New Restriction on Late Filing to Be Implemented from November 2025
📅 Issued: 29th October 2025
📢 By: Goods and Services Tax Network (GSTN)
🧾 Background
The Goods and Services Tax Network (GSTN) has issued an important advisory reminding taxpayers to file all pending GST returns before the expiry of three years from their respective due dates.
This comes as part of the implementation of Section 37, 39, 44, and 52 of the CGST Act, as amended by the Finance Act, 2023 (Act No. 8 of 2023), effective 1st October 2023 via Notification No. 28/2023 – Central Tax dated 31st July 2023.
The law prohibits filing any GST return after three years from its original due date — a major compliance reform aimed at closing long-pending defaults and cleaning up historical GST data.
⏳ Key Change Explained
Earlier, GST law allowed taxpayers to file their pending returns for any old period, even after several years, albeit with late fees and interest.
Now, under the new provisions, the GST portal will automatically block the filing of any return once three years have elapsed from its original due date.
To provide taxpayers with sufficient time to comply, the implementation timeline has been pushed to the November 2025 tax period.
This means that returns older than three years (as of November 2025) will be permanently barred from filing on the portal.
📢 Official Advisory Highlights (GSTN, 29th October 2025)
- As per Finance Act 2023, taxpayers cannot file GST returns after 3 years from the due date under the following sections:
- Section 37 – Outward Supply (GSTR-1 / IFF)
- Section 39 – Payment of Tax Liability (GSTR-3B, GSTR-4, GSTR-5, etc.)
- Section 44 – Annual Return (GSTR-9, GSTR-9C)
- Section 52 – Tax Collected at Source (GSTR-8)
- These sections collectively cover the following return forms:
GSTR-1, GSTR-1A, GSTR-3B, GSTR-4, GSTR-5, GSTR-5A, GSTR-6, GSTR-7, GSTR-8, GSTR-9, and GSTR-9C. - The restriction will be activated from the November 2025 tax period, meaning returns whose due dates were three years earlier or more cannot be filed after 30th November 2025.
- A similar advisory was previously issued on 29th October 2024, but the effective implementation date has now been extended to December 2025 for taxpayer convenience.
📊 Illustration of Returns to Be Blocked w.e.f. 1st December 2025
| GST Form | Period to Be Blocked | Description |
|---|---|---|
| GSTR-1 / IFF | October 2022 | Outward Supply Return (Monthly) |
| GSTR-1 (Quarterly) | July – September 2022 | For QRMP taxpayers |
| GSTR-3B (Monthly) | October 2022 | Summary Return with Payment |
| GSTR-3B (Quarterly) | July – September 2022 | For small taxpayers under QRMP |
| GSTR-4 | FY 2021-22 | For Composition taxpayers |
| GSTR-5 | October 2022 | For Non-resident taxable persons |
| GSTR-6 | October 2022 | For Input Service Distributors |
| GSTR-7 | October 2022 | For TDS Deductors |
| GSTR-8 | October 2022 | For TCS Collectors (E-commerce operators) |
| GSTR-9 / 9C | FY 2020-21 | Annual Return & Audit Report |
📌 Meaning of the Change
After 1st December 2025, if a taxpayer has not filed their pending return for any period earlier than the above, the system will automatically disallow the filing option.
In simple words:
Returns due before October 2022 (for monthly) or Q2 FY 2022-23 (for quarterly) will no longer be accessible for filing.
💡 Why This Restriction Has Been Introduced
The Government aims to:
- Clear the backlog of unfiled and inactive GSTINs.
- Improve the accuracy of return data and ITC reconciliation across the ecosystem.
- Prevent misuse or backdated compliance that could affect the integrity of GST credit chains.
- Encourage timely compliance and closure of old defaults.
⚠️ Practical Implications for Taxpayers
- Businesses with pending filings from FY 2020-21, 2021-22, or 2022-23 must act immediately.
- Once the blocking takes effect, such returns cannot be filed even with penalties or late fees.
- Failure to file may result in:
- ITC mismatches for buyers
- Demand notices for non-filing
- Risk of registration cancellation
🧮 Example:
If your GSTR-3B for October 2022 was due on 20th November 2022, the three-year limit expires on 20th November 2025.
After that date, you cannot file this return on the GST portal — even if you wish to voluntarily comply later.
📢 Action Steps for Taxpayers
✅ Review and reconcile pending GST returns up to FY 2021-22 and FY 2022-23.
✅ File all missing returns (GSTR-1, 3B, 4, 7, 8, 9/9C, etc.) before 30th November 2025.
✅ Inform your clients or accountants to complete filings before the portal blocks access.
✅ Ensure ITC, tax payment, and interest calculations are completed accurately.
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