GST (Fourth Amendment) Rules, 2025: New Registration Framework And Compliance Architecture

The Ministry of Finance has notified the Central Goods and Services Tax (Fourth Amendment) Rules, 2025 through Notification No. 18/2025 dated 31 October 2025, effective 1 November 2025. The amendments introduce a new optional registration category for small suppliers, streamline electronic grant of registration, and revise multiple registration-related forms. Together, these changes reflect a stronger policy emphasis on risk-based compliance, identity authentication, and targeted facilitation for small businesses.

1. Rule 9A – Electronic Grant of Registration

What Rule 9A Introduces?

Rule 9A provides that registration applications filed under Rules 8 or 12 or 17 may be granted electronically through the GST common portal within three working days, based on Portal-driven identification, Data analytics, and Risk parameters determined by the portal.¹

This marks a procedural departure from the earlier framework, where the grant of registration although intended to be time-bound often depended on officer-level scrutiny and verification.

How Rule 9A Interacts With Existing Provisions ?

Under the pre-existing Rule 9, registration approval required Aadhaar authentication (if opted), Physical verification in certain flagged cases, and Officer-driven examination and potential queries.

Rule 9A does not replace Rule 9 but co-exists with it. Applicants cleared through risk algorithms will get near-instant approval, reducing officer workload and allowing the tax administration to focus on entities with inconsistent or suspicious data.

2. Rule 14A – Optional Registration for Small B2B Suppliers

Rule 14A is arguably the most substantive change in the Amendment Rules, creating a new registration category designed specifically for small suppliers making supplies primarily to registered persons.

What are the Eligibility Criteria?

An applicant may opt for registration under Rule 14A if:

1. Their monthly output tax liability (CGST + SGST/UTGST + IGST + Cess) on supplies made to registered persons does not exceed ₹2,50,000.²
2. Aadhaar authentication is mandatory (except those notified under section 25 (6D), either via OTP or biometric mode.³
3. The same PAN does not have another Rule 14A registration within the same State/UT.⁴

Importantly, the threshold limit applies to output tax liability rather than turnover. Liability from B2C supplies is excluded from this calculation.

Approval Process Under Rule 14A: Once Aadhaar authentication is completed, the GST Portal may grant Rule 14A registration within three working days, based on risk checks, data analytics and consistency between Aadhaar and PAN records.⁵ The applications flagged as high-risk are redirected to standard verification under Rule 9.

Compliance Expectations Under Rule 14A : Although optional, registration under Rule 14A once chosen, requires taxpayers to comply with standard GST obligations, including issuing tax invoices, filing returns and maintaining statutory records Section 35 and, responding to notices under Section 61 or Section 73/74. The threshold limit simply eases the pathway to registration without altering the underlying compliance framework.

3. Mechanism for Withdrawal – FORM GST REG-32 and REG-33

Taxpayers registered under Rule 14A may opt to withdraw from the optional category by filing FORM GST REG-32. The withdrawal framework includes strict safeguards to ensure that taxpayers do not use Rule 14A as a temporary or compliance-avoidance category.

Preconditions for Filing FORM GST REG-32:

1. If withdrawal is sought before 1 April 2026, the taxpayer has filed returns for at least three months from the date of registration.⁶⁶
2. If filed on or after 1 April 2026, returns for at least one tax period must be furnished.⁷
3. All returns due up to the withdrawal application date have been filed.⁸
4. No cancellation proceedings under Section 29 have been initiated.⁹

Verification Process for withdrawal Applications: Upon receipt of FORM GST REG-32, the proper officer will assess whether conditions are met or seek clarifications if required. Officer will issue FORM GST REG-33 allowing withdrawal, or reject the application via FORM GST REG-05. All of these must be done within the timelines prescribed under Rule 9.¹⁰ Once a withdrawal application is filed under Form GST REG 32, no amendment or cancellation applications are permitted until the withdrawal application is disposed of.

Post withdrawal procedures: Where withdrawal has been approved, the taxpayer must furnish details of output tax liability exceeding ₹2,50,000 limit from the first day of the succeeding month in which the FORM GST REG-33 order is issued.¹¹ Failure to do so may result in demands under Sections 73/74, interest liabilities under Section 50, and late fees.

