The Goods and Services Tax Network (GSTN) issued a critical advisory on December 29, 2025, announcing stricter validation rules for Input Tax Credit (ITC) reporting. These changes will significantly impact how taxpayers file their GSTR-3B returns, particularly concerning the Electronic Credit Reversal Statement and RCM Liability/ITC Statement.
Understanding the Two Key Ledgers
Electronic Credit Reversal and Re-claimed Statement (Reclaim Ledger)
Introduced in August 2023, this ledger tracks ITC that taxpayers temporarily reverse in Table 4(B)(2) of GSTR-3B and subsequently reclaim through Table 4(A)(5) and 4(D)(1).
Who needs this?
- Monthly taxpayers: Applicable from August 2023
- Quarterly taxpayers: Applicable from July-September 2023 quarter
How to access: Dashboard › Services › Ledger › Electronic Credit Reversal and Re-claimed
RCM Liability/ITC Statement (RCM Ledger)
Launched in August 2024, this statement monitors Reverse Charge Mechanism transactions by capturing RCM liability declared in Table 3.1(d) and the corresponding ITC claimed in Tables 4A(2) and 4A(3).
Who needs this?
- Monthly filers: Applicable from August 2024
- Quarterly filers: Applicable from July-September 2024 quarter
How to access: Services >> Ledger >> RCM Liability/ITC Statement
What’s Changing: New Mandatory Validations
Currently, taxpayers receive only warning messages when attempting to claim excess ITC. However, GSTN has announced that negative balances will soon be blocked, preventing GSTR-3B filing altogether.
Validation Rules Coming into Effect
For Reclaim Ledger: The reclaimed ITC in Table 4(D)(1) must be ≤ (Closing balance of Electronic Credit Reversal Statement + ITC reversed in Table 4(B)(2) of current period)
For RCM Ledger: The RCM ITC claimed in Tables 4(A)(2) and 4(A)(3) must be ≤ (RCM liabilities in Table 3.1(d) + Closing balance of RCM Statement)
Critical: What If Your Ledger Already Shows Negative Balance?
For Negative Balance in Reclaim Ledger
If your Electronic Credit Reversal Statement shows a negative closing balance, you must:
- Reverse the excess claimed ITC in Table 4(B)(2) equal to the negative balance amount
- If no ITC is available in the current period, this reversal will be added to your liability
Example: Your reclaim ledger shows -₹10,000. This means you’ve over-claimed ₹10,000 in previous periods. You must now reverse ₹10,000 in Table 4(B)(2) to file your current GSTR-3B.
For Negative Balance in RCM Ledger
When your RCM Liability/ITC Statement has a negative balance, you have two options:
Option 1: Pay additional RCM liability in Table 3.1(d) equivalent to the negative balance
Option 2: Reduce the ITC claimed in Tables 4A(2) or 4A(3) by the negative balance amount (if sufficient ITC is available)
Example: Your RCM ledger shows -₹5,000. You can either:
- Pay additional ₹5,000 RCM liability in Table 3.1(d), OR
- Reduce your ITC claim by ₹5,000 in Table 4A(2)/4A(3)
Action Required: Check Your Ledgers Now
Taxpayers should immediately review both ledgers to identify any negative balances before the mandatory validations become active.
Step-by-Step Compliance Checklist
- Access your ledgers through the GST portal navigation paths mentioned above
- Review closing balances for all return periods
- Calculate discrepancies if negative balances exist
- Plan corrections in your next GSTR-3B filing
- Maintain documentation supporting all reversals and adjustments
Opening Balance Reporting: Important Deadlines (Now Closed)
Both ledgers had specific deadlines for reporting opening balances, which have now passed:
Electronic Credit Reversal Statement:
- Monthly filers: Reconcile ITC reversals up to July 2023
- Quarterly filers: Reconcile up to Q1 (April-June 2023)
- Reporting deadline: November 30, 2023
- Amendment deadline: December 31, 2023 (3 opportunities provided)
RCM Liability/ITC Statement:
- Monthly filers: Reconcile RCM ITC up to July 2024
- Quarterly filers: Reconcile up to Q1 (April-June 2024)
- Reporting deadline: October 31, 2024
- Amendment deadline: November 30, 2024 (3 opportunities provided)
Frequently Asked Questions
How do I view my Electronic Credit Reversal Statement?
Navigate to Dashboard › Services › Ledger › Electronic Credit Reversal and Re-claimed on the GST portal.
Will I receive any notification before filing is blocked?
Currently, you receive warning messages. Once mandatory validation is implemented, the system will prevent filing if negative balances exist.
Can I claim ITC reversed in earlier periods through Table 4A(2)?
No. RCM ITC previously reversed through Table 4(B)(2) should be reclaimed through Table 4A(5), not through Tables 4A(2) or 4A(3).
What happens if I don’t have sufficient ITC to reverse the negative balance?
If no ITC is available in the current period, the reversal amount will be added directly to your tax liability when filing GSTR-3B.
When will these mandatory validations take effect?
GSTN has announced they will be implemented “shortly” without specifying an exact date. Taxpayers should act proactively.
Expert Recommendations
For Tax Professionals:
- Audit client ledgers immediately to identify negative balances
- Prepare correction strategies for affected taxpayers
- Update filing SOPs to include ledger balance verification
For Businesses:
- Implement monthly ledger reconciliation as part of GST compliance
- Train accounts teams on proper ITC reversal and reclaim procedures
- Consider using automated GST compliance tools for tracking
Official Resources
For detailed guidance, GSTN has provided these reference documents:
- Electronic Credit Reversal Advisory (September 17, 2024)
- RCM Liability/ITC Statement Advisory (August 23, 2024)
- GSTN Advisory & FAQ on Electronic Credit Reversal and Re-claimed Statement & RCM Liability/ITC Statement (December 29, 2025)
Conclusion
The introduction of mandatory validations for ITC ledgers represents a significant shift toward automated compliance enforcement in GST. While these measures aim to reduce errors and improve accuracy, taxpayers with existing negative balances must take immediate corrective action.
Proactive ledger management and regular reconciliation will be essential to avoid GSTR-3B filing disruptions. Given that the implementation timeline is described as “shortly,” businesses should prioritize reviewing their ledger positions without delay.
Disclaimer: This article is for informational purposes only and does not constitute professional tax advice. Consult with a qualified GST practitioner for specific compliance guidance.