GSTR-9 Applicability for FY 2025-26: Who Must File and Who Is Exempt?

Introduction

GSTR-9 return is an important compliance requirement for eligible registered taxpayers in India. Form GSTR-9 provides a consolidated summary of GST transactions reported during a financial year, including outward supplies, inward supplies, input tax credit (ITC), tax liability and tax payments.

For the financial year 2025-26, taxpayers should determine whether they are required to file GSTR-9 based on their registration category, aggregate turnover and applicable government notifications. While certain regular taxpayers must file an annual return, others may be exempt from filing depending on their turnover or taxpayer category.

Understanding the applicability of GSTR-9 in advance helps businesses maintain accurate records, reconcile GST returns and avoid unnecessary compliance issues.

GSTR-9 Applicability for FY 2025-26

The applicability of GSTR-9 depends on the taxpayer's registration type and the applicable exemption provisions.

As per Notification No. 15/2025–Central Tax dated 17 September 2025, registered persons whose aggregate turnover is up to ₹2 crore in FY 2024-25 are exempt from filing the annual return for that financial year. The notification applies to FY 2024-25 onwards, subject to its terms.

For FY 2025-26, taxpayers should check the applicable notification and official GST portal instructions before concluding that they are exempt.

Turnover-Wise Applicability

Important: Aggregate turnover is calculated on an all-India basis for the same PAN. It includes taxable supplies, exempt supplies, exports and inter-State supplies, subject to the statutory definition. GST taxes and inward supplies taxable under reverse charge are excluded from aggregate turnover.

Who Must File GSTR-9 for FY 2025-26?

Eligible regular GST taxpayers who are not covered by an applicable exemption are generally required to file GSTR-9.

The following points help determine applicability:

• Regular GST taxpayers: Businesses registered under the regular GST scheme must assess their annual return obligation based on the applicable turnover exemption.
• Businesses exceeding ₹2 crore turnover: Eligible regular taxpayers with aggregate turnover exceeding the applicable ₹2 crore exemption threshold are generally required to file GSTR-9.
• Businesses with multiple GST registrations: Aggregate turnover is determined on an all-India PAN basis, but the annual return obligation is assessed for the relevant GST registrations.
• Businesses with low or nil activity: A lack of taxable sales does not automatically exempt a registered taxpayer from filing. The applicable exemption and registration status must be checked.
• Businesses with exempt supplies: Exempt supplies may form part of aggregate turnover and should be considered when determining the filing requirement.

Who Is Exempt from Filing GSTR-9?

Certain taxpayers are excluded from the annual return requirement under the GST law. In addition, eligible registered persons may be exempted through a specific government notification based on aggregate turnover.

Certain government departments and local authorities whose accounts are subject to audit by the Comptroller and Auditor-General of India or an auditor appointed for local authorities are also covered by the relevant statutory exclusion.

Taxpayers should verify their registration category and the specific legal provision applicable to them before relying on an exemption.

Difference Between GSTR-9 and GSTR-9C

GSTR-9 and GSTR-9C serve different purposes under GST annual compliance.

GSTR-9C is a self-certified reconciliation statement under the applicable GST provisions. Businesses should not confuse it with the earlier system of mandatory certification by a chartered accountant or cost accountant.

What Details Are Reported in GSTR-9?

GSTR-9 contains several sections covering the taxpayer's annual GST transactions. The relevant information should be checked against filed returns and accounting records.

The exact reporting requirements depend on the relevant table in GSTR-9 and the instructions applicable to FY 2025-26.

How to Calculate Aggregate Turnover for GSTR-9 Applicability?

Aggregate turnover is a key factor in determining whether a taxpayer falls within the annual return exemption threshold.

It is calculated on an all-India basis for persons having the same PAN. It generally includes:

• Taxable supplies.
• Exempt supplies.
• Exports of goods and services.
• Inter-State supplies made to persons with the same PAN, where applicable.

The following amounts are generally excluded:

• Central GST, State GST, Union Territory GST, Integrated GST and cess.
• Inward supplies on which tax is payable under reverse charge.

Example

Suppose a business has the following figures for FY 2025-26:

In this example, aggregate turnover is ₹2.05 crore. The business exceeds the ₹2 crore threshold and would generally be required to file GSTR-9 if it is an eligible regular taxpayer and no other exemption applies.

