Section 28 of the Central Goods and Services Tax Act, 2017 deals with the amendment of GST registration. It provides the legal framework for updating registration particulars when information furnished by a registered person or a person holding a Unique Identity Number changes.
GST registration is not a one-time process in which the details remain unchanged forever. A business may change its legal name, address, partners, directors, authorised signatory, contact details, bank details or other registration particulars during the course of its operations. Section 28 requires such changes to be communicated to the proper officer in the prescribed manner and within the prescribed period.
The detailed procedure is provided under Rule 19 of the CGST Rules, 2017. Under the current Rule 19, a registered person generally has to submit an amendment application within 15 days of the change, using FORM GST REG-14, along with documents relating to the change.
Section 28 also distinguishes between amendments that require approval by the proper officer and amendments that can take effect without such approval. It further provides that a rejection or approval under the corresponding State GST or Union Territory GST law is deemed to be a rejection or approval under the CGST Act.
What is Section 28 of the CGST Act?
Section 28 is titled “Amendment of registration.”
The provision contains three sub-sections:
- Section 28(1) requires a registered person or UIN holder to inform the proper officer about changes in registration information.
- Section 28(2) deals with approval or rejection of amendments by the proper officer and provides an opportunity of being heard before rejection.
- Section 28(3) provides that approval or rejection under the corresponding State GST or Union Territory GST Act is deemed to be approval or rejection under the CGST Act.
The detailed procedure, forms and timelines are prescribed under Rule 19 of the CGST Rules.
Why is Amendment of GST Registration Important?
GST registration contains important information about a registered taxpayer.
This can include:
- Legal name of the business
- Principal place of business
- Additional places of business
- Details of partners or directors
- Authorised signatory details
- Contact details
- Bank account information
- Nature and category of business
- Other registration particulars
If these details change, the GST registration should also be updated.
For example, if a company shifts its principal place of business to another address, continuing to use the old registration details without making the required amendment can create compliance issues.
Therefore, Section 28 ensures that the GST registration records remain aligned with the taxpayer’s actual business information.
Section 28(1) – Informing the Proper Officer About Changes
Section 28(1) requires every registered person and every person to whom a Unique Identity Number (UIN) has been assigned to inform the proper officer of changes in the information furnished at the time of registration or subsequently.
The information must be provided:
- In the prescribed form,
- In the prescribed manner, and
- Within the prescribed period.
The exact procedure is provided under Rule 19.
Under the current Rule 19, where there is a change in the particulars furnished in the relevant registration application or UIN application, the registered person must generally submit an application electronically in FORM GST REG-14 within 15 days of the change, along with documents relating to the change.
What is FORM GST REG-14?
FORM GST REG-14 is the application for amendment in registration particulars.
The form contains details such as:
- GSTIN/UIN
- Name of business
- Type of registration
- Details of the amendment
- Effective date of the change
- Reasons for the amendment
- Documents uploaded in support of the amendment
The prescribed form is specifically titled “Application for Amendment in Registration Particulars.”
Therefore, when a registered taxpayer needs to modify eligible registration details, FORM GST REG-14 is the principal amendment application.
15-Day Time Limit for Amendment
One of the most important practical requirements is the 15-day time limit.
Under Rule 19, where there is a change in the relevant registration particulars, the registered person is required to submit the amendment application within 15 days of the change.
Example
Suppose a company’s principal place of business changes on 1 September.
The company should generally submit the amendment application within 15 days of that change, along with the documents required to support the new address.
The taxpayer should therefore keep track of the date on which the underlying change actually occurred.
Core Fields and Non-Core Fields
GST registration amendments are broadly divided into:
- Core field amendments
- Non-core field amendments
This distinction is important because core-field amendments generally require verification and approval by the proper officer, whereas many non-core amendments can take effect without separate officer approval.
What Are Core Fields in GST Registration?
Under Rule 19, the important core fields include changes relating to:
- Legal name of the business, where the change does not result in a change of PAN
- Address of the principal place of business
- Address of any additional place of business
- Addition, deletion or retirement of specified persons responsible for the day-to-day affairs of the business, such as partners, directors, Karta, Managing Committee, Board of Trustees, Chief Executive Officer or equivalent persons
These changes require verification and approval by the proper officer where they do not warrant cancellation of registration under Section 29.
