GSTR-9C Reconciliation Statement: Applicability, Format & Filing (2026)

What is GSTR-9C?

GSTR-9C is an official statement that is used to double-check a business's tax records. Initially, it was launched on September 13, 2018, with the purpose of serving as a self-assessment and reconciliation tool for businesses. After the amendment of FY 2020-21, the government allowed registered taxpayers to self-certify GSTR-9C. Although this amendment removed the compulsory requirement of a Chartered Accountant (CA) or Cost Accountant (CMA). 

In 2026, the registered taxpayers whose Aggregate Annual Turnover (AATO) exceeds Rs 5 crore must file GSTR-9C. The statement filing is used to match the data mentioned in a business's annual return (GSTR-9) with its audited annual financial statement. At the end, it clarifies that there are no discrepancies in reported data related to turnover, ITC (Input Tax Credit), or tax liabilities.

Note: Taxpayers can file one GSTR-9C for every unique GSTIN. 

Who Can File GSTR-9C? 

Not everyone is eligible to file the form GSTR-9C. It is specifically mandatory for all regular registered taxpayers. Meanwhile, the applicability is determined by the Aggregate Annual Turnover (AATO). Must comply with these set criteria to file it:

• Turnover Threshold: If the aggregate annual turnover exceeds Rs 5 crore in the financial year. 

• Regular Taxpayers: It is mandatory to file the form for the normal/regular taxpayers. 

• Prerequisite: Before filing the form GSTR-9C, applicants must file their GSTR-9 (annual return). 

Who is Exempt From Filing Form GSTR-9C? 

If any business's annual turnover is Rs 5 crore or less, then it is not mandatory to file the form GSTR-9C. The following are restricted from GSTR-9C:

• Composition Scheme Taxpayers: The taxpayers registered under Section 10 of the CGST Act do not need to file GSTR-9C; instead, they file form GSTR-4 annually. The composition scheme dealers pay the tax at fixed, lower rates. 
• Casual Taxable Persons (CTP): The businesses whose registration is temporary in a territory where they have no fixed place of business do not need to file the GSTR-9C, as they are automatically exempt from the annual compliance pool. 
• Non-Resident Taxable Persons (NRTP): The international businesses or individuals who supply occasionally across India and do not have a fixed business footprint are exempt from GSTR-9C. 
• Input Service Distributors (ISD): Such businesses are liable to get tax invoices for inward supplies on behalf of their branches. These offices are legally removed from annual reconciliation filings, but they need to file the form GSTR-6. 
• Foreign Airline Companies:  The commercial airlines from foreign companies operating in India are exempt from filing GSTR-9C. It determines that the foreign companies are legally compliant with the Indian provisions. 
• Government Department & Local Authorities: The members of the government department and local authorities are generally exempt from the reconciliation process. This is because their books of accounts are legally subject to auditing by the Controller and Auditor General (CAG).

GSTR-9C Due Date FY 2025-26

The registered taxpayers are required to file the form GSTR-9C on or before the 31st of December. To file the GSTR-9C, it is mandatory to first file the GSTR-9. The portal will not unlock until the annual return is submitted. The last due date for the financial year follows:

• FY 2023-24: 31st December, 2024
• FY 2024-25: 31st December, 2025
• FY 2025-26: 31st December, 2026

Difference Between GSTR 9 vs GSTR 9C

Along with GST compliance, the regular taxpayers are required to file both GSTR-9 and GSTR-9C. However, both have different purposes and document types. GSTR-9 is an annual summary, whereas the GSTR-9C is a self-certified reconciliation statement. Here is the summary table to understand the difference between GSTR-9 and GSTR-9C. 

GSTR-9 is filed by all regular taxpayers; meanwhile, GSTR-9C is mandatory if a business's annual turnover meets the Rs 5 crore aggregate turnover threshold. On the other hand, the due date for both forms is December 31 of the financial year. Avoiding deadlines or making errors during form filing can raise serious consequences, leading to penalties mentioned under the CGST Act. 

What is the Format of GSTR-9C?

The GSTR-9C format is categorised into two different parts. Part A from the GSTR-9C format identifies other differences between a taxpayer's annual GST return (GSTR-9) and the audited financial statement. The registered person verifies that the reconciliation statement and related audited financial statement under Part B of such a format are true and complete.

GSTR-9C Format:

Part A: Reconciliation Statement

• Part I:  Basic Details

This section highlights the financial year, GSTIN, legal name, and trade name (if any), and whether you are liable to audit under any law. 

• Part II: Reconciliation of Turnover

This section compares the gross and taxable turnover mentioned in the audited financial statements with the turnover declared in GSTR-9. 

• Part III: Reconciliation of Tax Paid

It matches the tax liability, which is calculated from the books of account against tax paid and reported in GSTR-9. 

• Part IV: Reconciliation of ITC

This section matches the input tax credit claimed in audited books against the ITC (claimed in GSTR-9).

• Part V: Additional Liability

Allows the taxpayers to report any unreconciled differences or additional tax liabilities. 

Part B: Self-Certification 

This part serves as the final declarations where the taxpayers verify that the details mentioned in Part A are accurate to the best of their knowledge. Since FY 2020-21, there is no need to appoint a CA, as the taxpayers can sign and certify themselves. 

Step-by-Step Guide: How to File GSTR-9C?

Digital filing of form GSTR-9C is much easier and straightforward. The form is a self-certified reconciliation statement that is filed by taxpayers. Follow these major steps to avoid the basic mistakes:

Step 1: File the Mandatory GSTR-9

Before filing the GSTR-9C, the taxpayers are required to first file the GSTR-9 (GST Annual Return)(before December 31, 2026, for FY 2025-26). Must ensure that the GSTR-9 is filed for the same financial year. 

