GSTR-9, 9C for FY 2025-26: What Has Changed

The GST portal switched on GSTR-9 and GSTR-9C for FY 2025-26 on 8 October 2026, and the due date is 31 December 2026 unless it is extended. Some circulars describe a brand-new form, but most of the layout was reset last year; the real shake-up is the 22 September 2025 rate change, which means one product code can appear twice in Table 17 . This guide explains who must file, what to download first, the four tables where mistakes happen, why the 30 November credit cut-off should shape your filing date, and which popular claims we could not verify.

Quick answers for FY 2025-26

What actually happened this October

Every year around this time, my inbox fills with the same message: “Big change in the annual return, act now!” After 10 years of watching how people search and what they really need, I have learned that the loudest headline is rarely the most useful one. So let us slow down and separate what is confirmed from what is rumour.

The official news

The official news is simple. GSTN’s advisory dated 13 October 2026 says the annual returns in Form GSTR-9 and GSTR-9C for FY 2025-26 have been enabled on the portal from 8 October 2026 . It also reminds taxpayers that the filing tile will appear only after every GSTR-1 and GSTR-3B for the year has been filed.

The due date is 31 December 2026, unless extended . That date comes from Section 44 of the CGST Act, read with Rule 80 of the CGST Rules . The advisory itself does not list any new validations or a “five changes” list .

Do you need to file GSTR-9 and GSTR-9C?

Turnover limits in plain words

Taxpayers with aggregate turnover up to ₹2 crore are exempt from filing GSTR-9 under Notification 15/2025-Central Tax . Above ₹2 crore, GSTR-9 is generally mandatory. If your turnover is above ₹5 crore, you also file GSTR-9C, the reconciliation statement .

GSTR-9C is now self-certified. That means you or your authorised signatory certify it, and no CA signature sits on the form itself . Many businesses still ask a CA to prepare the workings, and I think that is wise, because you are the one signing off.

What if the filing tile is missing?

On 10 October, some taxpayers reported a glitch: the portal kept asking for returns that were already filed, which blocked the annual return . If this happens to you, first check the status of each month or quarter. Then raise a ticket on the GSTN helpdesk, as the advisory suggests.

Four places where mistakes happen

The annual return has 19 tables, but most notices and headaches come from a handful. Here are the four that deserve your time.

Tables 4 and 5: outward supplies

These tables fill automatically from GSTR-1 and IFF. Since FY 2024-25, supplies added or amended through GSTR-1A are also included . You can edit the figures, but published FAQs say a cell turns red when your number differs from the system value by more than 20 percent, and the portal asks you to confirm .

The circular says any edit turns the box red. Either way, a red cell is an invitation for a question, so keep a short working note that explains the gap between GSTR-1, GSTR-3B and your books.

Tables 6 and 7: credit you claimed and credit you reversed

Table 6A1 holds credit of the earlier year that you claimed this year. It arrived with the revised form, so it is not new for FY 2025-26 . Credit you reclaim under Rule 37 (supplier not paid within 180 days) or Rule 37A (supplier has not filed GSTR-3B) belongs in Table 6H, not 6A1 .

Table 7 now asks for reversals row by row, with separate lines for Rules 37, 37A and 38 . Sources differ slightly on which label (7A, 7A1 or 7A2) matches which rule, so read the labels on the utility before you type anything . Keep a separate ledger for reversals and reclaims. It makes this table far easier.

Table 8: credit on the portal versus credit you took

Table 8A is built from GSTR-2B. For FY 2025-26, it includes FY 2025-26 invoices that show up in your GSTR-2B up to October 2026, which means late-reported invoices count too .

Your actions on the Invoice Management System (IMS) do not change GSTR-9 directly. They matter because accepted or deemed-accepted invoices flow into GSTR-2B, and GSTR-2B feeds Table 8A . Some commentators add that rejected invoices will not appear in 8A . So if you rejected an invoice but later paid the supplier, expect a difference to explain.

There is also a newer row, Table 8H1, for import IGST of FY 2025-26 that you claim next year. It is compared with customs data, so keep your bills of entry handy .

Table 17: the HSN summary

Table 17 is mandatory. The usual rule is 6-digit HSN codes if turnover is above ₹5 crore, and 4-digit codes below that . The twist for FY 2025-26 is big enough to deserve its own section.

The Table 17 trap, explained with numbers

On 22 September 2025, India moved to the “GST 2.0” structure, with main slabs of 5 percent and 18 percent plus a 40 percent rate for some goods . Table 17 reports the HSN code, the rate and the value together. So if a product’s rate changed mid-year, the same code needs two lines: one up to 21 September and one from 22 September .

