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Direct and Indirect Taxation · Registration

Deemed Registration under Section 26 of the CGST Act

Updated 10 October 2026 · Fact-checked

Deemed registration means registration is treated as granted without a formal order. Under Section 26, registration granted under the State or UT GST Act counts as granted under the CGST Act unless rejected in time. Under Rule 9(5), registration is deemed approved if the officer takes no action within the stated time.

Understand Deemed Registration

Normally, a registration application under GST is examined by the proper officer, who approves or rejects it. Deemed registration covers cases where the law treats registration as granted even though no separate order is passed.

There are two ideas to keep apart. The first is Section 26, which links the CGST Act with the State GST and UT GST Acts. The second is Rule 9(5) of the CGST Rules, 2017, which says an application is deemed approved if the officer stays silent past the time limit. Students often mix these up, so keep them separate.

Under Section 26(1), the grant of registration or Unique Identity Number under the State GST or UT GST Act is deemed to be a grant under the CGST Act. The condition is that the application has not been rejected under the CGST Act within the time specified in section 25(10). Under Section 26(2), a rejection under the State or UT Act is deemed a rejection under the CGST Act. This works only for rejection of the application for registration.

Under Rule 9(5), the officer must act within a fixed time. If there is no action, the application is deemed approved. A separate migration rule, Rule 24(3A), gives deemed grant for persons who migrated from the earlier law and furnished their particulars, if no certificate or notice comes within fifteen days.

Key rules to remember

Section 26(1): deemed grant
Registration under State/UT GST Act = deemed registration under CGST Act, unless the application is rejected under CGST within the time in section 25(10)
Applies to registration and to Unique Identity Number. The condition about rejection must be stated.
Section 26(2): deemed rejection
Rejection under State/UT GST Act = deemed rejection under CGST Act
Operates despite section 25(10).
Rule 9(5)(a): normal cases
No action within 7 working days from date of submission = application deemed approved
For persons not covered by the proviso to Rule 9(1).
Rule 9(5)(b): physical verification cases
No action within 30 days from date of submission = application deemed approved
For persons covered by the proviso to Rule 9(1): no Aadhaar authentication or not opted for it, risk-flagged on the portal, or officer decides to verify the place of business.
Rule 9(5)(c): after reply
No action within 7 working days from receipt of clarification, information or documents under Rule 9(2) = deemed approved
The clock restarts from receipt of your reply in FORM GST REG-04.
Rule 9(2): notice and reply
Notice in FORM GST REG-03 within 7 working days (30 days in proviso cases); reply in FORM GST REG-04 within 7 working days of receipt of notice
Rejection, if any, is in FORM GST REG-05 under Rule 9(4).
Rule 24(3A): migrated persons
No certificate and no show cause notice within 15 days from furnishing information = registration deemed granted
Applies after the particulars are furnished in FORM GST REG-26 and are in order or not challenged.

How to solve Deemed Registration questions

Use this method for any question on deemed registration. First identify which provision the facts point to, then count the days.

  1. 1Read the facts and decide the situation: registration under State/UT Act (Section 26), a fresh application with officer silence (Rule 9(5)), or a migrated person (Rule 24).
  2. 2For Section 26, check whether the State or UT authority granted or rejected the application. Grant means deemed grant under CGST, subject to no rejection under CGST within the section 25(10) time. Rejection means deemed rejection under CGST.
  3. 3For Rule 9(5), check whether the proviso to Rule 9(1) applies: Aadhaar authentication failed or not opted for, risk-flagged on the portal, or physical verification ordered.
  4. 4Pick the time limit: 7 working days for ordinary cases, 30 days for proviso cases.
  5. 5Check whether a notice in FORM GST REG-03 was issued. If yes, the clock under Rule 9(5)(c) runs for 7 working days from receipt of your reply in FORM GST REG-04.
  6. 6Check whether the officer approved or rejected within the time. If neither happened, state that the application is deemed approved.
  7. 7Write the conclusion with the rule reference and the form names.

Quickest way: Count the days, then name the rule

When to use it: Use this for short numerical or MCQ questions that give dates and ask whether registration is deemed granted.

  1. Decide: normal case (7 working days) or proviso case (30 days).
  2. If a notice was issued, restart the count at 7 working days from receipt of the reply.
  3. If the officer did nothing in that window, answer deemed approved under Rule 9(5).
  4. If the question says the State authority granted or rejected, answer by Section 26(1) or 26(2).
  5. For migrated persons, use the 15-day rule in Rule 24(3A).

Common mistakes in Deemed Registration

  • Saying Section 26 is the provision for officer silence.

