Rules 16 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.
Rule 16 allows the proper officer to register, on a temporary basis, a person who is liable to registration but has not applied, by an order in FORM GST REG-12. Rule 16A, inserted with a date yet to be notified, provides a temporary identification number for a person who is not liable to registration but must make a payment. Rule 18 requires the certificate of registration and the GSTIN to be displayed at every place of business.
This article follows the Central Goods and Services Tax Rules, 2017 as amended up to 31 October 2025 in the compilation consulted; notifications issued after that date should be checked.
Where an enquiry, survey, inspection, search or other proceeding shows that a person liable to registration has failed to apply, the proper officer may register him on a temporary basis in FORM GST REG-12. The person must then apply for regular registration within ninety days of the grant. Rule 18 requires the certificate of registration to be displayed in a prominent location and the GSTIN on the name board at the principal and every additional place of business.
The section behind the rules
Rule 16 is the procedural side of the officer's power to register a person who is liable but has not applied. Registration itself is dealt with in section 25 of the CGST Act (see section 25 of the CGST Act, 2017), and who must register in section 24 (see compulsory registration under section 24). If a notice, survey or search has raised the question of registration for your business, our GST registration service can handle the application and the follow-up.
Rule 16: suo moto registration
Sub-rule (1): the power. "Where, pursuant to any survey, enquiry, inspection, search or any other proceedings under the Act, the proper officer finds that a person liable to registration under the Act has failed to apply for such registration, such officer may register the said person on a temporary basis and issue an order in FORM GST REG-12."
Three conditions: there must be a proceeding (survey, enquiry, inspection, search or any other proceeding); the proper officer must find that the person is liable to registration; and the person must have failed to apply. The word is "may".
Sub-rule (2): effective date. "The registration granted under sub-rule (1) shall be effective from the date of such order granting registration."
Sub-rule (3): the ninety days. Every person to whom a temporary registration has been granted under sub-rule (1) "shall, within a period of ninety days from the date of the grant of such registration, submit an application for registration in the form and manner provided in rule 8 or rule 12". The route is rule 8 (see rule 8) for an ordinary applicant, or rule 12 (see rule 12) for a person required to deduct or collect tax at source.
Proviso to sub-rule (3). If the person "has filed an appeal against the grant of temporary registration, in such case, the application for registration shall be submitted within a period of thirty days from the date of the issuance of the order upholding the liability to registration by the Appellate Authority."
Sub-rule (4): rules 9 and 10. "The provisions of rule 9 and rule 10 relating to verification and the issue of the certificate of registration shall, mutatis mutandis, apply to an application submitted under sub-rule (3)." See rules 9A and 10.
Sub-rule (5): the GSTIN. The Goods and Services Tax Identification Number assigned after the verification under sub-rule (4) "shall be effective from the date of the order granting registration under sub-rule (1)". The effective date therefore goes back to the date of the temporary order, not to the date of the later grant.
Rule 16A: temporary identification number
The rule reads: "Where a person is not liable to registration under the Act but is required to make any payment under the provisions of the Act, the proper officer may grant the said person a temporary identification number and issue an order in Part B of FORM GST REG-12."
The footnote says rule 16A was inserted by Notification No. 07/2025 - CT dated 23.01.2025, "w.e.f. a date yet to be notified". Because that footnote says the date is yet to be notified, no date is given here, and this article does not say whether the rule is or is not in force. Check the position before relying on it.
Note the contrast with rule 16: rule 16 is for a person who is liable to registration; rule 16A is for a person who is not liable to registration under the Act. Part B of FORM GST REG-12 is named by the rule; the rule describes no field of it.
Rule 18: display
Sub-rule (1). "Every registered person shall display his certificate of registration in a prominent location at his principal place of business and at every additional place or places of business."
Sub-rule (2). "Every registered person shall display his Goods and Services Tax Identification Number on the name board exhibited at the entry of his principal place of business and at every additional place or places of business."
