Deemed Registration explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
"Deemed registration" is used for two different things. Section 26 of the CGST Act treats a State registration as a Central registration and the other way round. Separately, section 25(12) and Rule 9(5) treat an application as approved if the officer does nothing within the time allowed. Mixing the two causes most of the confusion.
Section 26 links the Acts: a grant of registration under the State or UT GST Act is deemed a grant under the CGST Act, unless the application is rejected under the CGST Act in the time in section 25(10), and a State rejection is deemed a Central rejection. Section 25(12) with Rule 9(5) is the silence rule: if the officer takes no action within 7 working days (30 days where physical verification applies) the application is deemed approved. The clock also runs for 7 working days after you reply to a query.
Meaning one: section 26, the Centre-State link
Section 26(1) says a grant of registration or Unique Identity Number under the State GST Act or UTGST 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 in section 25(10). Section 26(2) says any rejection under the State or UT Act is deemed a rejection under the CGST Act, despite section 25(10).
The Background Material explains the practical result. Registration is taken on the common portal and is based on PAN, so you do not apply separately under each Act. A registration under one law is treated as registration under the other.
It also says that a rejection under the CGST Act is treated as if the registration had not been obtained under the State or UT Act. And the proper officer cannot reject an application or a UIN without a show cause notice and a reasonable opportunity of being heard.
The same pattern appears for amendments and cancellation. Under section 28(3) an approval or rejection of an amendment under the State Act is deemed the same under the CGST Act, and under section 29(4) a State cancellation is deemed a cancellation under the CGST Act.
Meaning two: deemed approval when the officer is silent
Section 25(12) says a registration or UIN is deemed granted after the period in section 25(10) expires, if no deficiency has been communicated to the applicant in that period. Rule 9(5) gives the working dates. Our GST registration process is built around these clocks, so a pending application can be followed up at the right point.
| Stage | Time limit | Source |
|---|---|---|
| Approval where no physical verification | 7 working days from submission | Rule 9(1) |
| Approval where physical verification applies | 30 days from submission | Proviso to Rule 9(1) |
| Query notice in FORM GST REG-03 | 7 working days from submission (30 days where physical verification applies) | Rule 9(2) |
| Your reply in FORM GST REG-04 | 7 working days from receiving the notice | Rule 9(2) |
| Approval after your reply | 7 working days from receipt of reply | Rule 9(3) |
| Deemed approval if officer does nothing | At the end of those periods | Rule 9(5) |
| Certificate and GSTIN after deemed approval | Within 3 days after the period in Rule 9(5) expires | Rule 10(5) |
Physical verification applies where a person, other than one notified under section 25(6D), fails to undergo Aadhaar authentication or does not opt for it, where a person who authenticated is flagged on the portal based on data analysis and risk parameters, or where the proper officer, with approval of an officer not below Assistant Commissioner, decides to verify the place of business.
If the officer rejects your application, it must be by a reasoned order in FORM GST REG-05 after you fail to reply or the reply is unsatisfactory (Rule 9(4)).
Illustration: how the days run
Illustration: you submit the application on a Monday with Aadhaar authentication done and no verification flagged. The officer has 7 working days to approve or to send REG-03. Suppose REG-03 is issued on day 5. You reply in REG-04 within 7 working days. The officer then has 7 working days from your reply. If those pass with no action, the application is deemed approved and the certificate is to be made available within 3 days after that.
If instead the application is flagged for physical verification, the period is 30 days from submission, and REG-03 may be issued at any time within that 30 days.
Faster route: electronic grant
Rule 9A (inserted with effect from 1 November 2025) says any person who applied under Rule 8, 12 or 17 and is identified on the common portal by data analysis and risk parameters is granted registration electronically within 3 working days. Rule 14A, covered in the small-taxpayer registration option, also gives electronic grant within 3 working days.
When does the registration start?
Under Rule 10(2), if you applied within 30 days of becoming liable, registration is effective from the date you became liable. Under Rule 10(3), if you applied later, it is effective from the date of grant, including grant under Rule 9(5). See compulsory registration for when the 30 days begins.
The Background Material also records Instruction No. 03/2025-GST dated 17.04.2025, which asks field officers to process applications on a standard framework, with relevance to the documents sought and timely disposal.
Need help with a stuck registration?
If your application is sitting in query or verification, the reply is usually the deciding step. We can prepare the REG-04 response, line up documents and handle the Aadhaar or biometric step through our GST registration service. If you are also weighing a separate registration for a new entity, we can advise on that.
Key takeaways
- Section 26 treats State and Central registrations as linked, and a State rejection is a Central rejection.
- Deemed approval is a separate rule: section 25(12) read with Rule 9(5).
- Standard time is 7 working days; it is 30 days where physical verification applies.
- A reply to REG-03 must be filed in 7 working days, and the officer then has 7 working days.
- Late applications take effect from the date of grant, not the date of liability.
Read next
- Compulsory GST registration: who must register
- GST registration, Aadhaar authentication and biometric verification
- GST REG-02 and REG-03: acknowledgment and queries
- GST REG-06: registration certificate and GSTIN explained
Disclaimer: Positions stated as on 30 September 2026, based on the CGST and IGST Acts and Rules as amended, the Finance Act 2026, and the ICAI Background Material on GST (14th Edition, July 2026). Verify current notifications before acting.