# Aadhaar Authentication for GST Registration

Legal basis: Section 25(6A), (6B), (6C) & (6D) of CGST Act read with Rules 8, 9, 10B & 25.

## 1. How Aadhaar Authentication is Done

### A. For New Registrants

1. Option to authenticate Aadhaar at the time of registration.

2. A link is sent via mobile/email → applicant enters Aadhaar + OTP.

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

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

5. SCN raised within 30 days → applicant must reply within 7 working days.

6. If officer doesn't act on the reply within 7 working days → deemed approval.

### B. For Existing Registrants

Regular and composition taxpayers must authenticate via the Aadhaar link on the GST portal or upload E-KYC documents.

## 2. Persons Required to Undergo Aadhaar Authentication

### A. New Applicants (Rules 8, 9)

Individuals → must authenticate their own Aadhaar.
Non-individuals → Aadhaar authentication required for:
Karta / MD / Whole-time Director
Partners / Managing Committee Members / Trustees
Authorized Signatory
Date of submission of application = Earlier of:
Aadhaar authentication date, OR
15 days from REG-01 Part B submission.
Risk-based biometric authentication: High-risk cases require biometric authentication, photograph of specified persons, and verification of original documents at Facilitation Centres.
If Aadhaar authentication not opted → application requires photograph and document verification at Facilitation Centres.

### B. Already-Registered Persons (Rule 10B)

Mandatory for: Proprietor, Partner, Karta, MD/WTD, Managing Committee Member, Trustee, Authorized Signatory.

Mandatory for the following events:

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

## 3. Where Aadhaar Number is Not Assigned

### A. New Applicant

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

### B. Already-Registered Person (Rule 10B)

Must furnish:

1. Aadhaar Enrolment ID slip; AND

2. Any one of:

Bank passbook with photograph
Voter ID issued by Election Commission of India
Passport
Driving licence issued by Licensing Authority

Once Aadhaar is allotted → must undergo Aadhaar authentication within 30 days. Failure → registration becomes invalid.

## 4. Persons Exempt from Aadhaar Authentication

Non-citizens of India
Department/Establishment of State/Central Government
Local Authority
Statutory Body
Public Sector Undertaking
Person applying for Unique Identity Number under Sec 25(9)

Worked example

### Example 1

Example 1: Mr. A (individual) applies for GST registration on 1st April and opts for Aadhaar authentication. He successfully authenticates Aadhaar on 5th April.

Date of submission of application: Earlier of (a) Aadhaar authentication date = 5th April, or (b) 15 days from REG-01 Part B = 16th April.

→ Date of submission = 5th April.

→ Registration to be granted within 7 working days (no site visit unless SCN issued).

### Example 2

Example 2: XYZ LLP applies for GST registration on 10th May. Designated Partner does not opt for Aadhaar authentication.

→ Application requires photograph of designated partner + verification of original documents at Facilitation Centre.

→ Mandatory site visit before grant.

→ Registration shall be granted within 30 days, subject to verification.

### Example 3

Example 3: ABC Co. (existing registrant) wishes to file revocation of cancellation under Rule 23. The Karta has not undergone Aadhaar authentication.

→ Aadhaar authentication is mandatory for Karta before filing revocation application. Without it, the application cannot proceed.

⚠️ Common exam mistakes

Confusing the 7-working-day approval (Aadhaar success) with the 30-day approval (no Aadhaar/risk-flagged) timelines.
Forgetting that for non-individual entities, Aadhaar authentication of partners/Karta/Director/Trustees (not the entity itself) is required.
Computing 'date of submission' as the actual Part B submission date instead of using the 'earlier of' rule (Aadhaar auth date vs. 15 days from Part B).
Treating Aadhaar authentication as optional for existing registrants seeking revocation of cancellation, refund, or IGST refund on exports — it is mandatory.
Believing PSUs, government departments, and local authorities must undergo Aadhaar authentication — they are exempt.
Assuming an unassigned Aadhaar means automatic rejection — alternative ID documents (Voter ID, Passport, etc.) are permitted, but Aadhaar must be authenticated within 30 days of allotment.

Bare-Act text Section 25(6A), 25(6B), 25(6C), 25(6D) · CGST Act, 2017 · click to expand

Section 25(6A): Every registered person shall undergo authentication, or furnish proof of possession of Aadhaar number... failing which registration allotted shall be deemed to be invalid. Section 25(6B): On and from the date of notification, every individual shall undergo authentication of Aadhaar number for grant of registration. Section 25(6C): On and from the date of notification, every person other than individual shall undergo authentication of Aadhaar number of Karta/MD/WTD/such number of partners/Members of Managing Committee/Trustee/Authorised Signatory for grant of registration.

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