4. Amendments to Forms and introduction of New Forms

GST REG-01: Updated to include a new Item 4.1, which requires applicants to declare whether they elect to register under Rule 14A and Aadhar requirements.

GST REG-02: Modified to reference Rule 14A in addition to Rule 8 (5).

GST REG-03: Updated to cover registration, amendment, cancellation, and withdrawal application.

GST REG-04: Modified to accommodate additional information requirements for withdrawal applications.

GST REG-05: Updated to include rejection orders for withdrawal applications under Rule 14A.

GST REG-32: New form for withdrawal applications from Rule 14A registration option.

GST REG-33: New form for Orders approving withdrawal from Rule 14A registration.

5. Practical Implications

For taxpayers, the amendments introduce both facilitation and stricter oversight. Rule 9A will substantially shorten registration timelines for low-risk applicants, particularly MSMEs, start-ups, and proprietors with consistent KYC details. However, the increased use of analytics also means that entities with mismatched documentation or historical compliance concerns may face heightened scrutiny, including physical verification or additional queries. Taxpayers must therefore ensure complete alignment across Aadhaar, PAN, address proof, and promoter details to avoid delays.

The introduction of Rule 14A offers a genuine compliance advantage for small suppliers engaged primarily in B2B transactions, enabling them to participate in the GST ecosystem with fewer hurdles. However, once registered, they remain subject to standard GST obligations such as invoicing, record-keeping, and return filing. The withdrawal mechanism through FORM GST REG-32 and FORM GST REG-33 also places clear responsibility on taxpayers to maintain timely compliance and avoid misuse of the optional category. Larger businesses sourcing from micro-suppliers should review their vendor-onboarding processes, as Rule 14A registration may become a preferred option for ensuring input tax credit (ITC ) continuity.

6. Conclusion

The GST (Fourth Amendment) Rules, 2025 mark a significant step in modernising India's GST compliance framework by integrating digital verification, targeted facilitation, and stronger identity controls. The introduction of Rule 9A reflects the Government's broader move toward a technology-driven, analytics-based registration system that accelerates approvals for low-risk applicants while directing officer scrutiny toward applications presenting inconsistencies or high-risk indicators. This shift aligns with global best practices in tax administration, where algorithmic screening has increasingly replaced manual verification to improve efficiency and safeguard revenue.

At the same time, Rule 14A introduces a thoughtful policy mechanism aimed at formalising small B2B suppliers who may have hesitated to enter the GST ecosystem due to compliance burdens. By offering a lower-friction pathway without compromising core statutory obligations, the amendment enhances ITC availability for recipients, improves invoicing discipline, and widens the base of compliant suppliers. The accompanying safeguards; Aadhaar authentication, PAN verification, structured withdrawal procedures, and risk-based approvals, demonstrate the Government's continued emphasis on preventing shell entities and strengthening identity integrity within the system.

Taken together, these amendments reflect a calibrated approach to reform in easing entry for genuine taxpayers while reinforcing checks against fraud and non-compliance. As the new framework is implemented, businesses, particularly small B2B suppliers and enterprises that rely on them, must ensure consistency in documentation, timely return filing, and readiness for risk-based checks. The reforms are ultimately aimed at fostering a more efficient, transparent, and reliable GST ecosystem, balancing ease of doing business with the need for robust compliance oversight.

TABLE: Rule 14A – Compliance Checklist

Footnotes

1. Notification No. 18/2025 – Central Tax, dated 31 October 2025, inserting Rule 9A into the CGST Rules, 2017.
2. Rule 14A(1), Central Goods and Services Tax Rules, 2017, inserted via Notification No. 18/2025 – Central Tax.
3. Rule 14A(2), ibid.
4. Proviso to Rule 14A(1), ibid.
5. Rule 14A(3), ibid.
6. Rule 14A(4)(i), ibid.
7. Rule 14A(4)(ii), ibid.
8. Rule 14A(4)(iii), ibid.
9. Rule 14A(5), ibid.
10. Rule 14A(6), ibid.
11. Rule 14A(7), ibid.

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