If your business is registered as a regular GST taxpayer and its aggregate turnover for the year was more than ₹2 crore, you file GSTR-9 for that year by 31 December of the following year. Above ₹5 crore, you also attach a self-certified reconciliation statement, GSTR-9C. At ₹2 crore or below, the annual return is not compulsory from FY 2024-25 onwards. So the FY 2025-26 return, for those who must file it, is due on 31 December 2026.
That is the whole rule in one paragraph. The rest of this post covers the edge cases that decide which side of it you fall on. If you already know you must file and would rather hand it over, our GST return filing service prepares and files GSTR-9 and GSTR-9C along with the monthly or quarterly returns.
Where you stand, by turnover
| Aggregate turnover in the financial year | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to ₹2 crore | Exempt from FY 2024-25 onwards (you may still file) | Not required |
| Above ₹2 crore, up to ₹5 crore | Required | Not required |
| Above ₹5 crore | Required | Required, self-certified, filed with GSTR-9 |
The duty to file comes from section 44 of the CGST Act, which also lets the Government exempt a class of taxpayers. The form, the 31 December date and the ₹5 crore GSTR-9C threshold are in rule 80 of the CGST Rules. The ₹2 crore exemption was notified in September 2025 (Notification No. 15/2025-Central Tax), with matching State notifications such as this one from Meghalaya.
The turnover that counts is PAN-wide
The test uses aggregate turnover, which adds up all GSTINs on the same PAN across India. It is not the turnover of one registration. Take a trader with a ₹2.6 crore GSTIN in Gujarat and a ₹60 lakh GSTIN in Rajasthan. Aggregate turnover is ₹3.2 crore, so both GSTINs file GSTR-9, the small one included. The return itself is filed separately for each GSTIN, as the GST portal’s GSTR-9 FAQ confirms.
Two other details matter at the margins:
- The figure is for the year being reported, not the previous year. A business that crossed ₹2 crore for the first time in FY 2025-26 files for FY 2025-26.
- Exempt supplies, exports and inter-State supplies are part of aggregate turnover. A business with mostly exempt sales can still cross the line.
Who never files GSTR-9
Section 44 leaves out several kinds of registration altogether, whatever the turnover:
- Input Service Distributors;
- persons deducting tax at source (section 51) or e-commerce operators collecting it (section 52), who have their own statements;
- casual taxable persons and non-resident taxable persons.
The portal FAQ adds suppliers of online information and database access services from outside India. Composition taxpayers do not file GSTR-9 either. Their annual return is GSTR-4 under rule 62.
One group that often assumes it is out but is not: a business whose registration was cancelled during the year. If it was a regular taxpayer above the threshold, the portal FAQ says the annual return is still due for that year. So is anyone who moved from composition to regular in the middle of the year, for the regular part.
GSTR-9C: what changed and what did not
GSTR-9C reconciles the turnover and tax in your returns with your audited financial statements. Since a 2021 change to rule 80 it has been self-certified by the taxpayer, and a professional’s certificate is no longer required. It applies above ₹5 crore.
The point many businesses learned the hard way: if you need a GSTR-9C and file only the GSTR-9, the annual return is treated as not filed. CBIC Circular No. 246/03/2025-GST says the late fee runs from the due date until both are in. If you are above ₹5 crore, plan the reconciliation with the return, not after it.
What a late GSTR-9 costs
Section 47(2) sets the late fee for the annual return at ₹100 for each day of delay, capped at 0.25% of turnover in the State. For returns from FY 2022-23 onwards, Notification No. 07/2023-Central Tax waives anything above a lower figure for smaller businesses:
| Aggregate turnover in the year | Late fee under the CGST Act (after the waiver) |
|---|---|
| Up to ₹5 crore | ₹25 a day, capped at 0.02% of turnover in the State or UT |
| Above ₹5 crore, up to ₹20 crore | ₹50 a day, capped at 0.02% of turnover in the State or UT |
| Above ₹20 crore | No waiver: ₹100 a day, capped at 0.25% |
These are the central tax amounts. An equal amount generally applies under the State or UT GST law, so the total you see on the portal is usually double the figure in the table.
The three-year cut-off
Since a 2023 amendment, section 44(2) says an annual return cannot be filed once three years have passed from its due date. If an older annual return is still pending, check with your adviser whether it is still within that window, and deal with it now. Once it is barred, you cannot file it at all, and the notices that follow are harder to answer.
Before you file: what to check
GSTR-9 is mostly auto-filled from your GSTR-1 and GSTR-3B. That makes it easy to file without thinking, which is the risk. It cannot be revised after filing. Before you submit, line up four sets of figures:
- Books against GSTR-1: every sales invoice, credit note and debit note in the year.
- GSTR-1 against GSTR-3B: any tax shown in GSTR-1 but not paid through GSTR-3B is extra liability. You pay it through Form DRC-03 before or along with the annual return.
- Input tax credit claimed against GSTR-2B: credit with no matching supplier invoice is a likely question in any later scrutiny.
- Credit for the year still to be claimed: under section 16(4), credit for a year must be taken by 30 November of the next year or by the date you file the annual return, whichever is earlier. Filing GSTR-9 early can close that window early.
Point 4 is easy to miss. A business that files its FY 2025-26 annual return in October 2026 loses any FY 2025-26 credit it has not claimed by then, even though 30 November has not arrived.
Frequently asked questions
My turnover is under ₹2 crore. Should I file GSTR-9 anyway?
You may, but you are not required to from FY 2024-25. Some businesses file to have a clean year-end record. Others skip it and rely on their monthly or quarterly returns. Either is lawful.
Can I file a nil GSTR-9?
Yes, if you were above the threshold but had no supplies or credit to report. The portal offers a simplified nil filing where it applies.
Does GSTR-9 replace my income tax audit?
No. GSTR-9C reconciles with your audited financial statements, but the audit itself is under other laws.
Complianto (complianto.in), operated by Mentorcorp Private Limited, is a private consultancy and is not affiliated with any government body. We do not issue official documents. We charge a professional fee for application assistance and advisory services. Applicants can apply directly to the government without our fees via the official portals: MCA (mca.gov.in), Income Tax (incometax.gov.in), GST (gst.gov.in), MSME (udyamregistration.gov.in), FSSAI (foscos.fssai.gov.in), Startup India (startupindia.gov.in), and IP India (ipindia.gov.in).
This article is general information, not legal or tax advice.
