What is GSTR-9C and Who Must File It: Complete Guide 2026-27

Introduction

For businesses with higher turnover under GST, filing the annual return is not the only compliance requirement. Taxpayers with aggregate annual turnover exceeding a specific limit must also file a reconciliation statement called GSTR-9C.

If you are wondering what GSTR-9C is and who must file it, this comprehensive guide explains everything you need to know. You will learn about eligibility, turnover limits, the filing process, due dates, required documents, and common mistakes to avoid.

GSTR-9C is an important part of GST compliance for businesses with a turnover above ₹5 crore. Missing this requirement can lead to penalties, notices, and higher scrutiny from the GST department.

What is GSTR-9C

GSTR-9C is the GST reconciliation statement that must be filed along with the annual return (GSTR-9) by certain taxpayers. It reconciles the figures in your books of accounts with the figures reported in your GST returns.

The purpose of GSTR-9C is to ensure that:

• Turnover declared in books matches GST returns
• Tax paid in returns matches the actual liability
• The input tax credit claimed is accurate and eligible
• All disclosures are complete and correct

GSTR-9C must be self-certified by a Chartered Accountant or Cost Accountant for taxpayers with a turnover above ₹5 crore. This certification adds credibility to the reconciliation and reduces the risk of discrepancies.

Who Must File GSTR-9C

Understanding who must file GSTR-9C is crucial for staying compliant. The rule is based on aggregate annual turnover during the financial year.
<h3Mandatory Filers for GSTR-9C:

✓ All registered taxpayers with aggregate annual turnover above ₹5 crore in a financial year
✓ Taxpayers who file GSTR-9 (annual return)
✓ Regular taxpayers under the GST regime

Who Does Not Need to File GSTR-9C:

✗ Taxpayers with turnover up to ₹5 crore (only need to file GSTR-9)
✗ Composition dealers (file GSTR-4 instead)
✗ Casual taxable persons
✗ Non-resident taxable persons
✗ Input Service Distributors (ISD)
✗ TDS/TCS payers

GSTR-9C Turnover Limit

The GSTR-9C turnover limit is ₹5 crore per financial year. This is the key threshold that determines whether you need a CA/Cost Accountant certification.

Turnover Threshold Table:

Turnover Range	GSTR-9 Filing	GSTR-9C Filing
Up to ₹2 crore	Optional	Not Required
₹2 crore to ₹5 crore	Mandatory	Not Required
Above ₹5 crore	Mandatory	Mandatory (with CA certification)

Important: Aggregate turnover includes all taxable supplies, exempt supplies, and exports across all states, based on the same PAN.

GSTR-9C Due Date 2026

The GSTR-9C due date is the same as GSTR-9. For each financial year, the last date to file is December 31 of the next year.

Due Date Table:

Financial Year	Due Date	Last Date to File
FY 2025-26	December 31, 2026	December 31, 2029
FY 2024-25	December 31, 2025	December 31, 2028
FY 2023-24	December 31, 2024	December 31, 2027

Late Fees: Filing after the due date attracts late fees of ₹50 per day (₹25 CGST + ₹25 SGST), with a maximum cap of ₹5,000.

GSTR-9C Format and Structure

GSTR-9C has a standard format with two main parts:

Part A: Reconciliation Statement

This part contains the reconciliation between books and GST returns across multiple tables:

Table	Description
Table 5	Gross annual turnover
Table 6	Turnover declared in the annual return
Table 7	Differences in turnover and reasons
Table 8	Tax paid as per books vs returns
Table 9	Input tax credit (ITC) reconciliation
Table 10	Differences in ITC and reasons
Table 11	Other liabilities (interest, late fees, etc.)
Table 12	Demands and refunds
Table 13	Additional information

Part B: Certification by CA/Cost Accountant

This part includes:

• CA/Cost Accountant certification
• Observations and remarks
• Signature and seal of the auditor
• Membership number

Prerequisites for the File GSTR-9C Online

Before you file GSTR-9C online, ensure the following:

1. File GSTR-9 First

• Annual return must be filed before GSTR-9C
• GSTR-9 data is used for reconciliation