Rule 17, which sits between 16A and 18, deals with the Unique Identity Number: see unique identity number under rule 17.
Who does what, by when
| Who | What | Form | Period | Rule |
|---|---|---|---|---|
| Proper officer | May register a person liable but not applied, on a temporary basis | FORM GST REG-12 | After a survey, enquiry, inspection, search or other proceeding | 16(1) |
| Person registered temporarily | Applies for registration under rule 8 or rule 12 | As in rule 8 or 12 | Within ninety days from the date of the grant | 16(3) |
| Same person, if appeal filed | Applies for registration | As in rule 8 or 12 | Within thirty days from the order upholding liability by the Appellate Authority | 16(3) proviso |
| Proper officer | Verification and certificate as in rules 9 and 10 | FORM GST REG-06 per rule 10 | As in rules 9 and 10 | 16(4) |
| Proper officer | May grant a temporary identification number to a person not liable but required to pay | Part B of FORM GST REG-12 | Rule inserted with a date yet to be notified | 16A |
| Every registered person | Displays the certificate of registration | Not applicable | Continuing | 18(1) |
| Every registered person | Displays the GSTIN on the name board | Not applicable | Continuing | 18(2) |
A worked example
Brightway Packaging Works, an invented partnership, supplies goods but has never applied for registration. During an inspection, the proper officer finds that the firm is liable to registration under the Act and has failed to apply. On 5 March he registers it on a temporary basis and issues an order in FORM GST REG-12. The registration is effective from 5 March (rule 16(2)).
The firm must submit an application under rule 8 within ninety days from the date of the grant. Suppose it files an appeal against the grant; the Appellate Authority upholds the liability on 20 July. Under the proviso the application must then be submitted within thirty days from the issuance of that order. Once the application is verified and the certificate issued under rules 9 and 10, the GSTIN assigned is effective from 5 March, the date of the order (rule 16(5)). From then on the firm must display the certificate at each place of business and the GSTIN on the name board at the entry of each place (rule 18).
Points to watch
- Temporary does not mean optional. Sub-rule (3) obliges the person to apply within ninety days.
- The appeal proviso changes the clock. Thirty days from the Appellate Authority's order, not ninety from the grant.
- GSTIN effective date. It goes back to the date of the order under rule 16(1).
- Rule 16A. The footnote gives no date; check the position before assuming it applies.
- Display is for every place. Principal and every additional place of business, both for the certificate and for the GSTIN.
- Next step if registration is cancelled. See rules 20 and 21.
Need help after a survey or inspection?
A temporary registration order starts a ninety-day clock, and a missed application is the start of a larger problem. We review the order, prepare the application under rule 8 or rule 12 and plan the follow-up. See our GST registration service.
Key takeaways
- Rule 16(1): the proper officer may register a liable person who has failed to apply, on a temporary basis, by an order in FORM GST REG-12.
- Rule 16(3): apply for registration within ninety days of the grant, or within thirty days of the Appellate Authority's order if an appeal was filed.
- Rule 16(5): the GSTIN is effective from the date of the order under sub-rule (1).
- Rule 16A: a temporary identification number for a person not liable but required to pay; inserted "w.e.f. a date yet to be notified".
- Rule 18: display the certificate in a prominent location and the GSTIN on the name board at the principal and every additional place of business.
Read next
- Rules 13 to 15 of the CGST Rules, 2017: non-resident, OIDAR and extension
- Rules 20 and 21 of the CGST Rules, 2017: application for cancellation and cases of cancellation
- Unique identity number under rule 17
- Rule 8 of the CGST Rules, 2017: application for registration
Disclaimer: Based on the Central Goods and Services Tax Rules, 2017 and the GST Acts as amended up to 31 October 2025 in the compilation consulted, read with the Finance Act, 2026 where this article says so, as consulted on 2 October 2026. Notifications, circulars and amendments issued after that date, the forms on the common portal and the way the tax authorities apply these provisions should be checked. This article is general information, not legal advice; check the official text before acting.