GST returns and ongoing compliance
The monthly cycle is the part of GST that feels settled, which is exactly why the changes to it have gone unnoticed in a lot of finance functions. Outward liability in GSTR-3B stopped being editable in 2025. Returns older than three years stopped being filable at all. The Invoice Management System changed what happens when nobody clicks anything. This guide sets out the cycle as it now runs.
The cycle, as it stands
| Return | Who files it | Due |
|---|---|---|
| GSTR-1 | Outward supplies, monthly filers | 11th of the following month |
| GSTR-1A | Optional amendment to GSTR-1 for the same period | After GSTR-1 is filed or its due date passes, and before GSTR-3B for that period |
| GSTR-3B | Summary return and payment, monthly filers | 20th of the following month |
| GSTR-3B, quarterly | QRMP filers | 22nd or 24th of the month following the quarter, depending on the state |
| GSTR-6 | Input Service Distributor | 13th of the following month |
| GSTR-7 and GSTR-8 | Tax deducted at source, and tax collected at source by e-commerce operators | 10th of the following month |
| GSTR-9 | Annual return, where aggregate turnover exceeds ₹2 crore | 31 December following the financial year |
| GSTR-9C | Reconciliation statement, self-certified, where aggregate turnover exceeds ₹5 crore | 31 December following the financial year |
The ₹2 crore exemption from GSTR-9 is now standing rather than annual. Notification 15/2025-Central Tax, dated 17 September 2025, is drafted to apply from financial year 2024-25 onwards, so it holds for 2025-26 without a fresh notification. GSTR-9C has been self-certified rather than certified by a chartered accountant or cost accountant since financial year 2020-21.
One ordering rule that is easy to trip over: GSTR-3B for a period can only be filed once GSTR-2B for that period is available on the portal, and GSTR-2B for a period is not generated until the previous period’s GSTR-3B has been filed. Fall two months behind and the sequence has to be unwound in order.
QRMP: quarterly returns, monthly money
The Quarterly Return, Monthly Payment scheme is open to a taxpayer with aggregate annual turnover on a PAN basis of up to ₹5 crore in the current and preceding financial year, provided the most recent GSTR-3B has been filed. The election is per GSTIN, not per entity.
Returns go quarterly. Payment does not. In months one and two of the quarter tax is paid in Form PMT-06 by the 25th, under one of two methods: the fixed sum method, which is 35% of the cash tax paid in the previous quarter computed head by head, or the self-assessment method, which is the actual liability less credit available per GSTR-2B.
The Invoice Furnishing Facility lets a QRMP filer upload business-to-business invoices for months one and two by the 13th of the following month, capped at ₹50 lakh per month, so that recipients get their credit without waiting for the quarterly GSTR-1. It is optional. Whether it is worth using is usually decided by your customers rather than by you.
GSTR-2B is not generated for the first two months of a quarter for a QRMP filer, only for the last month. A monthly reconciliation habit built on GSTR-2B does not survive a move to QRMP unchanged.
GSTR-3B stopped being a place to fix things
From the July 2025 tax period, the auto-populated outward liability in GSTR-3B, Tables 3.1 and 3.2, became non-editable. The figures come from GSTR-1, GSTR-1A and the Invoice Furnishing Facility, and they cannot be overwritten in GSTR-3B. The change was first announced in October 2024 for January 2025, deferred in January 2025 after representations, and re-confirmed by a GST Network advisory of 7 June 2025 for the July 2025 period.
The practical consequence is a change in where the truth lives. GSTR-1 and GSTR-1A are now the single source of outward liability. If an error is spotted after GSTR-1 is filed, the only route is to amend through GSTR-1A before filing GSTR-3B for that period. Once GSTR-3B is filed, GSTR-1A for that period is closed, and the correction becomes a next-period amendment with whatever interest that carries.
This rewards a review step that many finance functions do not have: a check of the outward register between filing GSTR-1 and filing GSTR-3B, in the window where a mistake is still free to fix.
Whether the input tax credit table of GSTR-3B has also been locked is not settled in published material, and we have not stated a position on it here. Treat any claim you read either way as needing checking against the portal on the day.
The three-year bar, and the door that opened afterwards
Sections 37(5), 39(11), 44(2) and 52(15), inserted by the Finance Act 2023, bar the filing of a GST return after three years from its due date. Those provisions came into force on 1 October 2023, but the portal did not enforce them for two more years. Enforcement began from the November 2025 tax period, which means returns became permanently barred from 1 December 2025. The bar now rolls forward month by month.
It covers the whole set: GSTR-1, GSTR-1A, GSTR-3B, GSTR-4, GSTR-5, GSTR-5A, GSTR-6, GSTR-7, GSTR-8, and GSTR-9 and 9C.
Since 4 February 2026 the portal has carried an Application for Unbarring Returns, under Services, then Returns. The taxpayer states reasons; the jurisdictional assessing officer decides; on approval the barred periods reopen and must be filed within thirty days or they may be barred again. It is a discretionary concession, not an entitlement, and it is absent from most published material on this topic, which still describes the bar as absolute.
This is the item most worth acting on if you are carrying old defaults. A dormant registration, a business that stopped filing during a dispute, an acquired entity whose historical filings were never completed: each of those is a case where the difference between applying now and applying later is whether the returns can be filed at all.
The Invoice Management System: doing nothing is a decision
The Invoice Management System has been live on the portal since 1 October 2024. Every inward document from a supplier lands there and can be accepted, rejected, or kept pending. The rule that matters most is what happens when none of those is done: a record on which no action is taken is deemed accepted and flows into your GSTR-2B as available credit. Ignoring the system is not neutral. It is acceptance.