2. Complete Reconciliation

• Reconcile books with GSTR-1
• Reconcile books with GSTR-3B
• Match ITC with GSTR-2B

3. Prepare Documents

• audited annual financial statements
• GSTR-9 draft copy
• GSTR-1 and GSTR-3B summaries
• ITC reconciliation sheet
• Tax payment challans

4. Engage CA/Cost Accountant

• For turnover above ₹5 crore, certification is mandatory
• Provide all documents to the auditor

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

Step 1: Log in to the GST Portal

• Visit www.gst.gov.in
• Enter GSTIN and password

Step 2: Navigate to the Annual Return Section

• Click Services → Returns → Annual Return
• Select Financial Year
• Click SEARCH

Step 3: File GSTR-9 First

• Complete and file GSTR-9 annual return
• Obtain ARN for GSTR-9

Step 4: Access GSTR-9C

• After GSTR-9 filing, GSTR-9C form becomes available
• Click PREPARE ONLINE on the GSTR-9C tile

Step 5: Fill Reconciliation Details

• Enter turnover figures from the books
• Enter turnover from GSTR-9
• Calculate and enter differences
• Fill ITC reconciliation details
• Add remarks for all differences

Step 6: Download Draft for CA

• Download draft GSTR-9C
• Submit to Chartered Accountant/Cost Accountant

Step 7: Get CA Certification

• CA reviews and certifies Part B
• CA adds observations and remarks
• CA signs and seals the form

Step 8: Upload Certified Form

• Upload the CA-certified GSTR-9C on the GST portal
• Verify all details

Step 9: File GSTR-9C

• Check declaration
• Select authorized signatory
• File with DSC or EVC
• Receive ARN and acknowledgment

Step 10: Save Documents

• Download the GSTR-9C PDF
• Save the CA certification copy
• Keep for future reference

Common Mistakes to Avoid

Mistake	Impact	Prevention
Filing GSTR-9C without GSTR-9	Rejected	File GSTR-9 first
Wrong turnover figures	Notice	Verify with audited financials
Missing ITC reconciliation	Discrepancy	Match with GSTR-2B
No CA certification	Non-compliance	Engage CA for >₹5Cr
Late filing	Late fees	File before December 31
Incomplete remarks	Query	Explain all differences

Penalties for Not Filing GSTR-9C

1. Late Fees: ₹50/day (max ₹5,000)
2. GST Notice: Under Section 44
3. Interest: 18% per annum on unpaid tax
4. Audit Trigger: Higher risk of GST department audit
5. Penalty: Up to 100% of the tax amount for fraud

Expert Tips for Perfect GSTR-9C Filing

1. Start Early: Begin reconciliation 3-4 months before due date
2. Maintain Records: Keep project-wise and month-wise records
3. Reconcile Monthly: Do reconciliation throughout the year
4. Use CA Early: Engage the auditor before year-end
5. Verify ITC: Check GSTR-2B before claiming credit
6. Document Differences: Keep proof for all reconciliation gaps
7. Review Thoroughly: Check all tables before submission

When to Seek Professional GST Help

Consider GST Compliance Experts if:

✓ Turnover exceeds ₹5 crore (GSTR-9C mandatory)
✓ Complex transactions (exports, RCM, interstate)
✓ High ITC claims requiring verification
✓ Received GST notices previously
✓ Unsure about the reconciliation process
✓ Want to avoid compliance errors and penalties

Conclusion

Understanding what GSTR-9C is and who must file it is essential for businesses with a turnover above ₹5 crore. GSTR-9C is the GST reconciliation statement that ensures your books match GST returns, and it must be certified by a Chartered Accountant or Cost Accountant.

Key Takeaways:

Point

Requirement

 

Point	Requirement
Turnover Limit	Above ₹5 crore (mandatory)
Due Date	December 31 of next year
Certification	CA or Cost Accountant
Filing Order	GSTR-9 first, then GSTR-9C
Late Fees	₹50/day (max ₹5,000)

Proper GSTR-9C filing reduces audit risk and ensures seamless GST compliance. For assistance with GSTR-9C filing, reconciliation, or CA certification, contact GST Compliance Experts for professional support.