GST Notice REG-27: What It Is, Why You Got It, and How to Reply Before REG-28 Is Issued

When GST replaced VAT, Service Tax, Central Excise, and several other taxes on 1 July 2017, the government issued provisional registrations in Form GST REG-25 to over 65 lakh businesses already registered under the old tax regime, allowing them to continue operations while they completed their formal enrolment on the GST common portal. That enrolment process required businesses to furnish specific information and documents, converting their provisional GSTIN into a permanent one. Where a business’s provisional registration was deficient, incomplete, or potentially fraudulent, the Proper Officer sends a show cause notice in Form GST REG-27 asking the taxpayer to explain why the provisional registration should not be cancelled. A REG-27 notice gives you a fixed window to submit missing information and documents. Ignore it, and the officer issues Form REG-28, a formal cancellation of your provisional GST registration, after which you must apply for a fresh GSTIN if your business requires one. This guide explains every trigger for REG-27, the exact documents required by deficiency type, and the voluntary exit route through Form REG-29.

What Is Form GST REG-27 and Who Receives It?

Form GST REG-27 is a show cause notice issued by the Proper Officer under Rule 24 of the CGST Rules 2017, read with the transitional provisions of the CGST Act 2017, governing the enrolment of persons registered under the earlier tax laws. It is directed exclusively at businesses that hold a provisional GST registration (Form REG-25), meaning they migrated from the pre-GST regime but whose enrolment on the common portal was found to be deficient, incomplete, or non-genuine. REG-27 is not issued to businesses that obtained fresh GST registration directly under the CGST Act: those businesses face a different notice chain under Section 29(2) and Rule 22 (REG-17 through REG-23). The forms flow for provisional registrations is distinct.

The notice is delivered to your registered email address and appears on your GST portal account under Services > User Services > View Notices and Orders. The reply window runs from the date the notice is uploaded on the portal. If you have not logged into the portal recently and missed the notice, check immediately: the clock runs from the portal date, not from the date you first read the email.

What Are the Common Triggers for a REG-27 Enrolment Notice?

The Proper Officer issues REG-27 when the enrolment information or documents submitted with Form REG-26 (or omitted entirely) do not meet the requirements under Rule 24 and the GST registration rules. The trigger is always a specific deficiency identified by the officer during scrutiny of the provisional registration record. REG-27 notices invariably cite one or more of the following grounds.

1. Bank Account Details Not Furnished or Validated

Rule 10A of the CGST Rules 2017 requires every registered taxpayer to furnish valid bank account details within 45 days of registration or 30 days of commencement of business, whichever is earlier. Many businesses that migrated from the old tax regime did not complete this requirement on the GST portal. Where bank account details are missing, invalid (account closed or mismatched), or unverified through PFMS/NPCI validation, the officer identifies the provisional registration as non-compliant and issues REG-27 citing this deficiency.

2. Principal Place of Business Does Not Exist or Changed

The address registered under the old tax regime (VAT or Service Tax) may differ from the actual current business location, or the original premises may have been vacated. When a physical verification under Rule 25 (Form REG-30) reveals that the registered address is non-operational, unoccupied, or used for a different business entirely, REG-27 is issued asking the taxpayer to explain the discrepancy or update the address through an amendment application.

3. Identity or Ownership Documents Mismatch

For proprietorships, partnerships, or HUFs that migrated from State VAT, the PAN details, partner names, or business ownership may have changed between the old registration and the GST enrolment. Where the GST portal records show a mismatch between the PAN linked to the old registration and the PAN used for GST enrolment, or where a business was transferred but the registration name was not updated, REG-27 is issued to resolve the identity inconsistency.

4. Enrolment Application Left Incomplete

The GST migration was conducted in phases in 2017 and 2018, with multiple extension windows for businesses to complete their enrolment. Some businesses started the REG-26 application but did not submit it within the final deadline, leaving the application in a saved-but-not-submitted state. Others submitted REG-26 but without mandatory attachments (authorisation letter, photographs, PAN proof). Officers reviewing the registration database identify these incomplete enrolments and issue REG-27.

5. Business Appears Non-Genuine or Fraudulent

CBIC analytics and intelligence units periodically cross-match provisional GST registrations against income tax PAN data, customs import/export records, and bank KYC information. Where a provisional registration appears to have been obtained without genuine business activity, or where the original VAT/Service Tax registration itself was suspected to be fraudulent, REG-27 is issued as part of a targeted enforcement action. These cases typically involve higher stakes: the officer’s examination goes beyond document compliance to substantive questions about the genuineness of the business.

