This advisory has been issued by GSTN to inform taxpayers about upcoming system validations in GSTR-3B linked to the Electronic Credit Reversal and Re-claimed Statement (ITC Reclaim Ledger) and the RCM Liability/ITC Statement.

• The Electronic Credit Reversal and Re-claimed Statement (Reclaim Ledger) was introduced from August 2023 for monthly filers and from the July–September 2023 quarter for quarterly filers to track ITC reversed in Table 4(B)(2) and reclaimed in Table 4(A)(5) and 4(D)(1) of GSTR-3B.
• Currently, the system only issues a warning where reclaimed ITC in Table 4(D)(1) exceeds the available balance, but filing of GSTR-3B is still allowed.
• Taxpayers were provided multiple opportunities to declare opening balances of earlier reversed but unreclaimed ITC in the Reclaim Ledger.
• The Reclaim Ledger can be accessed through Dashboard → Services → Ledger → Electronic Credit Reversal and Re-claimed Statement.
• To track Reverse Charge transactions, the RCM Liability/ITC Statement (RCM Ledger) was introduced from August 2024 for monthly filers and from the July–September 2024 quarter for quarterly filers. It captures RCM liability reported in Table 3.1(d) and corresponding ITC claimed in Tables 4(A)(2) and 4(A)(3) of GSTR-3B.
• At present, a warning is generated if ITC claimed under RCM exceeds the closing balance of the RCM Ledger plus current period RCM liability, but return filing is permitted.
• Taxpayers were also given multiple opportunities to declare and amend opening balances in the RCM Ledger for excess RCM ITC or liability pertaining to periods prior to introduction of the statement.
• The RCM Liability/ITC Statement is available at Services → Ledger → RCM Liability/ITC Statement.
• GSTN has informed that shortly, negative balances or excess availment of ITC will not be permitted in either ledger, and system-based validations will be enforced as follows:
  a. Reclaimed ITC in Table 4(D)(1) must be less than or equal to the closing balance of the Reclaim Ledger plus ITC reversed in Table 4(B)(2) of the current period.
  b. RCM ITC claimed in Tables 4(A)(2) and 4(A)(3) must be less than or equal to the RCM liability paid in Table 3.1(d) of the current period plus the closing balance of the RCM Ledger.
• Where a taxpayer has a negative closing balance in the Reclaim Ledger, filing of GSTR-3B will be blocked until the excess reclaimed ITC is mandatorily reversed in Table 4(B)(2). If no ITC is available, such reversal will be added to the output tax liability of the current period.
• Where a taxpayer has a negative closing balance in the RCM Ledger, filing of GSTR-3B will be blocked until either additional RCM liability equivalent to the negative balance is paid in Table 3.1(d) or the ITC claimed in Tables 4(A)(2) or 4(A)(3) is reduced to that extent in the current return period.
• These changes will convert existing warning-based controls into hard validations, directly restricting filing of GSTR-3B in cases of excess ITC reclaim or RCM ITC mismatch, thereby tightening ITC discipline and reducing reconciliation errors.