Accepted records feed GSTR-2B, rejected records are excluded, and pending records are carried out of that period. Draft GSTR-2B is generated on the 14th of the following month. You can still act after that and before filing GSTR-3B, but you must then use the recompute facility to regenerate GSTR-2B, or you will file against a stale statement.
From the October 2025 tax period four things changed:
- Pending status was extended to credit notes and certain amendments that previously demanded an immediate accept or reject.
- A pending record can be held for one tax period only, a month for monthly filers and a quarter for quarterly filers, expiring on the following period’s GSTR-3B due date, after which it is deemed accepted.
- On accepting a credit note you are asked whether input tax credit needs to be reduced, and by how much, so that a partial reversal is possible instead of an automatic full one. Where no credit was availed on the original invoice, no reversal is required.
- Remarks can be added on rejection or pending, and are visible to the supplier.
Two statutory changes from 1 October 2025 sit behind this and are the reason it is no longer safe to treat the system as optional housekeeping. Section 38 was amended so that credit is available only in respect of records that are in GSTR-2B, and Section 34(2) was amended so that a supplier’s output tax liability reduces on a credit note only if the recipient has reversed the corresponding credit. The second one changes the commercial dynamic: your supplier now needs you to act.
E-invoicing: the threshold has not moved, the reporting window has
Mandatory e-invoicing applies where aggregate annual turnover exceeded ₹5 crore in any financial year from 2017-18 onwards. That threshold has been in place since 1 August 2023 and has not been lowered since, despite a steady stream of speculation that it would be. Turnover is measured at PAN level across all registrations.
An Invoice Reference Number is required for tax invoices, credit notes and debit notes covering business-to-business supplies, supplies to a special economic zone, exports and deemed exports. Business-to-consumer supplies are outside it. A small set of entity categories is exempt, including banks and financial institutions, insurers, goods transport agencies, passenger transport and multiplex cinema exhibition.
The change that catches people is the thirty-day reporting window. A taxpayer with aggregate annual turnover of ₹10 crore or more must report an invoice, credit note or debit note to the Invoice Registration Portal within thirty days of the document date. This applied only at ₹100 crore and above until 1 April 2025, when it was extended down to ₹10 crore. The portal rejects a document outside the window outright, and there is no correction route: an invoice that misses it cannot be given an Invoice Reference Number at all.
Two thresholds, two different numbers, and they get conflated constantly. ₹5 crore decides whether you e-invoice. ₹10 crore decides whether you have thirty days to do it.
E-way bills, and one thing that did not happen this month
An e-way bill is required for movement of goods where the consignment value exceeds ₹50,000, generated before the movement starts. Validity runs one day per 200 kilometres or part, and one day per 20 kilometres for over-dimensional cargo, with a minimum of one day.
Two validations introduced on 1 January 2025 matter for anyone raising bills against older paperwork:
- An e-way bill cannot be generated against a document dated more than 180 days before the date of generation.
- Validity can be extended only up to 360 days from the original date of generation.
The E-Way Bill 2.0 portal went live on 1 July 2025, running alongside the original portal with real-time synchronisation, so a bill generated on one can be extended or updated on the other.
A further set of changes, including a mandatory Ship-To GSTIN for bill-to and ship-to transactions, was scheduled for 1 August 2026 and was put on hold shortly before that date, with the related guidance withdrawn and no new date announced. A good deal of material published in mid-2026 still describes these as being in force. They are not, as matters stand.
Late fees and interest, and the distinction that saves money
Late fee under Section 47 for GSTR-1 and GSTR-3B is ₹50 per day, being ₹25 central and ₹25 state, reduced to ₹20 per day for a nil return. Caps depend on turnover: ₹500 for a nil return, ₹2,000 up to ₹1.5 crore, ₹5,000 between ₹1.5 crore and ₹5 crore, and ₹10,000 above ₹5 crore. Late fee must be paid in cash. Credit cannot be used for it.
Interest under Section 50 runs at 18% a year on tax not paid by the due date. The distinction worth knowing is in the proviso to Rule 88B(1): where GSTR-3B is filed late but no proceedings under the demand provisions have started, interest is charged only on the part of the liability discharged from the electronic cash ledger, not on the part set off against credit. Money credited to the cash ledger before the due date does not attract interest either, whether or not the return went in on time.
Where credit has been wrongly availed and utilised, Section 50(3) applies an interest rate of 18% a year, running from the date of utilisation to the date of reversal or payment. Credit wrongly availed but never utilised does not attract it.
What an engagement on this looks like
Running the monthly cycle
Preparation and filing of GSTR-1, GSTR-1A and GSTR-3B with a review step in the window where an outward error is still free to correct, plus the Invoice Management System actioned rather than left to deem itself accepted.
Annual return and reconciliation
GSTR-9 and GSTR-9C prepared from a reconciliation rather than from the return summary, which is where the differences that later become notices actually surface.
Clearing a backlog
Working out what can still be filed under the three-year bar, what needs an unbarring application first, and in what order, so that the sequence does not stall halfway.
Send an enquiry
Tell us whether this is the routine monthly cycle, an annual return, a backlog you are trying to clear, or a reconciliation that is not tying out. A partner replies within one business day.
This page is general information, not professional advice. Indian GST law changed substantially between 2024 and 2026, several changes are enacted but not yet notified into force, and how any of this applies depends on your own facts, your state and your sector. Take professional advice before acting on anything on this page. We are happy to be that adviser, but we do not act on a web page, ours or anyone else's, without one.