GSTR-9 and 9C chase list for CA firms: FY 2025-26 (close 30 Nov, file by 31 Dec 2026)
Short answer (checked 19 Oct 2026): For CA firms, FY 2025-26 GST annual returns are due on 31 December 2026 (CGST Act section 44, CGST Rules rule 80). GSTR-9 is optional for clients with aggregate turnover up to ₹2 crore (Notification 15/2025-Central Tax) and must be filed above that. GSTR-9C is also needed above ₹5 crore. The date that matters first is 30 November 2026: after it, or after the client files the FY 2025-26 annual return if that is earlier, the client can no longer claim missed FY 2025-26 ITC (section 16(4)), declare FY 2025-26 credit notes (section 34(2)) or correct FY 2025-26 GSTR-1/GSTR-3B details (sections 37(3), 39(9)). So chase in two rounds: missed credit and corrections first, then the annual return. Sources: CBIC's rule 80 and section 16 pages and the GSTN GSTR-9 FAQ. This is a starting point, not GST advice. Confirm on the GST portal before you file.
What you get from this guide: a finished two-round chase list for FY 2025-26 GST annual returns. Sort each client into one of three bands by aggregate turnover: up to ₹2 crore (GSTR-9 optional), ₹2–5 crore (GSTR-9), above ₹5 crore (GSTR-9 + 9C). Round 1 (now to 30 Nov): close missed ITC, credit notes and corrections. Round 2 (1–24 Dec): collect books and audited accounts, draft, get sign-off and file before the 31 Dec rush. The collect list and the client scripts are below. Copy them into your own sheet.
The dates and thresholds you can rely on (FY 2025-26)
| What | Who | Rule | FY 2025-26 date |
|---|---|---|---|
| GSTR-9 (annual return) | Normal taxpayers with aggregate turnover above ₹2 crore (optional up to ₹2 crore) | s.44, r.80(1); Notification 15/2025-CT | 31 Dec 2026 (Thu) |
| GSTR-9C (reconciliation statement, signed by the taxpayer) | Aggregate turnover above ₹5 crore | r.80(3) | 31 Dec 2026, filed with GSTR-9 |
| Last date to take FY 2025-26 ITC | All recipients | s.16(4) | 30 Nov 2026 (Mon) or annual return filing, if earlier |
| Last date to declare FY 2025-26 credit notes | Suppliers | s.34(2) | 30 Nov 2026 or annual return filing, if earlier |
| Last date to correct FY 2025-26 GSTR-1 / GSTR-3B | All filers | s.37(3) and s.39(9) provisos | 30 Nov 2026 or annual return filing, if earlier |
What decides the date is when a return is actually filed, not its due date. For a monthly filer, the October 2026 GSTR-1 (due 11 Nov) and GSTR-3B (due 20 Nov) are the last returns that can carry FY 2025-26 items, because the November returns can only be filed after November ends. A credit note has to go in the return for the month it is issued, so issue FY 2025-26 credit notes by 31 Oct 2026. QRMP clients have fewer returns left than monthly filers. Their October–December GSTR-3B cannot be filed before January, so check today which returns they can still use (check the portal for each client).
Late fee: the late fee runs until the complete annual return is filed, which means GSTR-9 plus GSTR-9C where 9C is required (CBIC Circular 246/03/2025). Notification 07/2023-CT caps the fee by turnover band. Let the portal compute it, and check the notification before you quote a number to a client.
Two-round chase plan
| When | Who | What to ask for or do | Tone tip |
|---|---|---|---|
| Now (20–25 Oct) | Every GST client | Confirm FY 2025-26 aggregate turnover (PAN-wide, all GSTINs) and put the client in its band. List every GSTIN. GSTR-9 and 9C are filed per GSTIN. | Ask one question: "What was your total turnover for 2025-26 across all GST numbers?" |
| By 25 Oct | Clients above ₹2 crore | Purchase register for Apr 2025–Mar 2026 (Excel). You compare it with GSTR-2B and the Table 8A invoice download. | Ask for the Excel export, not PDFs |
| By 31 Oct | Suppliers with FY 2025-26 discounts, returns or rate errors | Issue any FY 2025-26 credit notes in October, so they go in the October GSTR-1. | Give a hard date: "issue by Saturday 31 Oct" |
| 1–8 Nov | Clients with ITC gaps | Send the client a list of vendor invoices missing from GSTR-2B. Vendors must report them by their own October GSTR-1 (due 11 Nov). | One line per vendor: GSTIN, invoice no., amount |
| 11 Nov | Monthly filers | October GSTR-1: add missed FY 2025-26 invoices, amendments and credit notes. | Last regular GSTR-1 that can still fix FY 2025-26 |
| 20 Nov | Monthly filers | October GSTR-3B: claim missed FY 2025-26 ITC that is now in GSTR-2B and meets section 16. Make any FY 2025-26 reversals. | File early. A 3B filed after 30 Nov cannot carry FY 2025-26 credit |
| 30 Nov | Internal only | The FY 2025-26 windows close. Write down, for each client, what could not be claimed or corrected and why. | Do not file GSTR-9 before this date for clients with open items |
