GST changes from 1 November 2026: what businesses must know

The government has started rolling out the GST reforms recommended by the GST Council in phases. The first set took effect on 1 November 2026: the Finance Act, 2026 change on post-sale discounts, faster refunds, a new registration form and an easier way to surrender a GST number. Changes that need further amendments to the CGST Act are lined up for 1 April 2027.

Here is what changed, who is affected and what you should do this month.

At a glance

1. Discounts after the sale: credit note is enough

Until now, Section 15(3)(b) of the CGST Act allowed a post-supply discount to be excluded from the value of supply only if it was established by an agreement entered into at or before the time of supply and linked to specific invoices. This was the root of many disputes on turnover discounts, year-end schemes and dealer incentives.

From 1 November 2026 the prior-agreement condition is removed and Section 34 recognises credit notes issued for such discounts. In practice:

• Supplier – issues a GST credit note for the discount and reports it in GSTR-1 / IFF; output tax reduces.
• Recipient – must reverse the input tax credit attributable to the discount. The supplier's reduction is linked to this reversal, so follow up with your buyers.
• Time limit still applies – a credit note for a financial year can be declared only up to 30 November of the following year (or the annual return date, if earlier). For FY 2025-26 supplies that date is 30 November 2026.
• Old disputes – the change applies from 1 November 2026. Notices on earlier years will still be decided under the old wording, though the amendment helps in arguing intent.

If you give year-end schemes to dealers, revisit your scheme letters and ITC reversal process now, so the credit note is accepted in the buyer's books.

2. Faster, automated refunds

The refund changes aim at the two biggest refund categories – exports (zero-rated supplies) and inverted duty structure:

• 90% provisional refund for zero-rated supplies and inverted duty claims, sanctioned on the basis of system risk assessment, with the balance after verification.
• Excess cash-ledger balance – refund of the excess balance in the electronic cash ledger is to be processed automatically.
• Shorter acknowledgement time – acknowledgement or deficiency memo within a shorter window than the earlier 15 days.
• Prospective – the automation applies to fresh claims; applications already pending continue in the old manner.

Tip: automated processing relies on clean data. Make sure GSTR-1, GSTR-3B, shipping bills / e-invoices and bank realisation data match before you file RFD-01; mismatches push the claim into manual scrutiny.

3. Revised GST registration form REG-01

New registration applications from 1 November 2026 are filed on a revised FORM GST REG-01. Existing GSTINs do not re-register. The main changes reported:

• One Person Company (OPC) shown as a separate type of constitution.
• SEZ Entity ID mandatory for SEZ units and developers, checked against SEZ records.
• A separate section for e-commerce operators paying tax under Section 9(5) (food delivery, passenger transport, accommodation).
• Principal place of business chosen from a fixed list of premises types.
• Up to 10 bank accounts can be reported.
• CIN, LLPIN, FCRN and FLLPIN validated online against MCA records.
• PAN–Aadhaar linking checked for promoters, partners, directors and authorised signatories.
• Standard size and format for uploaded documents.
• ARN generated only after all online validations pass.

What this means: applications with an unlinked PAN–Aadhaar, mismatched MCA data or weak address proof will now be stopped at the filing stage itself. Check these before applying. Our GST registration service in Delhi covers the full checklist.

4. Surrendering a GST number: system-based cancellation

Rule 20 of the CGST Rules has been substituted to create a system-enabled route for voluntary cancellation under Section 29(1), in addition to the officer-approved route:

• Meant for small taxpayers – the eligibility test is based on monthly output tax on supplies, not turnover.
• Apply in FORM GST REG-16 on the portal (Services → Registration → Application for Cancellation of Registration), after filing all pending returns and paying dues.
• If the officer does not act within the prescribed time, the application is treated as approved.
• File the final return GSTR-10 within three months of the cancellation date or order, whichever is later – otherwise a late fee and a notice follow.
• Cancellation does not wipe out past liability. Old notices and demands can still be raised for earlier periods.

5. Small online sellers: e-commerce warehouse as place of business

Reports of the 1 November rollout also mention a relaxation for small suppliers selling only through e-commerce platforms: subject to conditions, such a seller with no physical presence in a state may declare the e-commerce operator's warehouse in that state as the principal place of business. The concession is limited to sellers whose ITC passed on stays within a monthly ceiling. Check the final notification and the portal functionality before relying on it.

What is coming on 1 April 2027

Measures that need amendments to the CGST Act are expected from 1 April 2027. These include higher thresholds for prosecution and arrest, a minimum amount for issuing show-cause notices, e-way bill changes and wider ITC changes. A simpler annual-return system with quarterly payment for small B2C businesses has also been approved in principle. We will update this guide when these are notified.

Your November 2026 checklist

• Review dealer schemes and issue FY 2025-26 credit notes before 30 November 2026.
• Claim missed FY 2025-26 ITC before the same date and reconcile with GSTR-2B – see our GSTR-9 and 9C guide.
• Exporters: clean up data before the next refund claim to get the 90% provisional refund.
• New registrations: link PAN–Aadhaar of all promoters and keep MCA data updated.
• Closing a business: file pending returns, then REG-16 and GSTR-10 on time.
• Got a notice on old-year discounts or ITC? Read our GST notice reply guide.

This article is for general information, based on the notifications and official briefings reported up to 7 November 2026. Some details are being rolled out in phases on the GST portal; check the notification text or speak to us before acting.

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