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1. BACKGROUND & LEGAL CONTEXT

The Government of India, Ministry of Finance (Department of Revenue), through the Central Board of Indirect Taxes and Customs (CBIC), has issued Notification No. 18/2025 – Central Tax dated 31st October 2025.This introduces the Central Goods and Services Tax (Fourth Amendment) Rules, 2025, effective 1 November 2025.

These amendments modify the GST registration framework by introducing automation, risk-based verification, Aadhaar-linked authentication, and a new simplified registration route for small taxpayers.

2. OBJECTIVE OF THE AMENDMENT

The move aims to:

√ Use data analytics and risk parameters to identify genuine taxpayers.

√ Simplify registration for low-turnover businesses and startups.

√ Reduce manual processing time from 7 days to 3 days.

√ Strengthen safeguards against fake GST registrations and bogus invoicing.

3. MAJOR AMENDMENTS INTRODUCED

 A. Rule 9A – Automatic Grant of Registration

√ What’s new?

A completely automated GST registration process based on data analysis and risk scoring.

√ Key Features:

  • Registration granted electronically within 3 working days.
  • The system uses risk parameters to automatically verify applications.
  • If no discrepancies or risk are detected, no human intervention is required.
  • Applies to applications under Rule 8 (Normal), Rule 12 (Tax Deductor/Collector), and Rule 17 (Non-resident Taxpayer).

√ Impact:

  • Faster onboarding for legitimate taxpayers.
  • Reduced physical verification and departmental delays.
  • Enhanced transparency and consistency in registration approvals.

B. Rule 14A – Optional Registration for Low Output Tax Liability (≤ ₹2.5 Lakh/Month)

A new special registration category for small suppliers primarily making B2B supplies.

i. Eligibility Criteria:

  • Applicant’s monthly output tax liability ≤ ₹2,50,000 (including CGST, SGST/UTGST, IGST, and cess).
  • Must have Aadhaar authentication (mandatory).
  • Not covered under Section 25(6D) (persons notified for enhanced verification).
  • Can opt out (withdraw) later if business grows.

 ii. Grant of Registration:

  • Registration processed electronically within 3 working days after Aadhaar authentication.
  • Based on system-based verification and risk analysis.

 iii. Withdrawal Option:

A taxpayer registered under Rule 14A can withdraw from this scheme if output tax exceeds the threshold. Withdrawal application to be filed in FORM GST REG-32, and upon officer approval, FORM GST REG-33 is issued.

Conditions before withdrawal:

  • All pending returns filed up to the date of application.
  • Minimum:

♦ 3 months’ returns if applied before 1 April 2026, or

♦ 1 tax period if applied after 1 April 2026.

  • No pending cancellation proceedings under Section 29.

iv. Aadhaar Authentication & Digital Verification

  • Aadhaar OTP or biometric verification is mandatory for both primary authorised signatory and one promoter/partner.
  • Applications under 14A and withdrawal forms (REG-32) will only be processed after Aadhaar verification.

√ Why important?

This step eliminates fake registrations and ensures traceability of responsible persons.

4. CHANGES IN GST FORMS

Form No. Change Introduced
REG-01 Added an option to select registration under Rule 14A and Aadhaar OTP authentication.
REG-02 Updated to include reference to Rule 14A.
REG-03 Revised format for seeking clarifications (includes withdrawal cases).
REG-04 Revised for submission of additional information or amendments during registration or withdrawal.
REG-05 Updated order of rejection format to include “Withdrawal” applications.
REG-32 New form introduced – Application for Withdrawal from Rule 14A option.
REG-33 New form introduced – Order approving withdrawal from Rule 14A registration.

5. COMPARATIVE TABLE – EARLIER VS. NEW GST RULES (2025 UPDATE)

Aspect Earlier Regime (Before 1 Nov 2025) New Regime (After 1 Nov 2025)
Rule for registration approval Rule 9 – Manual verification and approval by an officer within 7 days. New Rule 9A – Electronic registration approval within 3 days based on risk data.
Special category for small taxpayers No special provision. Rule 14A was introduced for taxpayers with a monthly output tax ≤ ₹2.5 lakh.
Aadhaar Authentication Optional in many cases. Mandatory under Rule 14A and REG-32/33 process.
Multiple registrations (same State) Allowed for distinct business verticals. Not allowed under Rule 14A for the same PAN.
Withdrawal option Only cancellation is available under Section 29. New withdrawal system via FORM REG-32 and REG-33.
Verification model Physical or manual scrutiny by GST officers. AI-driven data analysis and risk-based verification.
Processing time 7 working days (or more). 3 working days (max).
Forms applicable REG-01 to REG-30. Revised REG-01 to REG-05 + new REG-32 & REG-33.
Ease of compliance Moderate. Significantly simplified, paperless, faster.

6. DETAILED LEGAL & PRACTICAL ANALYSIS

A. Shift Towards AI-Governed Registration

Rule 9A introduces a risk-scoring model where the GSTN portal evaluates applications using:

  • PAN and Aadhaar data validation,
  • Past compliance of promoters (if any),
  • Financial risk indicators,
  • Document consistency checks.

This ensures low-risk taxpayers get instant registration, while high-risk profiles face additional scrutiny or physical verification.

B. Ease for MSMEs and Startups

Rule 14A caters specifically to small-scale B2B traders, service providers, and manufacturers, reducing procedural burdens and improving turnaround time.
It reflects the government’s pro-business approach — enabling compliance without over-regulation.

C. Withdrawal Instead of Cancellation

Earlier, taxpayers exceeding turnover limits had to go through cancellation and fresh registration. Now, withdrawal allows seamless transition without losing previous filing records — a compliance-friendly innovation.

D. Regulatory Safeguards

Even though the process is simplified, several safeguards ensure integrity:

  • Mandatory Aadhaar verification,
  • Data-based monitoring,
  • Restrictions on multiple registrations,
  • Officer discretion for rejections under rule 14A(13).

E. Transitional Impact

  • Existing GST registrants remain unaffected.
  • New applicants from 1 Nov 2025 can opt into Rule 14A at registration.
  • Those with fluctuating turnover must monitor their liability monthly to stay compliant.

7. Compliance Checklist (For Practitioners)

Task Timing Notes
Apply under Rule 14A During registration Ensure monthly tax ≤ ₹2.5 lakh
Aadhaar Authentication At registration OTP or biometric mandatory
File returns Monthly/Quarterly Required before any withdrawal
Withdrawal (REG-32) When the threshold exceeds Must clear all pending returns
Officer order (REG-33) Within the Rule 9 time limit Approves or rejects withdrawal

8. Conclusion

The Fourth Amendment Rules, 2025, mark a major digital transformation in India’s GST regime. By introducing automated registration (Rule 9A) and low-turnover-friendly Rule 14A, the government aims to balance ease of doing business with robust compliance checks.

For taxpayers, this means:

  • Faster approvals
  • Less documentation
  • Greater transparency
  • Flexible exit option
  • Zero tolerance for fake GST registrations.

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Disclaimer: The information provided is for educational purposes and should not be considered as professional advice. The author shall not be liable for any direct, indirect, special, or incidental damage resulting from, arising out of, or in connection with the use of the information.

Author Bio

I am a Practicing Company Secretary (PCS) based in Delhi, heading S Kothiyal & Associates, a firm specializing in corporate compliance and governance. I hold professional qualifications as a Company Secretary, Certified CSR Professional, and GST Professional from the Institute of Company Secreta View Full Profile

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