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Microlesson · 5-min read

Aadhaar Authentication [Sec 25(6A)-(6D) & Rules 8, 9, 10B, 25]

## Aadhaar Authentication for Registration

### How Aadhaar Authentication Works

For new registrants:

1. Option to authenticate Aadhaar at registration stage.

2. Authentication link sent via mobile/email → enter Aadhaar + OTP.

3. If successful → approval within 7 working days (no site visit unless SCN issued).

4. If not opted / failed → mandatory site visit; approval after 30 days if no action by officer.

5. If SCN raised within 30 days → applicant replies within 7 working days; if officer doesn't act on reply within 7 working days → deemed approved.

For existing registrants: Regular and composition taxpayers must authenticate via Aadhaar link on GST portal OR upload e-KYC documents.

### Persons Required to Undergo Aadhaar Authentication

1. New Applicants (Rules 8 & 9):

  • Individuals: authenticate own Aadhaar.
  • Non-individuals: Aadhaar authentication of Karta / MD / Whole-time Director / Partners / Managing Committee Members / Trustees / Authorised Signatory.

Date of submission of application = earlier of:

  • Aadhaar authentication date, OR
  • 15 days from REG-01 Part B submission.

Risk-based biometric authentication: Biometric authentication may be required for high-risk cases, along with photograph and verification of original documents at Facilitation Centres.

If Aadhaar authentication not opted: photograph (of individual / specified person) + document verification at Facilitation Centre.

2. Persons Already Registered (Rule 10B):

Aadhaar authentication required for: Proprietor, Partner, Karta, MD/WTD, Managing Committee Member, Trustee, Authorised Signatory.

Mandatory for:

  • Revocation of cancellation (Rule 23)
  • Refund claims (Form RFD-01, Rule 89)
  • IGST refund on exports (Rule 96)

### Where Aadhaar Number is Not Assigned

New applicant:

  • Alternative identification method under Rule 9.
  • May face physical verification of premises/documents.
  • Registration granted within 30 days, subject to verification.

Already registered person (Rule 10B): Must furnish:

  • (a) Aadhaar Enrolment ID slip; AND
  • (b) Any one of: Bank passbook with photograph OR Voter ID OR Passport OR Driving Licence.

Once Aadhaar is allotted → must authenticate within 30 days. Failure → registration invalid.

### Exempt from Aadhaar Authentication

  • Person who is not a citizen of India
  • Department / establishment of State or Central Government
  • Local authority
  • Statutory body
  • Public Sector Undertaking (PSU)
  • Person applying for UIN u/s 25(9)

Worked example

### Example 1

Example: Partnership firm files REG-01 Part B on 1st June. One partner authenticates Aadhaar on 8th June, another on 20th June. Date of submission = earlier of 20th June (last authentication) or 16th June (15 days from Part B) → 16th June.

### Example 2

Example: Mr. K (already registered) seeks revocation of cancellation. Aadhaar authentication is mandatory before filing the revocation application under Rule 23.

### Example 3

Example (PSU): BHEL applies for registration. As a PSU, BHEL is exempt from Aadhaar authentication requirement.

⚠️ Common exam mistakes

  • Computing 'date of submission' purely from REG-01 Part B date — must take the earlier of Aadhaar authentication date and (Part B date + 15 days).
  • Forgetting that revocation of cancellation, refunds, and export IGST refunds REQUIRE Aadhaar authentication for existing registrants.
  • Treating non-citizens as needing Aadhaar — they are exempt.
  • Confusing alternate identification (Aadhaar Enrolment ID slip + one prescribed document) — both are required, not either/or.
  • Missing that once Aadhaar is later allotted to such person, they have only 30 days to authenticate, failing which registration becomes invalid.
Bare-Act text Section 25(6A), (6B), (6C) & (6D) of CGST Act, 2017 read with Rules 8, 9, 10B & 25 of CGST Rules, 2017 · CGST Act, 2017 / CGST Rules, 2017 · click to expand
Section 25(6A): Every registered person shall undergo authentication, or furnish proof of possession of Aadhaar number, in such form and manner and within such time as may be prescribed. Provided that if an Aadhaar number is not assigned to the registered person, such person shall be offered alternate means of identification in such manner as may be prescribed.
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