    The name 'deemed registration' is linked to Section 26 and the silence rule sits in a rule.

    Fix: Section 26 covers State/UT registration being treated as CGST registration. Officer silence is Rule 9(5).

  • Applying 7 days to every application.

    Students remember the headline seven-day figure and ignore the proviso.

    Fix: Check for no Aadhaar authentication, a risk flag, or physical verification. Then the limit is 30 days.

  • Counting 7 calendar days instead of working days.

    The word 'working' is skipped while reading.

    Fix: Rule 9(1), 9(2), 9(3) and 9(5) use working days for the 7-day periods. The 30-day period is plain days.

  • Counting the post-reply period from the original application date.

    Students forget that a notice resets the clock.

    Fix: Under Rule 9(5)(c) the 7 working days run from receipt of the clarification, information or documents.

  • Saying a rejection by the State officer has no effect on CGST registration.

    Students read only Section 26(1), which is about grant.

    Fix: Section 26(2) deems a State or UT rejection to be a rejection under CGST.

  • Confusing the 15-day migration rule with the 7-day rule.

    Both are deemed-grant provisions with different triggers.

    Fix: Rule 24(3A) is only for persons who migrated from earlier law and furnished particulars. It runs 15 days from furnishing the information.

Worked examples

Example 1

Meera Textiles of Surat applied for GST registration on 3 March. She completed Aadhaar authentication, was not flagged for physical verification, and the proper officer neither issued a notice nor approved the application. Is she deemed registered, and from when can she claim it?

Show the solution
  1. Meera completed Aadhaar authentication and was not flagged, so the proviso to Rule 9(1) does not apply.
  2. The time limit is therefore 7 working days from submission under Rule 9(5)(a).
  3. The officer took no action within 7 working days, neither approving nor issuing a notice in FORM GST REG-03.
  4. So the application is deemed approved under Rule 9(5).

Answer: Yes. Once 7 working days from 3 March pass without action, Meera's application is deemed approved under Rule 9(5)(a).

Example 2

Arjun Traders in Pune did not opt for Aadhaar authentication and applied on 1 June. The officer issued a notice in FORM GST REG-03 on 12 June. Arjun replied in FORM GST REG-04 on 15 June, which the officer received that day. The officer took no action afterwards. When is the application deemed approved, and was the notice in time?

Show the solution
  1. Arjun did not opt for Aadhaar authentication, so the proviso to Rule 9(1) applies.
  2. For such cases the notice in FORM GST REG-03 may be issued up to 30 days from submission. 12 June is within 30 days of 1 June, so the notice was in time.
  3. Arjun replied in FORM GST REG-04 on 15 June, within 7 working days of receiving the notice, so the reply was in time.
  4. Under Rule 9(5)(c), the officer has 7 working days from receipt of the reply, which is 15 June.
  5. If no action is taken in those 7 working days, the application is deemed approved.

Answer: The notice was in time. If the officer does nothing within 7 working days of 15 June, the application is deemed approved under Rule 9(5)(c).

Exam tips

  • Write the provision in your first line: Section 26 for State/UT registration, Rule 9(5) for officer silence, Rule 24(3A) for migrated persons.
  • In MCQs, check whether the number is 7 working days, 30 days or 15 days, and match it to the trigger.
  • In numerical problems, list the dates in a small timeline before concluding.
  • Quote the forms by name: GST REG-03 for the notice, REG-04 for the reply, REG-05 for rejection.
  • Do not mention section numbers beyond those you are sure of. Section 25(10) is the time reference in Section 26(1).

Practice questions from Registration

Deemed Registration in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

Deemed Registration: frequently asked questions

What is deemed registration under Section 26 of the CGST Act?

Section 26(1) treats registration or a Unique Identity Number granted under the State or UT GST Act as granted under the CGST Act too. This holds if the application is not rejected under CGST within the section 25(10) time. Section 26(2) treats a State or UT rejection as a CGST rejection.

Is GST registration deemed approved if the officer does not respond in 7 days?

Yes, in ordinary cases. Under Rule 9(5)(a), failure to act within 7 working days of submission means the application is deemed approved. In proviso cases the period is 30 days.

When does the 30-day period apply instead of 7 working days?

It applies when the proviso to Rule 9(1) is triggered. That means Aadhaar authentication was not done or not opted for, the portal flagged the applicant on risk parameters, or the officer decided to verify the place of business.

What happens if I reply to a notice in FORM GST REG-03?

You file FORM GST REG-04 within 7 working days of receiving the notice. The officer then has 7 working days from receipt of your reply to act. If the officer does not act, the application is deemed approved.