GSTR 9 Due Date for FY 2025-26: GST Audit Last Date 2026 & GSTR-9C

GSTR 9 Due Date for FY 2025-26: What Is Due on 31 December 2026?

GSTR 9 due date for FY 2025-26 is 31 December 2026 under the ordinary Section 44 and Rule 80 framework, unless the Government validly extends the deadline. This is also the GST audit last date 2026 in common search language: there is no separate CA/CMA GST audit. Where GSTR-9C applies, the self-certified reconciliation statement is furnished with the annual return.

Freshness check — 3 September 2026: the current CBIC framework continues to prescribe 31 December following the end of the financial year as the ordinary annual-return deadline. Taxpayers should still recheck for any later government extension before filing.

GST audit last date 2026 is best understood as the annual GST return deadline, not a separate CA/CMA audit deadline. For FY 2025-26, the ordinary due date for GSTR-9 and, where applicable, the self-certified GSTR-9C is 31 December 2026 under the current Section 44 and Rule 80 framework. Businesses should use the months before December to reconcile turnover, tax liability, input tax credit and financial statements rather than treating annual-return filing as a year-end portal exercise.

GST audit last date 2026: what is actually due?

The ordinary statutory deadline is 31 December 2026 for FY 2025-26. There is no separate mandatory CA/CMA GST audit merely because turnover crosses a threshold: the earlier Section 35(5) professional-audit requirement was removed from 1 August 2021. GSTR-9 is the annual return, while taxpayers exceeding the applicable ₹5 crore aggregate-turnover threshold must generally also furnish a self-certified GSTR-9C reconciliation statement with the annual return. Any later Government extension must be checked against the specific notification applicable to FY 2025-26.

Who is generally covered by the annual-return framework?

Section 44 excludes specified categories such as Input Service Distributors, persons required to deduct or collect tax under sections 51 or 52, casual taxable persons and non-resident taxable persons. In addition, the Government may exempt specified classes of registered persons by notification. Because such exemptions are notification-specific, businesses should verify the position applicable to FY 2025-26 before concluding that GSTR-9 is not required.

A practical control is to maintain a GSTIN-wise annual-return applicability matrix showing: legal entity, GSTIN, aggregate turnover, nature of registration, annual-return requirement, GSTR-9C requirement, responsible person and status of reconciliations. For groups with registrations in several States, the turnover analysis should be coordinated centrally rather than left to each GSTIN in isolation.

GSTR-9C: the ₹5 crore threshold still matters

Rule 80(3) requires a self-certified reconciliation statement in Form GSTR-9C where aggregate turnover during the financial year exceeds ₹5 crore, subject to the statutory exclusions and any applicable notification. CBIC Circular No. 246/03/2025-GST dated 30 January 2025 reiterates that, where GSTR-9C is required, the complete annual-return compliance comprises GSTR-9 together with GSTR-9C.

That distinction is operationally important. Filing GSTR-9 while leaving an applicable GSTR-9C pending does not necessarily complete the annual-return obligation for late-fee purposes. The reconciliation statement should therefore be planned as part of the year-end close, not treated as an afterthought after GSTR-9 is filed.

What should be reconciled before filing GSTR-9?

1. Outward supplies: reconcile books, e-invoice data where applicable, GSTR-1/GSTR-1A and GSTR-3B. Differences should be classified by cause — timing, amendments, credit notes, advances, exports, SEZ supplies, deemed exports, reverse-charge items or errors.

2. Tax liability: reconcile tax payable and tax actually discharged through electronic cash and credit ledgers. Investigate liability paid through DRC-03 or arising from return corrections, audits, notices or voluntary payments.

3. Input tax credit: reconcile purchase records with GSTR-2B and the ITC actually availed in GSTR-3B. Identify reversals, blocked credits, Rule 42/43 adjustments, supplier-reporting issues, imports, reverse-charge credits and credits booked in a later period.

4. Credit and debit notes: map the accounting entry, supplier reporting and return-period effect. Annual-return errors often arise when the books capture a commercial credit note but the GST treatment differs.