Here is a real-world example. Take readymade garments. Before 22 September, apparel up to ₹1,000 per piece was taxed at 5 percent, and anything above that at 12 percent . Since then, pieces up to ₹2,500 attract 5 percent, and pieces above ₹2,500 attract 18 percent .

That means three groups behave differently. Garments up to ₹1,000 stayed at 5 percent. Garments from ₹1,001 to ₹2,500 fell from 12 percent to 5 percent. Garments above ₹2,500 rose from 12 percent to 18 percent. The circular’s example treats all garments up to ₹2,500 as a 12-to-5 move, which is too simple for most sellers.

Now the arithmetic, using illustrative figures for goods that moved from 12 to 5 percent. Sales of ₹18,00,000 before 22 September at 12 percent give tax of ₹2,16,000. Sales of ₹21,00,000 after that date at 5 percent give ₹1,05,000. The correct total tax is ₹3,21,000.

If you instead show one row of ₹39,00,000 at 5 percent, the tax comes to ₹1,95,000. That understates the tax by ₹1,26,000. The circular claims the portal will then generate a system notice. I could not confirm that, but the gap would be easy for an officer to spot against GSTR-1 and GSTR-3B.

Two practical tips. First, use the HSN download from the GST dashboard, which gives your GSTR-1 data in a Table 17 style, and then split any code whose rate changed . Second, check that your HSN rows add up to the taxable outward supply in Table 4. Practitioners recommend this as a self-check, though I could not confirm that the portal blocks the return when it does not match .

Which filing date is smartest?

This is the part most guides skip. The last date to claim FY 2025-26 input tax credit under Section 16(4) is 30 November 2026, or the date you file GSTR-9 if that comes earlier . So filing the annual return early can close the door on credit you have not yet claimed.

Last year’s guidance pointed the same way: practitioners advised filing only after 1 December so that Table 8A would be complete . My practical reading, and not tax advice, is simple. Finish your reconciliation in November. Claim any eligible credit in GSTR-3B before the cut-off. Then file GSTR-9 in early or mid December, leaving a buffer before 31 December.

Because a delay could cost you money, also keep an eye on CBIC notifications. Due dates have moved in the past, but never plan around a hoped-for extension.

Documents to download before you start

Gather everything first. It saves you from jumping between screens and makes the reconciliation calmer.

1. GSTR-1 and GSTR-3B for all 12 months (or four quarters).
2. GSTR-2B from April 2025 to October 2026, because Table 8A draws on it .
3. The HSN summary download from the dashboard, for Table 17 .
4. Electronic credit ledger, cash ledger and liability ledger.
5. Your purchase register and books of account, for reconciliation.
6. IMS reports showing which invoices you accepted, rejected or kept pending.
7. Bills of entry or customs data for imports, for Table 8H1 .

Late fees: what to expect

For GSTR-9, the late fee depends on turnover, and it applies per day under both CGST and SGST. From FY 2022-23, the combined amounts are ₹50 a day for turnover up to ₹5 crore (capped at 0.04 percent of state turnover), ₹100 a day for ₹5 to ₹20 crore (same cap), and ₹200 a day above ₹20 crore (capped at 0.5 percent) .

Whether GSTR-9C carries a separate late fee is unclear. One source says there is no separate fee because 9C cannot be filed before 9, while the circular says it is calculated separately . The safe approach is to file both on the same day and avoid the question.

Claims we could not verify

Honesty builds trust, so here are the circular’s points that we could not find in any official or practitioner source. Test them on the portal before you rely on them.

1. That the portal was updated on 20 October (GSTN says tiles were enabled on 8 October) .
2. That any edit in Table 4 turns red (published FAQs mention a 20 percent deviation) .
3. That Table 8D shows a large negative will trigger a DRC-01C notice automatically.
4. That Table 8B now matches only Table 6B.
5. That a new “actual ITC considered” section with remarks exists in the 8A download.

Final thoughts

The headline is calm: the forms are live, the date is 31 December, and most of the structure is the same as last year. The real work is in the details, especially the Table 17 rate split and the November credit cut-off. Download early, reconcile properly, split your HSN rows, and file when your credit is settled.

Frequently asked questions

Can I revise GSTR-9 after filing it?

Generally no. Practitioners note that GSTR-9 cannot be revised once filed, and extra tax found later is paid through Form DRC-03 . That is why a calm reconciliation before filing is worth the effort.

Do I need a CA to file GSTR-9C?

Not for the form itself, since it is self-certified . But preparing the reconciliation is technical, so a CA’s help can save you from errors.

Will the due date be extended?

Nobody can promise this. The default date is 31 December 2026, unless CBIC notifies otherwise . Plan to file well before it.

What if my GSTR-1 and GSTR-3B do not match?

Fix it before filing. Differences will flow into Tables 4 and 8 and will be visible to officers. Where tax is short, many professionals use DRC-03 to pay it with a note of explanation .