GST Audit Limit for FY 2025-26: ₹5 Crore GSTR-9C Threshold, No CA/CMA Audit
Updated: Sep 3
GST audit limit for FY 2025-26: there is no separate turnover threshold that triggers a mandatory GST audit by a Chartered Accountant or Cost Accountant. Section 35(5), which earlier required professional certification, was omitted with effect from 1 August 2021. The key current threshold is aggregate turnover exceeding ₹5 crore for a self-certified Form GSTR-9C under Rule 80(3), subject to the applicable annual-return rules and exclusions.
Freshness check — 3 September 2026: the current CBIC framework continues to use self-certified GSTR-9C for registered persons whose aggregate turnover exceeds ₹5 crore. The ordinary FY 2025-26 annual-return timeline remains 31 December 2026 unless the Government issues a valid extension or specific relief.
GST Audit Limit for FY 2025-26: What the ₹5 Crore Threshold Actually Means
Businesses continue to search for a “GST audit limit” because the pre-2021 regime used a turnover-based professional audit requirement. That terminology is now outdated. The present compliance question is not “When must a CA/CMA conduct a GST audit?” but rather “When is Form GSTR-9C required, and what annual-return reconciliation should management perform?”
1. What happened to Section 35(5)?
Before 1 August 2021, Section 35(5) of the CGST Act required specified registered persons above the prescribed turnover limit to get their accounts audited by a Chartered Accountant or Cost Accountant and submit audited annual accounts with a reconciliation statement. The Finance Act, 2021 omitted that sub-section with effect from 1 August 2021.
This means that for FY 2025-26 there is no independent statutory GST audit under Section 35(5) merely because turnover crosses ₹2 crore, ₹5 crore or another figure. The old professional-certification model should not be confused with today’s self-certified annual-return framework.
2. What is the current FY 2025-26 threshold?
Rule 80(3) currently requires a registered person whose aggregate turnover during a financial year exceeds ₹5 crore to furnish a self-certified reconciliation statement in Form GSTR-9C along with Form GSTR-9. The ordinary statutory timeline is 31 December following the end of the financial year, unless the Government later extends or modifies the deadline.
For a detailed threshold and filing guide, see
3. “No GST audit” does not mean “no GST reconciliation”
The removal of mandatory CA/CMA certification does not reduce the underlying reconciliation risk. Management is still responsible for the accuracy of GSTR-9 and, where applicable, self-certified GSTR-9C. A defensible year-end file should reconcile turnover, tax liability, input tax credit, reverse-charge transactions, credit/debit notes, e-invoice data, GSTR-1, GSTR-3B, GSTR-2B and the audited financial statements.
In practice, the absence of a statutory external-certification requirement makes internal controls more important, not less. Errors in annual return data can flow into departmental scrutiny, DRC proceedings, ITC disputes and later litigation.
4. Which turnover should be checked for the ₹5 crore test?
The threshold refers to aggregate turnover, a PAN-based concept under the CGST Act. It therefore requires an all-India review across registrations of the same legal person rather than a GSTIN-by-GSTIN turnover test. Teams should reconcile the PAN-level figure before concluding that GSTR-9C is not applicable.
5. Practical example
Example: A company has registrations in Gujarat, Maharashtra and Karnataka. Its outward turnover is ₹2.1 crore, ₹1.8 crore and ₹1.6 crore respectively. Looking at each GSTIN separately may suggest that none crosses ₹5 crore. But the PAN-level aggregate is ₹5.5 crore. Subject to the statutory rules and exclusions, the company should evaluate GSTR-9C applicability on that aggregate basis.
6. What should a finance team reconcile before filing?
• Turnover per audited financial statements vs GSTR-1 and GSTR-3B.
• Tax liability reported vs tax actually discharged, including reverse charge.
• ITC per books vs GSTR-2B vs GSTR-3B, with blocked and reversed credits identified.
• Credit notes, debit notes, advances and amendments posted in later tax periods.
• E-invoice and e-way bill data where applicable.
• Exempt, nil-rated, non-GST and zero-rated supplies.
• Branch/stock transfers and cross-charges between registrations.
• Unreconciled differences carried into GSTR-9 and GSTR-9C with supporting explanations.
7. Common mistakes to avoid
Mistake 1: Treating ₹5 crore as a CA/CMA audit threshold. It is currently relevant to the self-certified GSTR-9C framework, not to the omitted Section 35(5) professional audit.
Mistake 2: Checking turnover GSTIN-wise instead of PAN-wise aggregate turnover.
Mistake 3: Assuming self-certification means the reconciliation can be superficial. Management remains responsible for the numbers filed.
Mistake 4: Waiting until December to identify annual-return mismatches. Material GSTR-1/GSTR-3B/ITC differences are usually easier to correct or explain when identified earlier.
8. Does the GST Department still have audit powers?
Yes. The omission of Section 35(5) did not remove departmental audit powers. Section 65 permits audit by tax authorities, subject to the statutory procedure. Businesses should therefore distinguish between the old taxpayer-obtained professional audit and a departmental audit initiated under the CGST Act.
9. FY 2025-26 decision checklist
1. Compute PAN-level aggregate turnover for FY 2025-26.
2. Identify whether Form GSTR-9 is applicable.
3. If aggregate turnover exceeds ₹5 crore, evaluate Form GSTR-9C applicability under Rule 80.
4. Do not appoint a CA/CMA merely because of the old Section 35(5) threshold; separately consider normal financial-statement audit requirements under other laws.
5. Complete GSTR-1, GSTR-3B, GSTR-2B and books reconciliation before annual-return filing.
6. Preserve explanations and supporting schedules for material differences.
7. Track any CBIC notification extending or modifying the FY 2025-26 annual-return deadline.
FAQs
Does ₹5 crore mean a statutory GST audit is required for FY 2025-26?
No. The ₹5 crore figure is relevant to the self-certified GSTR-9C reconciliation statement under Rule 80(3); it is not a threshold for reinstating the old CA/CMA-certified audit under omitted Section 35(5).
Is GST audit by a CA mandatory for FY 2025-26?
No separate CA/CMA GST audit is mandated under the former Section 35(5), because that provision was omitted with effect from 1 August 2021. Other audits under the Companies Act, Income-tax Act or sectoral law may still apply independently.
What is the GST audit turnover limit for FY 2025-26?
If by “GST audit limit” you mean the current annual reconciliation requirement, the important threshold is aggregate turnover exceeding ₹5 crore for self-certified Form GSTR-9C under Rule 80(3).
Is GSTR-9C still certified by a Chartered Accountant?
Under the current post-2021 framework, GSTR-9C is self-certified by the taxpayer rather than mandatorily certified by a Chartered Accountant or Cost Accountant.
What is the normal due date for GSTR-9C for FY 2025-26?
The ordinary statutory due date is 31 December 2026 along with the annual return, unless an extension or other specific relief is notified.
Can the GST Department still audit a business?
Yes. Departmental audit under Section 65 is distinct from the omitted professional audit requirement under former Section 35(5).
Related PGT & Associates guides
Primary sources
How PGT & Associates can help
PGT & Associates assists businesses with GST annual-return diagnostics, GSTR-9/GSTR-9C reconciliation, ITC and turnover reviews, mismatch analysis and preparation of defensible supporting schedules. For material year-end differences or uncertain annual-return positions, an early reconciliation is usually more efficient than trying to resolve inconsistencies after filing.
Disclaimer: This article is for general professional information and is based on the legal position reviewed as of 23 August 2026. GST law, forms, thresholds, notifications and due dates can change. Obtain advice for your specific facts before acting.
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