GST Annual Return (GSTR-9/9C) Applicability Checklist

Turnover-tiered applicability testing before assuming a GSTR-9/9C obligation — the optional-filing band, the GSTR-9C reconciliation threshold, and the categories excluded from annual return filing altogether.

Free · CORAA original — SA-aligned

Updated 28 Jul 2026

GSTR-9

Optional below, mandatory above the small-taxpayer threshold

GSTR-9C

Higher threshold, now self-certified (no CA certification since FY 2020-21)

Excluded

Casual/non-resident taxable persons, ISDs

Format

Microsoft Word (.docx)

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Your firm — letterhead

Appears at the top of the document as the audit firm letterhead.

Audit firm name

Audit firm address

Used as the letterhead block.

Engagement partner

ICAI membership no.

Firm registration no.(optional)

Engagement details

The client and period this document is for.

Registered person / entity name

GSTIN

PAN

Financial year ended

Date of report

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GST Annual Return

31 July 2026

GST ANNUAL RETURN (GSTR-9/9C) APPLICABILITY CHECKLIST

Entity: {{client_name}} · GSTIN: {{gst_no}} · Financial year ended: {{period_end}}

A. GSTR-9 (annual return)

Aggregate turnover band (verify current figures for the year)	GSTR-9 status
Up to the small-taxpayer optional-filing threshold	Optional (may still choose to file)
Above the optional-filing threshold	Mandatory

B. GSTR-9C (reconciliation statement)

Required only above a higher turnover threshold than GSTR-9 itself (verify the currently applicable figure — this has been revised over successive years). GSTR-9C is now SELF-certified by the registered person; the requirement for CA/Cost Accountant certification was removed with effect from FY 2020-21 onward.

C. Entities excluded from annual return filing altogether

Casual taxable persons.
Non-resident taxable persons.
Input Service Distributors.
Persons required to deduct tax at source under Section 51 (in that capacity) or collect tax at source under Section 52 (in that capacity, for their own GSTR-9 obligation as a TDS deductor/TCS collector — this does not exempt an e-commerce operator from GSTR-9 as a regular taxpayer for their own supplies, only from a return specific to the TDS/TCS role).
Composition taxpayers file a different, GSTR-9A-linked annual-return history (verify current applicability — this form has been discontinued/merged into other filings at various points; confirm the current position rather than assuming GSTR-9A still applies).

Test	Conclusion
Aggregate turnover for the year (₹)
GSTR-9 applicable? (Y/N — mandatory / optional / not applicable)
GSTR-9C applicable? (Y/N)

Prepared by: ____________________ Reviewed by: ____________________

Date: 31 July 2026

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What’s inside

An excerpt from the template.

GST ANNUAL RETURN (GSTR-9/9C) APPLICABILITY CHECKLIST

Entity: ___ · GSTIN: ___ · Financial year ended: ___

A. GSTR-9 (annual return)

B. GSTR-9C (reconciliation statement)

↑ Excerpt only — the full template is what you download as Word

About this template

What you’re downloading, and when to use it.

This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

Everything is generated in your browser and on a stateless API endpoint — no account, nothing stored on our servers. We’ll ask for a work email once before your first download so we can send you the file and the occasional relevant update; after that, downloads on this device are instant. Edit freely in Word, Google Docs or Pages before sending to your client.

Common questions

FAQs.

Is GSTR-9 mandatory for every registered person?

No — below a notified small-taxpayer turnover threshold, filing GSTR-9 is optional (the taxpayer may still choose to file it voluntarily). Above that threshold it becomes mandatory. Certain categories (casual taxable persons, non-resident taxable persons, Input Service Distributors) are excluded from GSTR-9 entirely regardless of turnover. Always verify the currently notified threshold figure for the specific financial year, since it has changed across years.

Does crossing the GSTR-9C threshold still require a CA to certify it?

No — CA/Cost Accountant certification of GSTR-9C was removed with effect from FY 2020-21 onward; it is now self-certified by the registered person. The underlying reconciliation work (see the `gstr9-books-reconciliation` working paper) is still typically performed with professional assistance even though the certification requirement itself no longer exists.

Does an e-commerce operator that collects TCS still need to file its own GSTR-9?

Yes, for its OWN outward supplies as a regular registered taxpayer (assuming it crosses the applicable threshold) — the TDS/TCS-role exclusions from annual return filing relate to a separate return specific to that TDS/TCS role, not to the operator's ordinary GSTR-9 obligation for the supplies it makes on its own account.

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