6. Multiple Registrations on the Same PAN Without Justification

GST allows multiple registrations for the same PAN where the business operates in multiple states or multiple distinct business verticals. However, duplicate or overlapping provisional registrations on the same PAN in the same state, migrated from the old regime without a valid basis, are flagged. REG-27 in these cases asks the taxpayer to justify the multiple registrations or to cancel the redundant ones via REG-29.

Why Are Businesses Still Receiving REG-27 Notices in 2026?

The GST migration formally concluded years ago, which raises the question of why REG-27 notices are still being issued in 2025-2026. The answer lies in three continuing CBIC activities that periodically resurface provisional registration cases long after the initial migration window closed.

Database Cleanup Drives

The GSTN database contains a segment of provisional registrations where the underlying enrolment was either never completed, was submitted with errors that were not corrected at the time, or was accepted provisionally pending additional verification that was deferred. The CBIC conducts periodic cleanup exercises to resolve these pending cases. Each such drive generates a fresh batch of REG-27 notices to businesses whose provisional registrations remain technically unresolved.

Cross-Verification with Income Tax and Bank Data

Under the data-sharing arrangements between the GSTN, CBDT, and the banking system, mismatches between GST registration data and PAN records or bank KYC data are automatically flagged. A business whose bank account is marked dormant or KYC-lapsed while an active GSTIN is mapped to that PAN triggers a mismatch alert. Similarly, a business that shows nil GST liability across all filed returns while showing significant income tax liability may be flagged for provisional registration review. REG-27 can follow such automated flag resolution.

Targeted Enforcement in High-Risk Sectors

Sectors with historically high rates of GST evasion, including scrap dealers, textile traders, works contractors, and certain agri-commodity traders, face periodic enforcement attention even for pre-existing provisional registrations. Where an earlier provisional registration in these sectors was found to be associated with a taxpayer who subsequently came under investigation for ITC fraud or fake invoicing, the provisional GSTIN itself is reviewed and REG-27 may be issued as part of the broader investigation.

How Do You Reply to a REG-27 Notice Step by Step?

A REG-27 reply does not have a separate named form like REG-18 or REG-24. You respond directly through the notice reply mechanism on the GST portal, within the time limit specified in the notice itself (most REG-27 notices allow 7 working days from the date of the notice, though the notice may specify a different period). The key principle is identical to all other GST notices: address every specific ground raised in the REG-27 with direct evidence, not general statements.

1. Log in and open the REG-27 notice. Go to gst.gov.in and navigate to Services > User Services > View Notices and Orders. Locate the REG-27 notice, download the PDF, and read it carefully. Note the exact deficiency cited, the reply deadline, and the officer’s contact details. Every word in the notice matters: officers who issue REG-27 are expected to state specific grounds, and a vague notice (one that does not specify the deficiency) can itself be challenged.
2. Identify the deficiency category and assemble documents. Match the deficiency in the notice to the document category in Section 5 below. Gather all required documents before drafting the reply. Do not draft and file a reply without attaching the evidence: a narrative without documents will not satisfy the officer and may trigger REG-28 even if your explanation is factually correct.
3. Complete any portal-level compliance action first. If the notice cites a missing bank account: add and validate the bank account on the portal before replying. If the notice cites an address mismatch: file an amendment application (Form GST REG-14) to update the address before replying and attach the amendment ARN in the reply. Resolving the deficiency at the portal level and then reporting the resolution in the reply is far stronger than promising to fix the issue after the notice.
4. Draft the reply point by point. Use the structure: (a) state the ground from the REG-27; (b) acknowledge or dispute the ground as applicable; (c) state the remedial action taken with date and reference number; (d) cite the attached annexure number. Keep the language factual and direct. Avoid defensive or argumentative language: officers respond better to a clear factual rebuttal with evidence than to assertions of hardship or good intent.
5. Request a personal hearing. Add an explicit sentence: “The Applicant respectfully requests a personal hearing before any adverse order is passed in this matter.” This invokes the natural justice protection under Section 75(4) of the CGST Act, which requires the officer to grant a hearing on request before an adverse order.
6. Upload supporting documents and submit. Attach all documents as clearly labelled PDF exhibits. Submit the reply through the portal’s reply mechanism for the specific REG-27 notice. Download and save the acknowledgement with timestamp. Monitor the portal status daily for the officer’s REG-20 (dropped) or REG-28 (cancellation) response.

What Documents Should You Include With Your Reply?

The documents required depend entirely on the specific deficiency cited in your REG-27. Submitting documents that address the wrong deficiency, or submitting incomplete documents for the correct deficiency, results in REG-28. The table below maps each common deficiency type to the exact documents that officers consistently accept as adequate rebuttal.

What Happens After Your Reply: Cancellation Dropped or REG-28 Issued?

