Skip to content
TThe Consulting Crew

Blogs · GST

GSTR-9 and 9C for FY 2025-26: the annual return in the year GST changed mid-stream

By Ashish Kumar Sharma · Published 17 Aug 2026

One financial year, two rate schedules, one annual return due 31 December 2026. Who files what, the fees for lateness, and the reconciliation that actually takes the time.

The annual return is where a year of monthly filings has to agree with itself — and with your books. Most years that is tedious. For FY 2025-26 it is genuinely tricky, because GST 2.0 switched the rate schedule on 22 September 2025, cutting the year into two regimes that both live inside one GSTR-9.

Who files what

Aggregate turnover (FY 2025-26)GSTR-9GSTR-9C
Up to ₹2 croreOptional (often worth filing)Not required
₹2 crore – ₹5 croreMandatoryNot required
Above ₹5 croreMandatoryMandatory, self-certified

Composition taxpayers are outside this table — their annual statement is GSTR-4. And the deadline discipline has teeth now: under the three-year bar, an annual return left unfiled for three years past its due date is barred permanently.

The tables where the work lives

  • Tables 4–5 (outward supplies): your GSTR-1s consolidated, split across taxable, exempt and non-GST — this year, reconciled across two rate regimes.
  • Tables 6–8 (ITC): credit availed per 3B against what the system shows, with the gap explained. The IMS accept/reject trail makes this cleaner for FY 2025-26 than it was — if you actually used it.
  • Tables 10–13 (spillover): FY 2025-26 transactions corrected or credited in FY 2026-27 returns up to the specified period.
  • Table 17 (HSN): HSN-wise outward summary — four digits up to ₹5 crore turnover, six digits above.

The rate-switch reconciliation

The 22 September 2025 boundary creates four specific traps we are seeing in FY 2025-26 files:

  • Credit notes that cross the line. A note issued in October 2025 against an August 2025 invoice carries the old rate. Notes issued at the new rate against old-rate invoices create mismatches that surface only at annual-return stage.
  • Advances and time of supply. Advances received before the switch and adjusted after it follow time-of-supply rules, not invoice dates.
  • Price renegotiations. Contracts repriced “GST-neutral” in September–October 2025 often were not; the differential shows up as a rate-wise anomaly in table 4.
  • Stock and ITC assumptions. Slab changes altered the economics of inventory bought at old rates and sold at new ones — the books entry is fine, but the 9C reconciliation must explain the margin movement.

Late fees

TurnoverLate fee / dayCap
Up to ₹5 crore₹500.04% of state turnover
₹5–20 crore₹1000.04% of state turnover
Above ₹20 crore₹2000.5% of state turnover

A sensible timeline

  • September–October 2026: books-to-returns reconciliation, and any FY 2025-26 corrections pushed into monthly returns before the 30 November specified period closes.
  • November 2026: draft GSTR-9 tables, resolve ITC gaps, quantify any DRC-03 payments.
  • December 2026: file 9 and 9C with margin — not on the 31st, when the portal remembers it is a government portal.

How we can help

Our GSTR-9 and 9C service does the reconciliation, not just the form-filling: books to 3B to 1 to 2B, the rate-switch cut-over, spillover tables and the 9C statement. Retainer clients on our monthly GST filing get the annual return built from reconciliations that already exist — which is the cheap way to do this. If your FY 2025-26 monthly returns need repair first, start now; December queues are real.

Not sure how clean your GST year is? Run the free GST health check →

This article is general information, not tax advice. Thresholds and dates can change by notification; confirm specifics for your business before acting.

Let's get your compliance off your plate.

Tell us what you are dealing with. A short reply from someone who does this every day — no pitch, no obligation.

  • Reply within one working hour on WhatsApp
  • Fixed monthly fee, agreed before any work starts
  • No lock-in — month to month, 15 days’ notice

Request a callback

Two fields and you are done. We reply on WhatsApp within one working hour, Mon–Fri 10:00–19:00 and Sat 10:00–14:00 IST.

or message us on WhatsApp instead →
The Consulting Crew

A Strategy That Drives Results