GST registration: Circular No. 257/03/2026-GST lists the documents and limits officer queries

CBIC has issued Circular No. 257/03/2026-GST dated 26 October 2026, under section 168(1) of the Central Goods and Services Tax Act, 2017 (CGST Act), with guidelines for applicants for GST registration in FORM GST REG-01. Officers already had guidelines of their own, in Instruction No. 03/2025-GST dated 17 April 2025. This circular is written for the applicant: what to furnish, which document proves which kind of premises, and when the officer may ask for more. It carries 51 FAQs (Annexure-I), a document checklist by constitution (Annexure-II), the list of premises documents (Annexure-III), and formats for an affidavit, an undertaking and a consent letter (Annexures IV to VI).

What the officer may ask for

Paragraph 5.4 confines a notice in FORM GST REG-03 to three situations, to be raised within seven working days of the application:

• a document is incomplete or not legible, and a complete or legible copy is sought;
• the address of the place of business does not match the uploaded document, or the document does not appear to be valid proof of that address;
• the address is incomplete or vague, and complete details with documentary proof are sought.

Where the system selects the application for physical verification, or the officer orders it with approval, the notice may be issued within thirty days instead (para 5.4.2).

Paragraph 5.4.1 names queries the Board has found being raised that should not be: the residential address of the applicant, Managing Director or authorised signatory being in a different city or State; a demand for the Udyam certificate; and objections that the activity declared cannot be carried on from the premises. Paragraph 6 goes further. The officer is to keep to the prescribed list of documents, raise a discrepancy only through FORM GST REG-03, and refrain from subjective assessments such as whether an electricity connection is domestic or commercial, the amount of a bill, or whether residential premises are fit for business. A utility bill or property tax receipt is checked only for the applicant’s name and address. A rent or lease agreement is checked mainly for validity, the names of both parties and the exact address.

The FAQs confirm this from the applicant’s side: a residential address elsewhere is not a bar (Q.30), and the Udyam certificate is neither required nor accepted as proof of the principal place of business, or PPoB (Q.36).

A REG-03 query on any of these excluded grounds can now be answered by citing paras 5.4.1 and 6.

One drafting slip needs watching. Para 5.4(ii) says the officer may seek additional documents “as per the list of documents in Annexure-IV”. Annexure-IV is the affidavit format for premises owned by a deceased ancestor; the list of premises documents is Annexure-III. The reference should be read as Annexure-III; until it is corrected, an officer could cite it to ask for the affidavit where it does not apply.

Proof of premises, by type

Owned. Premises count as owned only where they stand in the applicant’s own name. Property in the name of a parent, spouse, sibling, partner or director is not “own”, and the applicant should select “Consent”, “rented/leased” or “shared” instead (para 3.8.2.1). Proof is any one of: the latest property tax receipt, municipal khata, a document certifying property identification, or the latest electricity or water bill, in the applicant’s name and with the complete address (para 3.8.2.2). Where the property is jointly owned, the co-owner applying needs no consent or NoC from the others; if the bills stand in another co-owner’s name only, a document showing the ownership of both is to be uploaded (Q.37).

Owned by a deceased ancestor, with no document in the applicant’s name: the affidavit in Annexure-IV, the death certificate, and one of the documents above in the ancestor’s or the applicant’s name (para 3.8.2.3).

Rented or leased. Three cases are distinguished in para 3.8.3:

• a registered agreement, where it exists or local law requires registration: a copy of the registered agreement;
• an unregistered agreement: the agreement with one of the owner’s documents in the landlord’s name;
• no agreement at all: the undertaking in Annexure-V with a latest electricity or water bill in the tenant’s name.

A bill in the tenant’s own name, with a valid rent agreement, replaces the landlord’s proof.

Consent. Premises made available by a family member, partner or director need a consent letter on plain paper in the Annexure-VI format, signed by the owner, stating the relationship, with one of the owner’s documents. Where there are several co-owners, each must consent (para 3.8.4.1).

Co-working space. The membership agreement must show its period and the specific desk, cabin or suite allotted. If the provider owns the premises, one of its ownership documents is added; if the provider is itself a tenant, the registered lease between provider and owner is added (para 3.8.5).

Telecom towers and bank ATMs, being unmanned installations, need not be declared as a PPoB or additional place of business (para 3.9). A post office box is not acceptable (Q.32).

The address itself

The address must reach the specific shop, flat or premises: building or plot number, khasra or khata number where applicable, street, locality, town, district and PIN code. An address left at the level of a khasra number, road or colony invites a query or a negative physical verification report (para 3.7.2). The State and Centre jurisdictions should match the PIN code, which avoids the application being transferred (para 3.7.3). In Maharashtra, Rajasthan, Odisha, Andhra Pradesh, Assam and Madhya Pradesh the electricity board and consumer number for the PPoB are mandatory (para 3.10).

Photographs and signatories

DIN is mandatory for directors and designated partners (para 3.4.1). Photographs must be individual, recent, in colour and of the full face; a cropped image of a PAN, Aadhaar, driving licence or passport is not accepted, and a wrong photograph can lead to a query or a rejection (para 3.4.3). Each authorised signatory, up to ten, needs a photograph and an authorisation letter (paras 3.5.1 and 3.5.2).

Timelines

The circular restates rule 9 of the CGST Rules, 2017:

• with Aadhaar authentication opted for and completed, the application is to be processed within seven working days (para 5.1);
• without it, or where the system or the officer selects the case for physical verification, within thirty days, after verification under rule 25;
• a reply in FORM GST REG-04 is due within seven working days of the notice, and the officer is then to approve, or reject in FORM GST REG-05 with reasons recorded, within seven working days of the reply (para 5.5);
• where no action is taken within the rule 9 period, registration is deemed approved (para 5.7).

Registration under rule 14A, for those passing on ITC below ₹2.5 lakh a month, and system-granted registration under rule 9A are given within 3 working days (para 5.3). A person leaving rule 14A files FORM GST REG-32 with the REG-01 documents and goes through the normal process (para 6.1).

Two conditions that catch applicants out

A previous registration on the same PAN. Where an earlier registration was suspended under rule 21A(2) or (2A), or cancelled under rule 22, all due returns for it, including the final return in FORM GSTR-10, must be filed and no liability left pending before the new application (para 4).

Bank account. Not mandatory in the application, but under rule 10A it must be furnished within 30 days of grant or before the first GSTR-1 or IFF, whichever is earlier (para 3.11). The account must be in the applicant’s name and on its PAN.

Where the officer does not follow the circular

Para 8 allows a complaint about delay or unwarranted queries to the jurisdictional Chief Commissioner of Central Tax or Commissioner of State Tax, on a special e-mail address that each Zone or State is to identify. The circular does not give these addresses. It is addressed to CBIC’s Principal Chief Commissioners and Directors General, and does not itself say how State tax officers, who also process applications, will apply it. Until the trade notices asked for in para 9 issue, a copy of the circular attached to the REG-04 reply is the practical way to put the limits before the officer.

This article is intended for educational purposes only and should not be construed as professional advice. It is based on the law as understood on the date of publication; laws and regulations are subject to change, and it may not reflect later developments. Readers are advised to consult a qualified tax professional on their specific situation before taking any action based on it. CA. Mohit Gaba takes no responsibility for any action taken or decision made on the basis of this article.