Amendment of Legal Name of Business
A business may change its legal name without changing its PAN.
For example, suppose:
ABC Enterprises Pvt. Ltd.
changes its registered legal name to:
ABC Retail Pvt. Ltd.
If the change does not result in a change of PAN and does not otherwise require cancellation and fresh registration, the taxpayer can apply for amendment of the registration particulars.
The proper officer verifies the application and, where the requirements are satisfied, approves the amendment. The amended registration takes effect from the date of occurrence of the event warranting the amendment.
Important: Change in PAN
A change in business constitution that results in a change in PAN is treated differently.
Rule 19 specifically provides that where a change in the constitution of the business results in a change of the PAN of the registered person, the person must apply for fresh GST registration in FORM GST REG-01 rather than merely amending the existing registration.
This distinction is extremely important.
Change in eligible registration particulars without change in PAN → Amendment
Change in constitution resulting in change of PAN → Fresh registration
Change in Principal Place of Business
A change in the principal place of business is another important core-field amendment.
Suppose a registered business moves its main office from one address to another within the same State or Union territory.
The registered person needs to update the principal place of business in the GST registration.
The amendment application is submitted through FORM GST REG-14 with the relevant supporting documents.
Because the principal place of business is a core field, the amendment requires verification and approval by the proper officer under Rule 19.
Change in Additional Place of Business
A business may also add, remove or change an additional place of business.
For example, a company may open:
- A new warehouse
- A branch office
- A distribution centre
- Another business location
If the location qualifies as an additional place of business under GST law, the relevant registration particulars should be updated.
The address of an additional place of business is treated as a core field under Rule 19 and therefore follows the approval process.
Change in Partners or Directors
Changes in the persons responsible for the day-to-day affairs of a business can also require amendment.
Rule 19 specifically covers addition, deletion or retirement of:
- Partners
- Directors
- Karta
- Managing Committee
- Board of Trustees
- Chief Executive Officer
- Equivalent responsible persons
provided the change does not warrant cancellation of registration under Section 29.
The amendment application should contain the relevant details and supporting documents.
Changes Applicable to Multiple Registrations on the Same PAN
Rule 19 contains an important provision for certain amendments.
Changes relating to:
- Legal name of business, and
- Addition, deletion or retirement of specified persons responsible for the day-to-day affairs of the business
in a State or Union territory apply to all registrations of the registered person obtained under the rules on the same PAN in that State or Union territory.
This helps maintain consistency among registrations held under the same PAN within the relevant State or Union territory.
What Are Non-Core Fields?
Non-core fields are registration particulars that generally do not require separate approval from the proper officer before the registration certificate is amended.
Rule 19 provides that where a change relates to particulars other than the specified core fields, the certificate of registration stands amended upon submission of the amendment application on the common portal.
Examples can include certain:
- Contact details
- Bank account details
- Authorised signatory information
- Other eligible registration particulars
The exact field and verification requirement should be checked on the GST portal because the functionality and prescribed verification process can differ depending on the particular field.
CBIC’s FAQ also explains the distinction by noting that certain core fields require approval, while examples of amendments that can generally be made without officer approval include telephone number, email ID and bank account details.
Change in Mobile Number or Email Address of Authorised Signatory
There is a specific verification requirement for changes to the mobile number or email address of the authorised signatory.
Rule 19 provides that such changes are carried out only after online verification through the common portal in the manner prescribed under the registration rules.
Therefore, a taxpayer should not assume that every contact-detail amendment is completely automatic without verification.
Approval of Core Amendments
For core-field amendments, the proper officer is required to examine the application.
Where the change:
- Does not warrant cancellation under Section 29, and
- Is supported by the required information and documents,
the proper officer is required to approve the amendment within 15 working days from receipt of the application in FORM GST REG-14.
The order of amendment is issued electronically in FORM GST REG-15.
FORM GST REG-15 – Order of Amendment
FORM GST REG-15 is the Order of Amendment.
It is issued when the proper officer approves an amendment requiring officer approval.
The form records that the amendment application has been examined and found to be in order and that the amended registration certificate is available on the taxpayer’s dashboard.
Therefore:
REG-14 = Application for amendment
REG-15 = Order of amendment
What if the Proper Officer Finds a Problem?