This example is illustrative. Actual calculations should be based on the statutory definition of aggregate turnover and the taxpayer's complete records.

Due Date for Filing GSTR-9 for FY 2025-26

The general statutory due date for filing GSTR-9 for a financial year is 31 December following the end of that financial year, unless the government extends the deadline or specifies otherwise.

Accordingly, the general due date for FY 2025-26 is 31 December 2026.

Taxpayers should monitor official GST notifications and portal announcements for any extension or special instructions.

Step-by-Step Procedure to File GSTR-9

Eligible taxpayers can generally complete the annual return filing process through the GST portal by following these steps:

• Visit the official GST portal at https://www.gst.gov.in/.
• Log in using the registered GST credentials.
• Navigate to Services, then Returns, and select the annual return option.
• Choose the financial year 2025-26 and the relevant GST registration.
• Review the system-generated figures and enter the required details.
• Reconcile GSTR-1 and GSTR-3B figures with the books of accounts.
• Verify ITC details, tax payments, amendments and other disclosures.
• Preview the return and check for errors or inconsistencies.
• Submit and file the return using the permitted verification method.
• Download and preserve the filed return and acknowledgement for future reference.

The available filing options and portal workflow may vary according to the applicable GST portal functionality.

Reconciliation Checklist Before Filing GSTR-9

Businesses should complete a reconciliation exercise before submitting the annual return.

• Reconcile outward supplies as per the books with GSTR-1 and GSTR-3B.
• Verify taxable, exempt, nil-rated and export supplies.
• Reconcile ITC claimed with GSTR-3B, GSTR-2B and the purchase register.
• Review ITC reversals and ineligible credit.
• Verify reverse-charge transactions and the related tax payments.
• Check credit notes, debit notes and amendments.
• Reconcile tax paid with the electronic cash and credit ledgers.
• Review any additional tax liability and applicable interest.
• Confirm whether GSTR-9C is applicable.
• Retain supporting invoices, ledgers and reconciliations.

Accurate reconciliation can help identify reporting differences and reduce the risk of errors in the annual return.

What Happens if GSTR-9 Is Not Filed?

Failure to file a mandatory annual return may result in late fees under the applicable GST provisions. The amount payable depends on the law, the taxpayer's turnover category, the period of delay and any applicable relief or notification.

Taxpayers should also be aware that failure to file can create compliance issues and may require follow-up with the GST department.

An exemption from filing GSTR-9 should not be confused with an exemption from filing periodic GST returns or paying tax liabilities.

Conclusion

Determining GSTR-9 applicability for FY 2025-26 is an important part of annual GST compliance. Eligible regular taxpayers should evaluate their aggregate turnover, registration category and applicable government notifications to establish whether filing is mandatory.

Businesses should also reconcile their annual sales, purchases, ITC and tax payments before filing. Checking applicability early and maintaining proper records can help taxpayers complete their GST annual compliance accurately and within the prescribed deadline.

FAQs

1. Is GSTR-9 mandatory for FY 2025-26?

GSTR-9 is generally mandatory for eligible regular GST taxpayers whose aggregate turnover exceeds the applicable ₹2 crore exemption threshold, unless a specific exemption applies.

2. Is GSTR-9 required if turnover is below ₹2 crore?

Eligible registered persons with aggregate turnover up to ₹2 crore may be exempt where the applicable government notification covers the financial year. Taxpayers should confirm the notification applicable to FY 2025-26.

3. Is GSTR-9 mandatory for composition dealers?

Composition taxpayers generally file the applicable annual composition return, such as GSTR-4, rather than GSTR-9.

4. Is GSTR-9C mandatory for all taxpayers filing GSTR-9?

No. GSTR-9C generally applies to registered persons whose aggregate turnover exceeds ₹5 crore, subject to the applicable provisions and any relevant notifications.

5. Does a business with no sales need to file GSTR-9?

Nil sales alone do not establish an exemption. The taxpayer must check the applicable turnover-based exemption, registration category and statutory requirements.

6. Can additional tax be paid while filing GSTR-9?

Additional liability identified during annual reconciliation must be handled in accordance with the applicable GST provisions and permitted payment mechanism. Taxpayers should not assume that every adjustment can be made directly through GSTR-9.