Step 2: Prepare Audited Financial Statements

Must gather the PAN-level audited accounts, balance sheet, P&L, and the auditor's report for the financial year. 

Step 3: Navigate the GST Portal

As the complete process is online, visit the GST official portal. Look for the 'Services' section, select 'Returns,' and proceed to 'Annual Return.'

Step 4: Download Required Tables

Locate the GSTR-9C tile on the annual returns dashboard and proceed by clicking on "initiate filing." Once it is complete, download the GSTR-9C tables derived from GSTR-9.  

Step 5: Download the GSTR-9C Offline Utility

Must download the official tool to prepare the reconciliation statement. To download it, visit the GST portal home page, go to the section download> offline tools, and then select the GSTR-9C offline tool. 

Step 6: Complete the Details 

Part A includes the reconciliation statement, whereas Part B determines the self-certification. To fill out both tables, one must use the Audited Financial Statement and the GSTR-9 data. 

Step 7: Upload the JSON File

To check the errors, use the GSTR-9C offline tool. Upon validation, generate a JSON file. Once it is complete, upload the JSON file. 

Step 8: Pay Additional Liability & File

If any additional tax liability or unreconciled difference was not previously declared, use the Form DRC-03 to make payments. Before final submission, review the drafted GSTR-9C to confirm that all data is accurate.  

Step 9: Verify with DSC or EVC

For companies and LLPs, the authorised signatory signs using the Digital Signature Certificate (DSC), whereas others verify through the Electronic Verification Code (for other registered taxpayers). 

GSTR-9C: Late Fee Under Section 47 (2)

The taxpayers might face strict financial consequences for avoiding filing the GSTR-9C. The fee penalty majorly rises due to late filing, filing without disclosing additional liability, etc. As per the latest rationalisation of the late fee mentioned by the CBIC, the actual late fee cap depends on a business's aggregate turnover. The plus point is that the late fee cap is significantly reduced for small and mid-sized taxpayers.

 In case the turnover lies between Rs 2 crore and Rs 5 crore, the late fee penalty is Rs 100 per day (Rs 50 CGST + Rs 50 SGST), capped at a maximum of 0.04% of the turnover in the State/UT. The late fee is Rs 200 per day (Rs 100 CGST + Rs 100 SGST) if the turnover is above Rs 20 crore, capped at a maximum of 0.50% of the turnover in the state/UT. 

Note: In case a shortfall is identified in GSTR-9C, taxpayers must use the form DRC-03 to pay along with interest at 18% per annum. 

Conclusion | File GSTR-9C with JustStart Assistance

The regular taxpayer with an aggregate annual turnover exceeding Rs 5 crore is required to file the GSTR-9C. Filing the GSTR-9C in India is a critical compliance formality. This form of statement serves as a self-certified reconciliation to reconcile the taxpayer’s annual GST returns (GSTR-9C) with the audited financial books. 

Filing the GSTR-9C by the due date on 31st December of the respective financial year is crucial to avoid the late fees and possible penalties. On-time filing is an important step to safeguard a business's financial leakages and legal scrutiny. JustStart makes filing of GSTR-9C easy by providing qualified CAs and tax experts for complex financial reconciliations. 

Frequently Asked Questions (FAQs)

1. What is GSTR 9C?

Ans. GSTR-9C is an annual reconciliation statement of GST to be filed in India. It is in line with the numbers reported in the taxpayer’s annual GST return (GSTR-9). 

2. What is the GSTR-9C threshold for the year 2026?

Ans.  The GSTR-9C has a turnover threshold of Rs 5 crore in a financial year (PAN-based). If the business turnover is less than Rs 5 crore and more than Rs 2 crore, it does not need to file GSTR-9C but still needs to file GSTR-9.

3. Is CA certification compulsory to file GSTR-9C?

Ans. No, the legal requirement for a mandatory GST audit and independent certification was removed. Since FY 2020-21, self-certification has been allowed. But, still, businesses contact a CA or GST consultant to avoid errors.

4. Is it mandatory to file the GSTR-9 before GSTR-9C?

Ans. Yes, the taxpayers must file the GSTR-9 (Annual Returns) before filing GSTR-9C. The GST portal will not be active for GSTR-9C filing until the annual return is fully submitted. 

5. What should be done if additional tax liability is found during GSTR-9C reconciliation?

Ans. If additional tax liability is discovered, you must declare and pay the shortfall using Form GST DRC-03 before or at the time of filing the reconciliation statement. 

6. Can composition scheme taxpayers file GSTR-9C 

Ans. No, the taxpayers registered under the composition scheme don't need to file the GSTR-9C. Their primary periodic return is Form GSTR-4, which must be filed annually. 

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

Ans. For the financial year 2025-26, the due date for filing GSTR-9C is December 31, 2026. Filing after the deadline can attract financial and legal penalties. 

8. How many GSTR-9C forms can be filed with one GSTIN?

Ans. For each separate GSTIN, it is required to file the GSTR-9C. For example, if there is a business with four GSTINs, it is required to file the 4 GSTR-9C forms. 

9. How to avoid the penalty for GSTR-9C?

Ans. The chances of penalties can increase if GSTR-9C is not filed by the due date of 31st December for FY 2025-26. Registered taxpayers shall file the forms within the statutory deadline. Keep certified documents, stay active in government amnesty schemes, etc.

10. How can JustStart help with GSTR-9C filing?

Ans. JustStart professionals have helped thousands of businesses and individuals to avoid mistakes while filing GSTR-9C. The experts streamline the major complexities by ensuring financial statements, turnover limits, and Input Tax Credit (ITC) for strict compliance.