The nil return obligation catches many small business owners off guard. When your shop is closed for a month, or your trading company has no turnover during the off-season, or you have just registered for GST but have not yet started operations, the instinct is to do nothing and file next month when activity resumes. That instinct is wrong under GST law.
GST is a return-filing regime, not merely a tax-payment regime. The obligation to file exists independently of the obligation to pay tax. A nil return is how you formally tell the GST system that you had no transactions in a given period. Missing it exposes you to late fees, blocks your next returns, and can lead to cancellation of your registration.
Why Zero Transactions Still Require a Return
The obligation to file returns under GST arises from Section 39(1) (GSTR-3B) and Section 37(1) (GSTR-1) of the CGST Act 2017. Neither section exempts periods with zero transactions. Registration creates the obligation; only cancellation removes it.
The same logic runs across income tax and ROC filings too; see our guide on why zero-income businesses must still file ITR, GST and ROC.
The portal also enforces sequence. Under Section 37(4), you cannot file GSTR-1 for a period if GSTR-1 for an earlier period is pending, and under Section 39(10), you cannot file GSTR-3B for a period if an earlier GSTR-3B, or the GSTR-1 for that same period, is pending. So one unfiled nil month holds up every later return, including the months in which you do have sales and your buyers are waiting for their Input Tax Credit (ITC) in GSTR-2B.
Nil GSTR-3B: Monthly and Quarterly Filing
GSTR-3B is the monthly (or quarterly for QRMP) summary return of tax liability and ITC.
A GSTR-3B is nil only if, for the period, you have no outward supplies (including nil-rated, exempt or non-GST supplies), no inward supplies on reverse charge, no ITC to claim and no tax liability.
Monthly Filers
Due date: 20th of the following month.
To file a nil GSTR-3B on the GST portal:
- Log in at gst.gov.in with your username and password.
- Go to Services > Returns > Returns Dashboard and select the financial year and tax period.
- In the GSTR-3B tile, click "Prepare Online".
- Answer "Yes" to the question asking whether you want to file a nil return.
- File with EVC (electronic verification code) or DSC.
QRMP Quarterly Filers
Businesses with aggregate annual turnover up to Rs 5 crore in the preceding financial year can opt for the Quarterly Return Monthly Payment (QRMP) scheme. QRMP filers:
- File GSTR-3B quarterly (not monthly).
- Due dates: 22nd of the month after the quarter for taxpayers in the first group of States and UTs (Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, Daman and Diu and Dadra and Nagar Haveli, Puducherry, Andaman and Nicobar Islands, Lakshadweep), and 24th for all other States and UTs.
For nil quarters, the quarterly GSTR-3B is filed as nil. Monthly PMT-06 payments for the first two months are not required when there is no tax liability.
Filing Nil GSTR-3B via SMS
Rule 67A of the CGST Rules allows a nil GSTR-3B to be filed by SMS. Send an SMS to 14409 from the mobile number of an authorised signatory registered on the GST portal:
NIL 3B [GSTIN] [Return Period in MMYYYY]
Example: NIL 3B 27AAAAA0000A1Z5 052026 (for May 2026)
The portal replies with a 6-digit verification code. Reply with:
CNF 3B [Code]
On successful validation, the portal sends an ARN by SMS and email, confirming the return is filed. No portal login is needed.
Conditions: the return must be genuinely nil (see above), all earlier GSTR-3B returns must be filed, and there must be no data saved in the online GSTR-3B for that period. If you have even one outward supply, one ITC entry or one reverse charge transaction to report, you must use the portal.
Nil GSTR-1: Monthly and Quarterly Filing
GSTR-1 reports outward supplies (sales). A nil GSTR-1 has no invoices, no debit or credit notes, no advances, no exports and no nil-rated or exempt supplies to report.
Monthly Filers
Due date: 11th of the following month.
Portal filing process:
- Go to Services > Returns > Returns Dashboard, select the period and open GSTR-1.
- Leave all tables empty.
- Tick the option to file a nil GSTR-1 and proceed to file.
- File with EVC or DSC.
QRMP Quarterly Filers
Due date: 13th of the month after the quarter ends (13 July for April to June, 13 October for July to September, 13 January for October to December, 13 April for January to March).
