GST Audit Threshold — Who Needs GSTR-9C in FY 2026-27?
GSTR-9C is a reconciliation statement that reconciles the figures reported in GSTR-9 with the taxpayer’s annual financial statements. Importantly, the old requirement of mandatory GST audit by a Chartered Accountant/Cost Accountant has been removed. For the current framework, taxpayers crossing the prescribed turnover threshold are required to furnish a self-certified GSTR-9C. CBIC has specifically clarified that the threshold for GSTR-9C is aggregate turnover exceeding ₹5 crore in a financial year.
Who Needs to File GSTR-9C?
For FY 2026-27, a registered taxpayer whose aggregate turnover exceeds ₹5 crore during the financial year will generally be required to furnish:
- GSTR-9 — Annual Return
- GSTR-9C — Self-certified Reconciliation Statement
Therefore:
| Aggregate Turnover FY 2026-27 | GSTR-9C |
|---|---|
| Up to ₹5 crore | Generally not required |
| More than ₹5 crore | Required |
| ₹5 crore exactly | Generally not required |
| ₹5.01 crore | Required |
The ₹5 crore test is based on aggregate turnover, not simply the taxable turnover shown in one GSTIN.
Is CA Certification Required?
No. This is an important change.
Earlier, GSTR-9C was required to be certified by a Chartered Accountant or Cost Accountant. Under the current provisions, the reconciliation statement is self-certified by the taxpayer. CBIC has expressly confirmed that, from 1 August 2021 onwards, taxpayers exceeding ₹5 crore aggregate turnover are required to furnish a self-certified GSTR-9C.
What Does GSTR-9C Reconcile?
GSTR-9C primarily reconciles:
- Turnover as per financial statements with GSTR-9
- Taxable turnover
- Tax paid
- Input Tax Credit (ITC)
- Differences between books and GST returns
- Reasons for unreconciled differences
The GSTN’s current GSTR-9C guidance includes reconciliation of turnover, tax paid and ITC.
Example
Suppose a company has the following aggregate turnover during FY 2026-27:
₹6.80 crore
Since the turnover exceeds ₹5 crore, the company will generally need to file:
GSTR-9 + GSTR-9C
The GSTR-9C should be prepared by reconciling the GST returns with the financial statements and then self-certified before filing.
Due Date
The statutory due date for the annual return, including GSTR-9C where applicable, is generally 31 December following the end of the financial year, unless the Government extends the deadline. Thus, for FY 2026-27, the normal due date would be 31 December 2027.
Important Point — GSTR-9C ≠ GST Audit
It is better to use the term “GSTR-9C reconciliation statement” rather than assuming that every taxpayer filing GSTR-9C is undergoing a mandatory GST audit.
The earlier statutory requirement under Section 35(5) for accounts to be audited for GST purposes was removed, while Section 44 and Rule 80 continue to require GSTR-9C for taxpayers crossing the prescribed threshold.
Conclusion
For FY 2026-27, the key GSTR-9C threshold is aggregate turnover exceeding ₹5 crore. Eligible taxpayers generally need to file GSTR-9 along with a self-certified GSTR-9C. A separate CA/Cost Accountant certification is no longer required merely for GSTR-9C. Businesses crossing the ₹5 crore threshold should reconcile their books, GST returns, turnover, tax liability and ITC well before the annual-return filing deadline to identify and resolve differences.
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Kartar Sonwal is an Accounts Executive in TAXAJ's Accounts & Taxation team. With over six years of industry experience, Kartar handles bookkeeping, tax filings and day-to-day compliance for clients. TAXAJ is a multi-disciplinary consulting firm spanning finance, taxation, legal, secretarial, FEMA and IPR, with offices in Delhi, Bihar, Bangalore and Goa.
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