The proper officer can examine whether the amendment requested is warranted and whether the supporting documents are complete and correct.
If the officer believes that the amendment should not be approved or the documents are incomplete or incorrect, a notice can be issued requiring the registered person to explain why the amendment application should not be rejected.
The notice is issued electronically in FORM GST REG-03.
Reply to Amendment Notice – FORM GST REG-04
When a taxpayer receives a notice seeking clarification or additional information in relation to the amendment application, the taxpayer can submit the response through FORM GST REG-04.
Under Rule 19, the registered person has seven working days from the date of service of the notice to furnish the reply.
The reply should clearly address the reason for the objection and provide any missing or corrected documents.
Rejection of Amendment Application – FORM GST REG-05
If the taxpayer:
- Does not respond within the prescribed period, or
- Provides a response that is not satisfactory,
the proper officer may reject the amendment application.
The rejection is made through FORM GST REG-05 in accordance with the prescribed procedure.
However, Section 28(2) contains an important safeguard: the proper officer cannot reject an application for amendment without giving the person an opportunity of being heard.
Opportunity of Being Heard
The right to be heard is an important procedural protection under Section 28.
Before rejecting an amendment application, the taxpayer must be given an opportunity to explain the requested change.
This means the amendment process is not designed to allow arbitrary rejection without giving the taxpayer a chance to respond.
The taxpayer should therefore carefully respond to any notice issued by the proper officer and provide appropriate supporting documents.
Deemed Amendment When Officer Does Not Act
Rule 19 contains a deemed-amendment mechanism.
If the proper officer fails to take action:
- Within 15 working days from submission of the amendment application, or
- Within 7 working days from receipt of the taxpayer’s reply to the notice,
the certificate of registration stands amended to the extent applied for, and the amended certificate is made available to the registered person on the common portal.
This provides a time-bound mechanism for processing amendment applications.
Effective Date of Amendment
For core-field amendments that require approval, Rule 19 provides that the amendment takes effect from the date of occurrence of the event warranting the amendment.
For example, if a qualifying change in the principal place of business occurs on 1 October and the amendment is subsequently approved, the amendment is generally effective from the date of the event rather than simply from the date on which the officer approves the application.
However, the taxpayer should ensure that the actual event date and supporting documents are correctly declared.
Can an Amendment Take Effect From an Earlier Date?
Rule 19 contains a restriction concerning the effective date of amendments.
As a general rule, a particular of the registration application cannot stand amended with effect from a date earlier than the date of submission of FORM GST REG-14, except under the specified circumstances where the Commissioner passes an order for reasons recorded in writing and subject to conditions specified in that order.
This provision is important where taxpayers attempt to make amendments retrospectively.
The taxpayer should therefore accurately report the date on which the underlying event occurred and follow the prescribed procedure.
When is Fresh Registration Required Instead of Amendment?
Not every change can be handled through an amendment application.
One of the most important exceptions concerns a change in the constitution of the business resulting in a change of PAN.
In such a situation, Rule 19 requires the taxpayer to apply for fresh registration in FORM GST REG-01.
Example
Suppose a proprietorship business is converted into a company and the conversion results in a different PAN.
This is not simply a minor amendment to the existing GST registration.
The new entity must examine the fresh-registration requirement.
Amendment vs Cancellation of GST Registration
Section 28 should also be distinguished from Section 29.
Amendment
Amendment is appropriate where the registered person’s identity and registration can continue but certain particulars have changed.
Examples include:
- Change in eligible business name
- Change of business address
- Addition or deletion of an additional place
- Change in specified partners or directors
Cancellation
Cancellation becomes relevant where the circumstances warrant termination of the GST registration, such as discontinuation, transfer or other circumstances covered by Section 29.
If a proposed change is so significant that it requires cancellation under Section 29, it cannot simply be handled as an ordinary amendment.
Section 28 and State GST / UTGST
Section 28(3) provides that approval or rejection of amendments under the State GST Act or Union Territory GST Act is deemed to be approval or rejection under the CGST Act.
This is similar in concept to Section 26, which coordinates registration decisions between the Central and State/Union Territory GST laws.
The purpose is to maintain consistency in the taxpayer’s registration particulars across the dual GST framework.
Example of Section 28(3)
Suppose a taxpayer has a GST registration covering both the Central and State components of GST.