| 1–15 Dec | Clients above ₹2 crore | Books: sales and purchase registers, ITC ledger, HSN-wise summary, RCM paid, ITC reversals (rules 37/37A, 42/43, s.17(5)). For 9C clients, also the audited financial statements. | Send the collect list below as one checklist |
| 16–24 Dec | All filers | Draft GSTR-9 (and 9C), send the client a one-page summary of tax and differences, take sign-off, file. | Aim for 24 Dec. Don't plan on the last week |
| 31 Dec | Internal only | Due date. Note the ARN or the reason each pending client was not filed. | Never file on presumed consent |
Collect list for each GSTR-9 / 9C client
- Client name, GSTIN(s), state, monthly or QRMP, FY 2025-26 aggregate turnover and band (optional / 9 / 9 + 9C)
- GSTR-1 and GSTR-3B filed for every period Apr 2025–Mar 2026 (Y/N), plus FY 2025-26 items reported in Apr–Nov 2026 returns (these feed Tables 10–14)
- Sales register with taxable, exempt, nil and non-GST supplies split, plus advances, and credit and debit notes
- Purchase register vs GSTR-2B / Table 8A download: matched, missing and excess
- ITC reversals during the year (rule 37 and 37A, rules 42/43, section 17(5) blocked credit) and any reclaims
- FY 2024-25 credit reclaimed in FY 2025-26. Per the GSTN FAQ it is reported in Table 6A1 (reclaims other than rule 37/37A) or Table 6H (rule 37/37A reclaims). Check the GSTN FY 2025-26 advisory of 13 Oct 2026 for the current table rules.
- RCM tax paid and the related ITC, import of goods/services, ISD credit
- HSN-wise summary of outward and inward supplies
- Demands, refunds and late fees paid for FY 2025-26
- For 9C: audited financial statements, and a turnover reconciliation (unbilled revenue, unadjusted advances, credit notes after year end, deemed supplies)
- Owner on your team, draft sent date, client sign-off date, ARN
Clients ask fewer "is the annual return due?" questions when the dates sit on a one-page calendar with your firm's name on it. Free national dates and a browser .ics builder: free CA due-date calendar tool.
WhatsApp / email script pack
Turnover check: "Hello. We are preparing your GST annual return for 2025-26, which is due on 31 December 2026. Please confirm your total turnover for April 2025 to March 2026 across all your GST numbers by [date]. That tells us whether GSTR-9 and 9C apply."
Purchase register: "To make sure you get every input credit for 2025-26, please send your purchase register for April 2025 to March 2026 in Excel by [date]. Any credit not claimed by 30 November 2026 is lost."
Credit notes: "If you owe any customer a discount, return or price correction on a 2025-26 sale, please issue the credit note by 31 October 2026, so we can report it in your October return."
Vendor gap: "These [n] purchase bills from 2025-26 are not showing in your GST credit statement. Please ask these vendors to report them in their October GSTR-1 by 11 November. List attached: GSTIN, bill number, amount."
Sign-off: "Your 2025-26 GST annual return is ready. Summary attached. Please reply 'OK to file' by [date], and we will file it before 31 December."
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If you want branded quarterly packs
The White-Label Client Compliance Calendar for CA Firms (₹999/year) sends four quarterly packs with your firm name on the DOCX, PDF and WhatsApp image, plus national .ics/.xlsx and extension notes, so 30 Nov and 31 Dec are already on every client's page. Files are made after checkout (not instant). 14-day refund from when you receive the first pack. Disclosure: that is an Unadhi product. You can use this chase list without buying anything.
This guide is general information, not legal or tax advice and not an official government publication. Thresholds and tables can change by notification, and the government may extend the due date at any time. Check the GST portal and CBIC notifications before you file or message clients. Your firm stays responsible for advice to your clients.
Sources to re-check
- CGST Rules, rule 80 (GSTR-9 by 31 December, GSTR-9C above ₹5 crore): taxinformation.cbic.gov.in
- CGST Act, section 16(4) (ITC time limit, 30 November) and section 34(2) (credit notes): section 16 · section 34
- Notification 15/2025-Central Tax, 17 Sep 2025 (GSTR-9 optional up to ₹2 crore, FY 2024-25 onwards): taxreply.com (text) · CBIC notifications page
- Late fee: Notification 07/2023-Central Tax (gstcouncil.gov.in) and Circular 246/03/2025 (gstcouncil.gov.in)
- GSTN GSTR-9 FAQ (due date, extension by notification) and GSTR-1 FAQ (30 November amendment cut-off): FAQs on GSTR-9 · GSTR-1
- GSTN advisory "Annual Returns in the form of GSTR-9/9C for FY 2025-26", 13 Oct 2026, as listed by ICAI: idtc.icai.org
- Related guides: GSTR-1 chase before the 11th · GSTR-3B chase list before the 20th · ROC AOC-4 / MGT-7 chase list · what belongs on a white-label calendar
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