Filing Nil GSTR-1 via SMS
Send an SMS to 14409 from the registered mobile number:
NIL R1 [GSTIN] [Return Period in MMYYYY]
Example: NIL R1 27AAAAA0000A1Z5 052026
Confirm with the verification code received in the reply:
CNF R1 [Code]
The portal sends an ARN confirming that the nil GSTR-1 is filed.
IFF is not a return: QRMP filers can upload B2B invoices for the first two months of a quarter using the Invoice Furnishing Facility (IFF), but IFF is optional. If a QRMP filer has no invoices in a month, nothing is uploaded and no nil IFF is needed. The nil GSTR-1 is filed for the quarter only if the whole quarter had nothing to report.
Nil CMP-08 for Composition Dealers
Composition taxpayers (aggregate turnover up to Rs 1.5 crore for goods and restaurant service suppliers, Rs 75 lakh in certain special category States; Rs 50 lakh for service providers opting under Section 10(2A)) do not file GSTR-1 or GSTR-3B. Instead, they file:
- CMP-08: a quarterly statement-cum-challan for self-assessed tax.
- GSTR-4: an annual return, due by 30 June following the financial year (from FY 2024-25, Notification 12/2024-Central Tax; earlier 30 April).
CMP-08 due date: 18th of the month after the quarter ends.
| Quarter | CMP-08 Due Date |
|---|---|
| Q1 (April to June) | 18 July |
| Q2 (July to September) | 18 October |
| Q3 (October to December) | 18 January |
| Q4 (January to March) | 18 April |
When a composition dealer has nothing to report in a quarter:
- Go to Services > Returns > Returns Dashboard, select the quarter and open CMP-08.
- Select the option to file a nil statement.
- File with EVC or DSC.
Filing Nil CMP-08 via SMS
A nil CMP-08 can also be filed by SMS to 14409:
NIL C8 [GSTIN] [Return Period in MMYYYY]
The return period is the last month of the quarter, for example 062026 for April to June 2026. Confirm with CNF C8 [Code]. SMS filing is available only if all earlier CMP-08 statements are filed and nothing is saved in the online CMP-08.
Composition dealers also owe one annual return on top of the quarterly CMP-08 statements; our GSTR-4 annual return filing guide for FY 2025-26 covers the 30 June 2026 due date, the table-wise format and a CMP-08 reconciliation checklist.
CMP-08 even with Rs 0 tax: some composition dealers have only exempt supplies in a quarter. Filing CMP-08 is still required. The GST portal's CMP-08 FAQ states that no late fee applies to a delayed CMP-08, but interest at 18% per year applies on any tax paid late, and a late GSTR-4 attracts a late fee (see below).
Late Fees for Missing Nil Returns
Section 47(1) of the CGST Act prescribes a late fee of Rs 100 per day (CGST), with an equal amount under SGST. For nil returns, the government has reduced this to Rs 10 per day under CGST plus Rs 10 under SGST, that is Rs 20 per day, with the caps below:
| Return | Late Fee per Day (Nil Return) | Maximum Late Fee (Nil Return) | Source |
|---|---|---|---|
| Nil GSTR-3B | Rs 20 (Rs 10 CGST + Rs 10 SGST) | Rs 500 per return (Rs 250 CGST + Rs 250 SGST) | Notification 19/2021-Central Tax |
| Nil GSTR-1 | Rs 20 (Rs 10 CGST + Rs 10 SGST) | Rs 500 per return (Rs 250 CGST + Rs 250 SGST) | Notification 20/2021-Central Tax |
| Nil GSTR-4 (annual) | Rs 20 (Rs 10 CGST + Rs 10 SGST) | Rs 500 per return (Rs 250 CGST + Rs 250 SGST) | Notification 21/2021-Central Tax |
| CMP-08 | No late fee (per GST portal FAQ) | Not applicable; interest applies on tax paid late | GST portal CMP-08 FAQ |
Why the Rs 20/day matters before hitting the cap: a nil return filed 25 or more days late costs Rs 500 (Rs 20 x 25). A return filed 10 days late costs Rs 200. Across 12 monthly GSTR-3B and 12 GSTR-1 returns a year, occasional delays add up.