After you file your reply to REG-27, the Proper Officer reviews the response and supporting documents. Two outcomes are possible, and there is no statutory intermediate step (such as the REG-23 mechanism in the revocation process) between the REG-27 reply and the final order.

Outcome 1: Proceedings Dropped (Form REG-20)

If the officer is satisfied with your reply and finds that the deficiency has been adequately addressed, they issue Form REG-20, an order dropping the cancellation proceedings. Your provisional registration continues without interruption and your GSTIN remains active. The status on the portal reverts to normal. In practice, REG-20 in the REG-27 context is issued promptly for straightforward cases, particularly where the deficiency was purely documentary (missing bank account, outdated address) and the taxpayer has corrected the issue through a portal update or amendment application.

Outcome 2: Provisional Registration Cancelled (Form REG-28)

If the officer is not satisfied with the reply, or if no reply was filed within the specified period, the officer issues Form REG-28, the order of cancellation of the provisional registration. The effective date of cancellation is specified in REG-28 and may be retroactive. Once REG-28 is issued, your GSTIN becomes inactive. Your buyers cannot claim ITC on invoices you issue after the effective date of cancellation, and you cannot file regular returns or claim ITC on purchases.

After REG-28: Your Options

Unlike the REG-17/REG-19 cancellation process, there is no statutory revocation mechanism specifically designed for REG-28 provisional registration cancellations. The REG-21/REG-22/REG-23 revocation chain under Section 30 is limited to cancellations under Section 29(2), which covers regular registered taxpayers, not provisional registrations under the transitional provisions. After a REG-28 order, your options are:

• Appeal under Section 107: A REG-28 cancellation order is an appealable order. File a first appeal before the Appellate Authority within 3 months of the REG-28 order, with a 10% pre-deposit of disputed tax, citing errors in the officer’s findings or procedural defects in the REG-27 process.
• Writ petition: Where the REG-27 notice was vague, the personal hearing was denied, or the REG-28 order did not state adequate reasons, a writ petition under Article 226 before the jurisdictional High Court is a viable and often faster remedy.
• Fresh registration: If your business continues to operate and requires GST registration, apply for a new GSTIN under Section 22 or 24 of the CGST Act using Form REG-01. A fresh registration creates a new GSTIN and is not affected by the cancelled provisional GSTIN, provided you have cleared any outstanding liabilities under the old GSTIN.

Should You Voluntarily Cancel Your Provisional Registration via Form REG-29?

If your business is closed, has fallen below the GST registration threshold, or no longer requires a GST registration under any provision, you can avoid the REG-27 process entirely by filing a voluntary cancellation application in Form GST REG-29. REG-29 is the cleanest and fastest way to close out a provisional registration that is no longer needed, and it prevents the automatic generation of REG-27 notices from the CBIC’s database cleanup drives.

When REG-29 Is the Right Choice

• Business permanently closed: If the business that held the old VAT/Service Tax registration has ceased operations and has no outstanding liabilities, REG-29 closes the GSTIN cleanly without the need for return filing under the cancelled GSTIN going forward.
• Turnover below threshold: If the business’s aggregate annual turnover has fallen below Rs. 20 lakh (Rs. 10 lakh for specified special category states) and GST registration is not required voluntarily, REG-29 removes the compliance burden of return filing.
• Succession or restructuring: If the business has been sold, transferred to a company or LLP, or merged with another entity that holds its own GSTIN, the original provisional GSTIN of the predecessor entity can be cancelled via REG-29. For businesses evaluating whether a corporate structure improves compliance positioning after such transitions, our Pvt Ltd company registration guide covers the relevant trade-offs.
• Duplicate GSTIN: If the REG-27 itself cites a duplicate GSTIN on the same PAN, filing REG-29 for the unwanted GSTIN is both the simplest resolution and the correct reply to submit with the REG-27 notice.

What REG-29 Does Not Cover

REG-29 is specifically for voluntary cancellation of provisional registrations (REG-25 category). For businesses that obtained a fresh GST registration directly under the CGST Act after 1 July 2017, the voluntary cancellation mechanism is Form GST REG-16, not REG-29. Using the wrong form will result in a portal error. If you are unsure which category your GSTIN belongs to, check the registration certificate: a provisional certificate was issued in Form REG-25 and your GSTIN would have been assigned during the 2017-18 migration period under your pre-existing state or central tax registration number.

For businesses navigating the broader GST notice landscape, our series covers the notice chain from the beginning: GSTR-3A notices for return non-filers, REG-3 notices during new registration scrutiny, and REG-23 notices before rejection of revocation applications.

Frequently Asked Questions on GST REG-27 Notice