5. Turnover and financial statements: explain differences between GST turnover and audited/reviewed financial statements. Common causes include non-GST income, Schedule III transactions, branch transfers, unbilled revenue, forex differences, pure-agent items and accounting presentation differences.

6. Prior-period and post-year-end corrections: maintain a schedule of FY 2025-26 items corrected in FY 2026-27. This is essential for documenting why the annual-return figures do not mechanically equal the sum of monthly books for the financial year.

Worked example: why early reconciliation matters

Assume an Indian company has ₹42 crore of aggregate turnover for FY 2025-26 and multiple GST registrations. One GSTIN shows outward taxable supplies of ₹9.80 crore in the books but ₹9.65 crore in GSTR-1 because a March invoice of ₹15 lakh was reported later. Another ₹4 lakh credit note is reflected in the books but not in the GST return. If the team waits until December to investigate, the annual return becomes a search exercise. If it creates an exception register now, each difference can be tied to invoice numbers, reporting periods and the appropriate annual-return treatment.

Because aggregate turnover exceeds ₹5 crore, the entity should also plan for the GSTR-9C reconciliation requirement, subject to the final applicability review for each registration and any notification relevant to FY 2025-26.

Does filing GSTR-9 close the door on later changes?

The GST Portal’s annual-return guidance has historically treated a filed GSTR-9 as non-revisable. That makes pre-filing review significantly more important than ordinary monthly-return preparation. The annual return should be treated as a controlled finalisation process with documented maker-checker review, rather than a portal exercise completed at year-end.

Late fee and the “complete annual return” principle

Section 47(2) provides for late fee where the annual return required under section 44 is not furnished by the due date. CBIC Circular No. 246/03/2025-GST clarifies that where GSTR-9C is required, the annual return is complete only when both GSTR-9 and GSTR-9C are furnished. The GST Portal has also implemented this principle in annual-return functionality.

This means a taxpayer should not look only at the date on which GSTR-9 is filed. If GSTR-9C applies, the filing calendar should target completion of both forms before the statutory due date, leaving enough time for financial-statement and GST-return reconciliation.

FY 2025-26 filing checklist for finance and tax teams

• Confirm GSTR-9 applicability GSTIN by GSTIN and verify any FY 2025-26 exemption notification before relying on an exemption.

• Compute PAN-level aggregate turnover and separately test the ₹5 crore GSTR-9C threshold.

• Freeze a reconciliation cut-off date and assign owners for outward supplies, ITC, RCM, e-invoices, imports and financial-statement mapping.

• Reconcile GSTR-1/GSTR-1A with GSTR-3B and books, including amendments and credit/debit notes.

• Reconcile GSTR-2B with the purchase register and GSTR-3B ITC, documenting reversals and later-period availment.

• Review DRC-03 payments, departmental demands, refunds and adjustments that affect the annual-return narrative.

• Prepare a financial-statements-to-GST bridge with support for every material difference.

• Where GSTR-9C applies, prepare the reconciliation statement in parallel with GSTR-9 rather than after filing GSTR-9.

• Obtain internal approval of unresolved differences, material positions and explanatory workings before portal submission.

• Preserve the final filed forms, workings, source reports and reviewer sign-off in the GST compliance file.

How this differs from the existing GSTR-9C and late-fee questions

For the separate question of whether a CA/CMA GST audit is required and how the ₹5 crore GSTR-9C threshold works, see: https://www.pgtandassociates.com/post/gst-audit-limit-fy-2025-26

The core question here is the FY 2025-26 due date and readiness process. For a deeper discussion of GSTR-9C threshold and self-certification, see: https://www.pgtandassociates.com/post/gstr-9c-applicability-for-fy-2025-26-5-crore-threshold-self-certification-due-date

For the late-fee consequences where GSTR-9C is filed after GSTR-9, see: https://www.pgtandassociates.com/post/gstr-9c-late-fee-fy-2025-26

For annual-return late-filing caps and broader GSTR-9 late-fee mechanics, see: https://www.pgtandassociates.com/post/gstr-9-late-filing-late-fee-turnover-caps-annual-return