The blocking effect: as explained above, Sections 37(4) and 39(10) stop you from filing a later return while an earlier one is pending. One missed nil return in April blocks May, which blocks June. By the time you catch up, you owe late fees for every missed period.
The three-year bar: under Sections 37(5), 39(11) and 44(2) of the CGST Act (inserted by the Finance Act 2023, effective 1 October 2023), a return cannot be filed after three years from its due date. GSTN began enforcing this on the portal from the July 2025 tax period. A nil return left unfiled for three years can no longer be filed at all.
What Happens if You Stop Filing Nil Returns
Under Section 29(2)(c) of the CGST Act, the proper officer can cancel the registration of a regular taxpayer who has not furnished returns for a continuous period. The Act originally fixed this at six months; the Finance Act 2022 (effective 1 October 2022) changed it to "such continuous tax period as may be prescribed". For composition taxpayers, Section 29(2)(b) applies where the annual return is not furnished for more than three months after its due date. Cancellation is not automatic: the officer first issues a show cause notice, but abandoned registrations are regularly cancelled this way.
If a business genuinely has no intention to make taxable supplies, the correct course is to apply for voluntary cancellation in Form GST REG-16 under Section 29(1) before missed returns trigger the officer's action.
Until the registration is cancelled, the return filing obligation continues.
Downstream Impact on Your Buyers
Your GSTR-1 is what puts your invoices into your buyers' GSTR-2B, and under Section 16(2)(aa) of the CGST Act they can claim ITC only on invoices that appear there. A nil GSTR-1 has no invoices, so it does not affect buyers directly. The problem comes when a nil month is left unfiled: because of the sequential filing rule, you cannot file GSTR-1 for the next month in which you did make sales until the pending nil return is filed. Until then, those invoices do not reach your buyers' GSTR-2B and they cannot claim the credit.
Consistent nil filing keeps your registration in good standing and keeps your buyers' ITC flowing.
Let Tax Garden Handle Your GST Filings
Whether you have zero transactions or high-volume monthly filings, Tax Garden manages your GSTR-1, GSTR-3B and annual GSTR-9, so each nil period is filed by its due date and each active period is reconciled against GSTR-2B before submission. See the scope of our GST filing services or talk to our team.
Frequently Asked Questions
Do I need to file GST returns if my business had no sales or purchases this month?
Yes. Every registered person must file GSTR-1 and GSTR-3B for each period, even with zero transactions, until the registration is cancelled. The filings are made as nil returns. Skipping them attracts late fees and blocks later filings, because Sections 37(4) and 39(10) of the CGST Act require returns to be filed in sequence.
What is the late fee for filing a nil GSTR-3B late?
For a nil GSTR-3B, the late fee is Rs 20 per day, made up of Rs 10 CGST and Rs 10 SGST, capped at Rs 500 per return (Notification 19/2021-Central Tax). For a return with tax liability, the fee is Rs 50 per day with a cap based on turnover. Interest at 18% per year does not apply to a nil return because there is no tax payable.
Can I file a nil GSTR-3B by SMS if I have only reverse charge purchases?
No. SMS filing to 14409 works only for a true nil return: no outward supplies, no reverse charge purchases, no ITC to claim and no tax liability. If you have any reverse charge liability, ITC to claim, outward supply or exempt supply to report, you must file GSTR-3B through the GST portal instead.
Is a composition dealer with no sales in a quarter still required to file CMP-08?
Yes. A composition taxpayer must file CMP-08 for every quarter by the 18th of the month after the quarter ends, even when no tax is payable, and a nil CMP-08 can be filed by SMS to 14409. The annual GSTR-4 is due by 30 June after the financial year (from FY 2024-25). GSTN's FAQ says no late fee applies to CMP-08, but interest applies on tax paid late, and GSTR-4 attracts a late fee.
How can I stop filing nil returns if my business has closed?
Apply for voluntary cancellation of registration in Form GST REG-16 on the GST portal. Until the cancellation is approved, the obligation to file returns continues. After cancellation, you must file a final return in GSTR-10 within three months of the date of cancellation or the date of the cancellation order, whichever is later.
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