Suo Moto Registration Under GST — Guide (2026)
An unregistered business making taxable supplies gets caught in an enforcement survey. The GST officer doesn't wait for them to apply. They register them on the spot. That's suo moto registration — and it has teeth.
If you're running a business, advising clients, or studying GST compliance, this is one process you need to understand clearly. Especially now, after the significant changes brought in through Notification No. 07/2025.
"Suo moto" is Latin — it means on its own motion. Under GST, when a tax officer discovers that a person is making taxable supplies without having obtained GST registration, they can register that person directly, without waiting for any application from them. No request needed. The officer acts on their own authority.
This power sits in Section 25 of the CGST Act, 2017, read with Rule 16 of the CGST Rules, 2017.
It's an enforcement tool, not a voluntary option.
CBIC, through Notification No. 07/2025 – Central Tax dated 23 January 2025, amended the CGST Rules in three meaningful ways. If you're working in GST compliance, these changes matter.
This is the most significant addition. Rule 16A covers a specific situation: a person who is not liable to register under GST but still needs to make a payment under the Act. For such persons, the Proper Officer can now issue a Temporary Identification Number (TIN) — through Part B of Form GST REG-12.
Before this rule existed, there was no clean mechanism for such payments. That gap has now been addressed.
The form has been updated to cover both temporary registrations and TIN issuance under a single document. It now also captures PAN, Aadhaar, and bank details — which weren't part of the earlier version.
Rule 87(4) has been linked directly to Rule 16A. What this means in practice: TIN holders can now log in to the GST portal, generate a challan, and make their payment online. That's a cleaner process than before.
Two conditions must be satisfied simultaneously — not one, both.
First, the Competent Officer must have conducted a survey, search, inquiry, inspection, or any other proceeding under the CGST Act.
Second, during that proceeding, the officer must determine that the unregistered person is liable to be registered under GST — and has not applied.
Both boxes need to be checked. Only then does the Proper Officer issue a Temporary Registration or TIN through Form GST REG-12. This isn't something that happens randomly — it's triggered by an active enforcement action.
A tax officer conducts a survey, inspection, search, or inquiry. If an unregistered person is found making taxable supplies, the suo moto registration process begins from that moment.
The Proper Officer grants a Temporary Registration Number (TRN) through Form GST REG-12. This registration is effective from the date of the order and carries a Reference Number for tracking and compliance purposes.
The tax authorities share the Temporary ID and password with the taxpayer via both SMS and Email.
The Temporary ID has a specific 15-character structure worth knowing:
First 2 digits — State Code
Next 2 digits — Year (YY format)
Next 8 digits — Serial Number
Last 3 digits — "TMP"
So for a business in Rajasthan registered in 2026, it would look like: 0826 12345678TMP
The taxpayer logs in to www.gst.gov.in using the Temporary ID and password. From there, they can access Registration, Orders, Payment, Notices, Appeals, and related functionalities.
GST Portal → Services → User Services → View Notices and Orders
The Allotment Order for Temporary Registration can be viewed and downloaded from here.
When applying for permanent GST registration, go to Part B under "Business Details." Select "Indicate Existing Registrations" and enter the Temporary ID. This links the temporary and permanent registrations on the portal — a step many people miss.
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The 90-day revocation window is worth noting specifically — it was extended from 30 days under CGST Notification No. 38/2023, effective 1 October 2023. Many practitioners still cite the old 30-day limit. It's 90 days now.
There are two ways to handle this.
Through the Officer: The tax officer can collect cash or a Demand Draft directly during enforcement proceedings and deposit it on behalf of the taxpayer.
By the Taxpayer directly: After receiving the Temporary ID or TIN, the taxpayer can log in to the GST portal, generate a challan, and make the payment online. This is now enabled through the amended Rule 87(4).
Once the payment goes through, the Liability Register updates automatically. Outstanding liabilities can be adjusted from there.
These two rules address different situations. Confusing them is easy — so here's the clear distinction:
Rule 16 is about bringing unregistered taxable persons into the system. Rule 16A is about creating a payment pathway for those who don't need registration but still have payment obligations under the Act.
Suo moto cancellation is a different situation entirely. Here, the officer cancels an existing GST registration on their own motion.