Primary sources

Central Goods and Services Tax Act, 2017 — Section 44 (Annual Return): https://cbic-gst.gov.in/hindi/CGST-bill-e.html

CGST Rules — Rule 80 annual-return framework, substituted by Notification No. 30/2021-Central Tax with effect from 1 August 2021: https://cbic-gst.gov.in/pdf/central-tax/notfctn-30-central-tax-english-2021.pdf

CBIC Circular No. 246/03/2025-GST dated 30 January 2025 on GSTR-9C late fee and complete annual return: https://cbic-gst.gov.in/pdf/cir-cgst-246-03-2025.pdf

Professional takeaway

The 31 December 2026 deadline should be viewed as the end of the process, not the start of it. The highest-value work is the reconciliation performed months earlier: turnover, tax liability, ITC, financial statements and any GSTR-9C requirement should already be mapped before the filing window becomes compressed.

PGT & Associates can assist businesses with GST annual-return readiness, GSTR-9/GSTR-9C reconciliation, exception analysis and documentation of material differences. Professional advice should be based on the taxpayer’s facts, registrations and notifications applicable at the time of filing.

Frequently asked questions

What is the GST audit last date 2026? For FY 2025-26, businesses commonly use this phrase to refer to the GSTR-9/GSTR-9C annual-return deadline. The ordinary due date is 31 December 2026. GSTR-9C, where applicable, is self-certified rather than a CA/CMA-certified GST audit report.

What is the current legal basis? Rule 80, as substituted with effect from 1 August 2021, prescribes 31 December following the financial year for GSTR-9 and for GSTR-9C where applicable. CBIC Circular No. 246/03/2025-GST further clarifies that where GSTR-9C is required, annual-return compliance is complete only when the required reconciliation statement is also furnished.

Is 31 December 2026 automatically the final date in every case? It is the ordinary statutory due date for FY 2025-26. Any valid Government extension applicable to the taxpayer class must be checked separately.

Is GSTR-9C a CA/CMA-certified audit report? Under the current Rule 80 framework, GSTR-9C is a self-certified reconciliation statement. The earlier taxpayer-obtained professional GST-audit requirement was removed from the statutory framework.

Does the ₹5 crore threshold apply GSTIN-wise? Rule 80 refers to aggregate turnover, which is a PAN-based concept across India. Applicability should therefore be tested using the statutory aggregate-turnover definition and then operationalised GSTIN-wise for filing.

Can GSTR-9 be filed first and GSTR-9C later? Technically the portal sequence allows GSTR-9 first, but where GSTR-9C is required, late-fee consequences can continue until the complete annual-return obligation is satisfied. The two should be planned together.

Should businesses wait until December to begin? No. A controlled annual-return close should start with a books-vs-returns exception register, ITC reconciliation and financial-statement bridge well before the filing deadline.

Disclaimer: This article is for general professional information and does not constitute legal, tax or accounting advice. GST law, portal functionality, notifications and due-date extensions should be re-verified for the taxpayer’s facts before filing.

Frequently Asked Questions

What is the GSTR 9 due date for FY 2025-26?

The ordinary due date is 31 December 2026, unless the Government issues a valid extension or specific relief.

Is GSTR-9C also due on 31 December 2026?

Where Rule 80(3) applies, the self-certified GSTR-9C reconciliation statement is furnished with GSTR-9. The current threshold is aggregate turnover exceeding ₹5 crore for the financial year.

Does “GST audit last date 2026” mean a separate CA/CMA audit deadline?

No. The earlier mandatory professional GST audit requirement under Section 35(5) was omitted. The practical year-end compliance now focuses on GSTR-9 and, where applicable, self-certified GSTR-9C.

Related PGT & Associates GST Guides

For the ₹5 crore reconciliation-statement threshold, see GST Audit Limit for FY 2025-26. For delayed reconciliation-statement filing, see GSTR-9C Late Fee for FY 2025-26. For annual-return cut-off reconciliation around the September 2025 rate change, see GSTR-9 FY 2025-26 reconciliation guide.