GSTR-9 for 2025-26: who files by 31 December, the 30 November input tax credit limit, and the papers to ask clients for

GSTR-9 is a December job that is really a November job. The return mostly restates what was filed through the year, but the year's last input tax credit has to be taken by 30 November, and every missing invoice found while preparing the return is one the client has to send. Asking for the papers in the first week of November leaves time for both.

Who files, and by when

Rule 80(1) of the CGST Rules requires every registered person, other than input service distributors, persons deducting or collecting tax at source, casual and non-resident taxable persons and those exempted under section 44, to file the annual return in GSTR-9 on or before 31 December following the end of the financial year. A taxpayer under the composition scheme files GSTR-9A.¹

Rule 80(3) adds that a taxpayer whose aggregate turnover in the year exceeds ₹5 crore also files a self-certified reconciliation statement in GSTR-9C, with the annual return and by the same date.¹

Notification No. 15/2025–Central Tax of 17 September 2025 exempts registered persons whose aggregate turnover in a financial year is up to ₹2 crore from filing the annual return, for 2024-25 onwards.² So your clients fall into three groups:

The 30 November input tax credit limit

Section 16(4) of the CGST Act says input tax credit for an invoice or debit note cannot be taken after 30 November following the end of the financial year it belongs to, or after the annual return is filed, whichever is earlier.³ For 2025-26, that is 30 November 2026.

Two things follow. Any credit still missing from a client's 2025-26 returns has to be claimed in the return filed by then. And filing GSTR-9 before 30 November ends the window at that moment. Our recommendation is to match each client's purchase records against the credit claimed in the first half of November, and to file the annual return only after that.

The papers to ask for

• Sales for the year: the sales register or invoice list, and credit and debit notes, to match against the GSTR-1s filed.
• Purchases for the year: the purchase register, to match against the credit claimed in GSTR-3B and the suppliers' figures.
• Anything paid under reverse charge, and any credit reversed during the year.
• Invoices that arrived late, from 2025-26 suppliers, which may still be claimed until 30 November.
• For clients above ₹5 crore: the audited or final books, for the reconciliation in GSTR-9C.

Messages you can copy

Replace the words in brackets, and write them in English or Hindi, whichever the client uses. The year's GST messages are in our GST reminder templates.

The year's other dates are in our compliance calendar, and the papers request style is the same as in our ITR documents checklist.

What can run by itself

• The three groups, worked out from each client's turnover for the year, so the right message goes to each.
• The papers request and a follow-up that names only what is still missing, as in our client reminders.
• The registers and bills, read as they arrive and filed under the client, as in our document processing.
• A hold on filing any client's GSTR-9 before 30 November until a partner has checked the credit.

What stays with your team

• The match itself, and what to do with differences between the books and the returns.
• Whether a late bill qualifies for credit at all.
• The self-certified GSTR-9C, which needs the final books and a partner's review.

More of what we write for CA practices is on the blog.

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