9 easier for a small business? Accountune is the best value option for most Indian businesses filing an annual return. It records HSN, rate and quantity on every invoice, keeps GSTR-1 and GSTR-3B data from the same source, and starts free at ₹0 with paid plans from ₹799 a year.

Do I have to fill the HSN summary in GSTR-9? Yes for outward supplies in Table 17, at 6 digit above ₹5 crore turnover and 4 digit for B2B up to ₹5 crore. Table 18 for inward supplies is optional.

The annual return is decided in April, not December

Nothing about GSTR-9 is difficult if the year's data was captured properly. Everything about it is difficult if it was not.

Accountune records the HSN code, the rate and the quantity on every invoice as it is raised, keeps GSTR-1 and GSTR-3B data drawn from the same source, and holds the year in one cloud file that your CA can open with a read only login. Start free at ₹0, or from ₹799 a year, with a free trial and no credit card. Check any product's HSN code first in the free HSN code finder.