CBIC Issues Notification No. 09/2025–Central Tax (11th Feb 2025): Key Amendments and Compliance Impact
Background and Legal Framework
The Notification issues by the authority given by section 164 of the Central GST Act, 2017. This is based on the provisions which are laid down in the CGST Amendment Rules, 2024. These were notified through Notification No. 12/2024-Central Tax. It is also published in the Gazette of India. Notification No. 09/2025 formalizes effective dates for amends so that they can be phased-in.
A table attached to this notification has detailed dates which indicate the coming into force of such provisions. While it is only in effect on 11th February 2025 for Rule 2, 24, 27, and 32, other requirements like Rule 8, 37 and clause (ii) of Rule 38 commence on 1st April 2025.
Key Amendments Effective from 11th February 2025
The provisions set to be enforced on 11th February 2025 target four critical areas of the GST process:
Rule 2: Streamlining GST Registration Through Aadhaar Authentication
Rule 2 introduces a revised mechanism for GST registration. Under the new procedure:
- For applicants opting for Aadhaar authentication:
The submission date of the GST registration application will be recorded as the date of Aadhaar authentication, or fifteen days from the submission of Part B of Form GST REG-01—whichever occurs earlier.
- For applicants not opting for Aadhaar authentication:
The applicant is required to have their photograph taken (if an individual) or that of the relevant persons (in case of non-individual entities) and must also undergo verification of the originally submitted documents at a designated Facilitation Center. The application is considered complete only after this verification is successfully completed.
This change is intended to reduce delays in registration and improve the accuracy of submission dates, thereby facilitating smoother onboarding of taxpayers
Rule 24: Enhancing E-Way Bill Generation for Unregistered Persons
Rule 24 addresses the process by which unregistered persons—who are required to generate an e-way bill under GST—must submit their details:
- These individuals must furnish their information electronically on the common GST portal, either directly or via a Facilitation Center.
- Once the details are validated, a unique enrollment number is generated and communicated to the applicant.
This amendment aims to ensure that even unregistered taxpayers can generate e-way bills efficiently and accurately, thereby reducing compliance complexities and the risk of errors
Rule 27: Introduction of a New Enrollment Form (ENR-03)
To further streamline the e-way bill process for unregistered persons, Rule 27 introduces a new application form—Form ENR-03. This form is designed specifically for those who need to enroll on the common portal in order to generate their e-way bills. The new process is expected to simplify the application procedure and improve the turnaround time for obtaining the necessary enrollment number.
Rule 32: Updating GSTR-3B Reporting
Rule 32 brings about a key change in the way taxpayers report supplies made under Section 9(5) of the CGST Act:
- A new reporting table (Table 3.1.1) is introduced in GSTR-3B.
- Both the supplier and the e-commerce operator are required to report the relevant supplies using this new table.
This amendment enhances transparency and accuracy in tax reporting by ensuring that all relevant transactions are captured in a standardized format.
Implementation Timeline and Broader Impact
The phased implementation of these amendments is designed to allow businesses and tax professionals to adapt gradually to the new processes. With Rules 2, 24, 27, and 32 coming into force on 11th February 2025, stakeholders will immediately experience improvements in:
- Registration processes: Faster and more reliable GST registration due to the streamlined Aadhaar authentication mechanism.
- E-way bill compliance: A simplified and more efficient method for generating e-way bills for unregistered persons.
- Reporting: Enhanced accuracy in the filing of GSTR-3B returns, which should reduce discrepancies and facilitate smoother tax administration.
The remaining provisions (Rules 8, 37, and clause (ii) of Rule 38) are set to be implemented on 1st April 2025, further building on the reformative measures introduced by this notification.
Implications for Taxpayers and the GST Ecosystem
By addressing several long-standing challenges in the GST registration and compliance processes, Notification No. 09/2025 is expected to yield significant benefits:
- Reduced Compliance Burden: Streamlined procedures minimize paperwork and administrative delays.
- Improved Accuracy: The clear timelines and verification requirements help in maintaining accurate records and submission dates.
- Enhanced Transparency: Standard formats for reporting facilitate the monitoring and verification of transactions by the tax authority, resulting in the lessening of likelihood for litigation and disputes.
The reforms are intended to improve the tax administration, enhance transparency, and promote voluntary compliance with tax rules by the taxpayers.
Conclusion
Notification No. 09/2025–Central Tax, dated 11th February 2025, represents a strategic step toward reforming the goods and service tax (GST) architecture in India. It is based on important amendments in relation to GST registration, e-way bill generation, and return filing. By reducing the compliance burden on the taxpayer, the notification, however, strengthens the overall administration of the GST system. The phased implementation strategy will ensure a smooth transitional flow as businesses prepare themselves to align with these changes, reinforcing the government's commitment to a more efficient and transparent tax regime.
Note:-For All information and official documentation, taxpayers should read to the CBIC's official portal or consult with tax professionals to ensure accurate interpretation and application of the new rules.