Rule 85 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 85 of the Central Goods and Services Tax Rules, 2017 says how the electronic liability register is kept. It is maintained in FORM GST PMT-01 for each person liable to pay tax, interest, penalty, late fee or any other amount; every amount payable is debited to it, and payments, reliefs and reductions credit it.
This article follows the CGST Rules, 2017 as amended up to 31 October 2025 in the compilation consulted; notifications issued after that date should be checked.
The register is kept in FORM GST PMT-01 for each person liable to pay an amount, on the common portal. It is debited by amounts payable as per the return, amounts determined by a proper officer or ascertained by the person, and interest that accrues. It is credited when the liability is paid through the electronic credit ledger or electronic cash ledger, when relief is given by an appellate authority, Appellate Tribunal or court, and when a penalty stands reduced under sub-rule (6). A discrepancy is reported in FORM GST PMT-04.
The section behind the rule
Rule 85 gives effect to sub-section (7) of section 49 of the CGST Act, 2017, which provides for the electronic liability register: see section 49 to 53: payment and electronic ledgers and, for the ledgers and forms together, electronic ledgers under section 49 and the PMT forms. The register sits beside the electronic credit ledger (rule 86) and the electronic cash ledger (rule 87). If you want your liability, credit and cash positions checked together, our GST health check reviews all three.
Rule 85(1): the register and the debit
"The electronic liability register specified under sub-section (7) of section 49 shall be maintained in FORM GST PMT-01 for each person liable to pay tax, interest, penalty, late fee or any other amount on the common portal and all amounts payable by him shall be debited to the said register."
So the register is kept for each person liable to pay, not only for registered persons, and all amounts payable are debited to it.
Rule 85(2): what debits the register
The register "shall be debited by":
- Clause (a): the amount payable towards tax, interest, late fee or any other amount payable as per the return furnished by the person;
- Clause (b): the amount of tax, interest, penalty or any other amount payable as determined by a proper officer in pursuance of any proceedings under the Act, or as ascertained by the person;
- Clause (c): shown as omitted. The footnote records that it was omitted by Notification No. 19/2022-Central Tax dated 28.09.2022, with effect from 01.10.2022;
- Clause (d): any amount of interest that may accrue from time to time.
The words "said person" in clause (b) were substituted by the same notification, as the footnote records.
Rule 85(3): payment through the credit ledger or cash ledger
Subject to the provisions of section 49, section 49A and section 49B (the last two inserted by Notification No. 03/2019-Central Tax dated 29.01.2019 with effect from 01.02.2019, as the footnote records), payment of every liability by a registered person as per his return "shall be made by debiting the electronic credit ledger maintained as per rule 86 or the electronic cash ledger maintained as per rule 87 and the electronic liability register shall be credited accordingly". For the order in which credit is used, see section 49A and section 49B.
Rule 85(4): items payable only from the cash ledger
The amount deducted under section 51, the amount collected under section 52, the amount payable on reverse charge basis, the amount payable under section 10, and any amount payable towards interest, penalty, fee or any other amount under the Act, "shall be paid by debiting the electronic cash ledger maintained as per rule 87 and the electronic liability register shall be credited accordingly". Section 10 is the composition scheme: see section 10 of the CGST Act: composition scheme.
Rule 85(5) and (6): relief and reduced penalty
- Relief (sub-rule 5). Any amount of demand debited in the register "shall stand reduced to the extent of relief given by the appellate authority or Appellate Tribunal or court" and the register is credited accordingly.
- Penalty (sub-rule 6). The amount of penalty imposed or liable to be imposed "shall stand reduced partly or fully, as the case may be, if the taxable person makes the payment of tax, interest and penalty specified in the show cause notice or demand order" and the register is credited accordingly. The rule does not say which section allows the reduction or in what proportion; read the relevant section of the Act for that.
Rule 85(7): discrepancy
A registered person, "upon noticing any discrepancy in his electronic liability ledger", communicates it to the officer exercising jurisdiction in the matter, through the common portal in FORM GST PMT-04. The rule prints no period.
Two drafting slips to note
The rule is headed "Electronic Liability Register" and sub-rules (1) to (6) speak of the "electronic liability register", but sub-rule (5) says "electronic tax liability register" and sub-rule (7) says "electronic liability ledger". Read all three as referring to the electronic liability register of sub-rule (1).
What debits the register and what credits it
| Event | Effect on the register | Sub-rule |
|---|---|---|
| Amount payable as per the return | Debit | (2)(a) |
| Amount determined by a proper officer, or ascertained by the person | Debit | (2)(b) |
| Interest that accrues from time to time | Debit | (2)(d) |
| Liability discharged from the credit ledger or cash ledger | Credit | (3), (4) |
| Relief by appellate authority, Appellate Tribunal or court | Credit (demand reduced) | (5) |
| Penalty reduced on payment of tax, interest and penalty specified in the notice or order | Credit | (6) |
Who does what, by when
| Who | What | Form | When |
|---|---|---|---|
| The common portal | Maintains the register for each person liable to pay | FORM GST PMT-01 | Rule prints no period |
| Registered person | Pays liability as per return through the credit ledger or cash ledger | Not named | As per section 49 and the due date of the return |
| Registered person | Pays items in sub-rule (4) through the cash ledger | Not named | As the Act requires |
| Registered person | Reports a discrepancy to the officer exercising jurisdiction | FORM GST PMT-04 | On noticing it; no period printed |
A worked example
Orchid Components, an invented registered person, furnishes its return for a month showing tax of two lakh rupees (the amounts in this example are assumed). Under rule 85(2)(a) the electronic liability register in FORM GST PMT-01 is debited with that amount. Orchid pays one lakh forty thousand rupees from its electronic credit ledger and sixty thousand rupees from its electronic cash ledger; each payment credits the register under rule 85(3). Later the proper officer determines a further amount in proceedings under the Act. Under rule 85(2)(b) the register is debited with it. The appellate authority gives relief on part of that demand, and under rule 85(5) the demand stands reduced to that extent and the register is credited. If Orchid sees an entry it cannot reconcile, it communicates the discrepancy to the officer exercising jurisdiction in FORM GST PMT-04, as rule 85(7) says.
Points to watch
- Debits and credits. The register is debited when a liability arises and credited when it is discharged or reduced.
- Cash only items. Tax deducted under section 51, collected under section 52, payable on reverse charge, or payable under section 10, and interest, penalty and fee, go through the cash ledger under sub-rule (4).
- Interest accrual. Clause (d) debits interest "from time to time".
- PMT-04 is shared. Rules 85(7), 86(6) and 87(12) each name FORM GST PMT-04 for discrepancies in the register, credit ledger and cash ledger.
Need help reading your ledgers?
A register that does not match your records is easier to fix early. We review the three ledgers against your returns and tell you what to report in FORM GST PMT-04. See our GST health check.
Key takeaways
- The electronic liability register is kept in FORM GST PMT-01 for each person liable to pay.
- Returns, officer determinations, ascertained amounts and accruing interest debit it.
- Payment through the credit or cash ledger, relief on appeal and reduced penalty credit it.
- Section 51, section 52, reverse charge, section 10, interest, penalty and fee are paid from the cash ledger.
- Discrepancies go to the jurisdictional officer in FORM GST PMT-04.
Read next
- Rule 86 of the CGST Rules, 2017: the electronic credit ledger
- Rules 87 and 88 of the CGST Rules, 2017: electronic cash ledger and identification number
- Electronic ledgers under section 49 and the PMT forms
- Section 49 to 53: payment and electronic ledgers
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.