Rule 9: Seven Days, Thirty Days, and Deemed Approval

Rule 9 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.

Registration is one of the few GST processes with a deeming provision in the applicant's favour. It is also one of the least used, because the timelines that trigger it are misread.

Rule 9(1): the proper officer approves within seven working days from the date of submission of a complete application. Where Aadhaar authentication was not done or not opted for, where the applicant is flagged by risk parameters for physical verification, or where the officer deems physical verification fit with the approval of an officer not below Assistant Commissioner, the period is thirty days, after physical verification under Rule 25. Rule 9(2): deficiencies are notified in FORM GST REG-03 within seven working days, and the applicant replies in FORM GST REG-04 within seven working days of receipt.

The two timelines

Seven working days — the ordinary case. Aadhaar authenticated, no risk flag, no physical verification.

Thirty days — where any of three conditions applies:

(a) the person fails to undergo Aadhaar authentication under Rule 8(4A), or does not opt for it;

(aa) the person has undergone Aadhaar authentication but is identified on the common portal, based on data analysis and risk parameters, for physical verification of the place of business;

(b) the proper officer, with the approval of an officer authorised by the Commissioner not below the rank of Assistant Commissioner, deems it fit to carry out physical verification.

In each of these, registration is granted within thirty days of submission, after physical verification of the place of business in the manner provided under Rule 25, and verification of such documents as the officer deems fit.

Note (b): the officer's own discretion

Clause (b) is worth reading carefully. It lets the proper officer require physical verification on his own view, provided he obtains the approval of an officer not below the rank of Assistant Commissioner.

Two implications:

The approval is a condition. Physical verification directed without that approval is procedurally defective.

No reasons are prescribed in clause (b). Unlike Rule 86A, the sub-rule does not require reasons to be recorded — though the requirement of a superior's approval supplies a comparable check.

The REG-03 loop

Rule 9(2): where the application is deficient in information or documents, or the officer requires clarification, he issues FORM GST REG-03 within seven working days of submission.

The applicant furnishes the clarification, information or documents in FORM GST REG-04 within seven working days of receipt of the notice.

Where physical verification is required — the same three conditions as above — the period for issuing REG-03 extends to thirty days.

Rule 9(3): where the officer is satisfied with the clarification, he grants registration within seven working days of receipt of REG-04.

Rule 9(4): where no reply is furnished, or the officer is not satisfied, he rejects the application and informs the applicant electronically in FORM GST REG-05, for reasons to be recorded in writing.

Deemed approval under Rule 9(5)

"If the proper officer fails to take any action — (a) within a period of seven working days from the date of submission of the application; or (b) within a period of seven working days from the date of the receipt of the clarification, information or documents furnished by the applicant under sub-rule (2); or (c) within a period of thirty days from the date of submission of the application, in cases where a person is identified under sub-rule (1) proviso, the application for grant of registration shall be deemed to have been approved."

Three separate trigger points. The one most often available in practice is (b) — the officer raised a REG-03, the applicant answered in REG-04, and nothing happened for seven working days.

Why it is under-used:

"Working days", not days. Saturdays, Sundays and gazetted holidays are excluded, which lengthens the window materially.

"Date of submission" is defined by Rule 8(4A) — the date of Aadhaar authentication or fifteen days from Part B, whichever is earlier — and where biometric authentication is required, the application is not complete until that is done. Biometric Aadhaar authentication →

Deemed approval must be pursued. The portal generally issues the GSTIN, but where it does not, the applicant has to raise a grievance citing Rule 9(5). Waiting quietly does not help.

Rule 25: what physical verification involves

Where physical verification is directed, the officer verifies the place of business in the presence of the person, and uploads a verification report along with photographs and other documents in FORM GST REG-30 on the common portal within fifteen working days following the date of such verification.

Points that decide outcomes:

• someone must be present at the premises, with the documents;
• the signage should display the trade name and, once registered, the GSTIN;
• the premises should match the address and the ownership or tenancy proof uploaded;
• the officer's report is uploaded, and a copy can be sought.

Practical notes

• Calendar the working-day count from the correct start date, and note it against the ARN.
• Answer REG-03 within seven working days. No extension is provided, and non-reply leads to rejection under Rule 9(4).
• Answer completely. A partial REG-04 invites rejection rather than a second query.
• Prepare the premises where physical verification is likely — an application without Aadhaar authentication will attract it.
• A rejection under REG-05 must record reasons. A bare rejection is appealable and, more practically, correctable by a fresh application addressing the stated reason.
• Deemed approval is a right, not an automatic outcome. Pursue it.

Key takeaways

• Seven working days ordinarily; thirty days where physical verification applies.
• Three triggers for the longer route: no Aadhaar authentication, risk-parameter flag, or the officer's view with Assistant Commissioner approval.
• REG-03 within seven working days; REG-04 within seven working days of receipt.
• Rule 9(5) deems approval on three separate failures to act.
• "Working days" excludes weekends and holidays.
• Rule 25 verification requires the person's presence and a REG-30 report within fifteen working days.

Read next

• Biometric Aadhaar Authentication: Rule 8(4A)
• GST REG-02 and REG-03: Acknowledgment and Queries
• GST Registration Process Step by Step
• Documents Required for GST Registration

Disclaimer: Positions stated as on 5 September 2026, based on the CGST Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition) and the ICAI Handbook on Registration under GST (November 2025).