Under Section 29(2) of the CGST Act, the Proper Officer can cancel a GST registration suo moto when:
The taxpayer has violated provisions of the CGST Act or rules
Registration was obtained through fraud, suppression, or misrepresentation of facts
Voluntary registration was taken but business was not commenced within six months
There are additional grounds too. Continuous failure to file returns for 6 consecutive months (3 quarters for composition taxpayers) can trigger cancellation. So can collecting tax but not depositing it with the government within 90 days. Issuing invoices without actual supply of goods or services — essentially fraudulent ITC claims — is another serious ground.
GST law requires the tax officer to first issue a Show Cause Notice. The taxpayer must respond within 7 working days through Form GST REG-18, via Services → Registration → Application for Filing Clarifications.
Only if the officer is unsatisfied with the response does the cancellation order follow. The taxpayer does get a chance to explain.
Run through this after receiving a Temporary ID:
[ ] Received Temporary ID and Password via SMS and Email
[ ] Logged in to GST Portal and downloaded the Allotment Order
[ ] Applied for permanent registration within 90 days
[ ] Mentioned Temporary ID in the permanent registration application
[ ] Deposited tax and verified the Liability Register
[ ] Updated mobile number at the time of permanent registration
The last point gets skipped more often than it should. Mobile number update at permanent registration time is operationally important — future notices go there.
Suo moto registration is designed for one purpose: pulling unregistered taxable businesses into the GST net. It's not a gentle nudge — it comes with an enforcement action behind it.
The 2025 amendments through Notification No. 07/2025 have made the process more structured. Rule 16A fills a real gap that practitioners had flagged. The revised Form GST REG-12 is cleaner. The payment pathway through amended Rule 87(4) removes friction.
None of that makes the experience pleasant for the business on the receiving end, though.
Staying registered, filing on time, and maintaining clean compliance records is the only way to ensure this process never becomes relevant to you personally. If you're already navigating a suo moto action — or advising someone who is — the 90-day window for permanent registration is the first clock to watch.
LegalDev's GST experts are available if you need guidance on any of these compliance matters.
A: Voluntary registration is initiated by the business owner — they apply themselves. Suo moto GST registration is initiated by the tax officer, usually after an enforcement survey or inspection reveals that the business was making taxable supplies without registration. The taxpayer has no choice in the matter once the process begins.
A: No. Suo moto registration under Section 25 of the CGST Act is an officer-initiated process — the taxpayer's consent is not required. The Proper Officer issues the temporary registration through Form GST REG-12 and the process proceeds whether or not the person cooperates.
A: The 90-day limit is a hard deadline. Missing it can result in further compliance action by the department, including potential suo moto cancellation of the temporary registration and continuation or escalation of the original enforcement proceedings. It's not a window you want to let close.
A: No. A TIN issued under Rule 16A is not a GSTIN. It is a Temporary Identification Number issued to persons who are not liable to register under GST but need to make a specific payment under the Act. It does not carry the same rights or obligations as a regular GST registration.
A: The revocation application must be filed within 90 days of the cancellation order, as extended by CBIC Notification No. 38/2023. After the 90-day window, revocation through normal channels is not possible — you would need to approach the appellate authority or the High Court, depending on the circumstances. Always file within the deadline.
A: Form GST REG-12 is used by the Proper Officer to grant temporary registration or a Temporary Identification Number during suo moto proceedings. After the 2025 amendments, it covers both purposes — Part A for temporary registration under Rule 16, and Part B for TIN issuance under the new Rule 16A.
A: Not directly. Suo moto GST registration is a tax compliance matter — it doesn't interact with credit bureaus. However, if it leads to a tax demand, penalties, or legal proceedings, and those go unpaid, the downstream financial impact could affect your business's financial profile over time.
A: The Temporary ID follows this structure: first 2 digits are the state code, next 2 digits are the year in YY format, next 8 digits are the serial number, and the last 3 digits are always "TMP." For example, a Rajasthan-based temporary registration in 2026 would begin with "0826" and end in "TMP."
A: Yes. After the amendment to Rule 87(4) through Notification No. 07/2025, TIN holders and temporary registration holders can log in to the GST portal using their Temporary ID, generate a challan, and make payment online. This removed the earlier limitation of paying only through the officer.
A: Before cancelling a GST registration suo moto, the Proper Officer must issue a Show Cause Notice. The taxpayer has 7 working days to respond through Form GST REG-18 via the GST portal. If the officer is satisfied with the response, the cancellation does not proceed. If not, the cancellation order is issued — and the 90-day revocation clock starts from that date.
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