The taxpayer submits a valid amendment application.
If the corresponding State GST authority approves the amendment under the State GST Act, that approval is deemed to be approval under the CGST Act as provided by Section 28(3).
Similarly, a rejection under the State GST or UTGST Act is deemed to be a rejection under the CGST Act.
Amendment of UIN Details
Section 28 does not apply only to ordinary registered taxpayers.
It also specifically covers persons to whom a Unique Identity Number has been assigned.
Where relevant information furnished for the UIN changes, the UIN holder must inform the proper officer in the prescribed manner.
Rule 19 includes the UIN application in FORM GST REG-13 within the registration particulars covered by the amendment framework.
GST Registration Amendment Process
The amendment process can broadly be understood through the following steps:
Step 1 – Identify the Change
Determine what information in the GST registration has changed.
Step 2 – Determine Whether Amendment or Fresh Registration Is Required
Check whether the change can be made through amendment or whether it results in a change of PAN requiring fresh registration.
Step 3 – Submit FORM GST REG-14
The registered person generally has to submit FORM GST REG-14 within 15 days of the change, with the relevant supporting documents.
Step 4 – Verification
For core-field changes, the proper officer verifies the application and documents.
Step 5 – Approval or Clarification
If everything is satisfactory, the amendment is approved.
If clarification is required, FORM GST REG-03 may be issued.
Step 6 – Submit Reply if Required
The taxpayer submits the required response through FORM GST REG-04.
Step 7 – Amendment or Rejection
The amendment is approved and reflected in the registration certificate, or the application may be rejected through the prescribed procedure.
Important Documents for GST Amendment
The documents required depend on the nature of the amendment.
For example:
Change of Address
Possible supporting documents can include documents establishing possession or use of the premises, depending on the circumstances.
Change of Legal Name
Supporting documents reflecting the legal change may be required.
Change in Partners or Directors
Relevant constitutional and identification documents may be required.
Bank Account Change
Appropriate bank account evidence may be required through the portal.
The taxpayer should upload documents relevant to the particular change rather than submitting unrelated documents.
Examples of GST Registration Amendment
Example 1 – Change of Business Address
A registered business shifts its principal office from one address to another within the same State.
The taxpayer should update the principal place of business through the amendment procedure.
Because address is a core field, officer verification is involved.
Example 2 – Addition of Warehouse
A business opens a new warehouse that qualifies as an additional place of business.
The registration particulars should be updated through the prescribed amendment process.
Example 3 – Change in Mobile Number
A registered taxpayer changes the mobile number of the authorised signatory.
The relevant details can be amended through the GST portal, subject to the prescribed online verification mechanism.
Example 4 – Change in Bank Account
A business closes one bank account and starts using another account.
The eligible bank details can be updated in the registration particulars through the amendment process.
Example 5 – Change in Partner
A partner retires from a partnership firm.
If the change does not warrant cancellation of registration, the relevant registration particulars can be amended and the proper officer will verify the change.
Example 6 – Change Resulting in New PAN
A change in the constitution of a business results in a new PAN.
In this situation, the existing GST registration cannot simply be amended for the new PAN. A fresh registration application in FORM GST REG-01 is required.
Core vs Non-Core Amendment
| Particular | General Treatment |
|---|---|
| Legal name of business, without change of PAN | Core field; officer approval required |
| Principal place of business | Core field; officer approval required |
| Additional place of business | Core field; officer approval required |
| Addition/deletion/retirement of specified partners/directors etc. | Core field; officer approval required |
| Many contact details | Generally non-core, subject to prescribed verification |
| Bank account details | Generally non-core |
| Other eligible registration particulars | Generally amended without separate officer approval |
| Change resulting in new PAN | Fresh registration required |
The classification and procedure are governed by Rule 19 and the GST registration system.
Common Mistakes Under Section 28
Mistake 1 – Not Updating Registration After a Change
A taxpayer may continue using old registration details after shifting the business address or changing other important particulars.
This can create discrepancies between the GST portal and actual business records.
Mistake 2 – Missing the 15-Day Deadline
Rule 19 requires the amendment application to generally be submitted within 15 days of the change.
Mistake 3 – Treating Every Amendment as Automatic
Core-field amendments require verification and approval by the proper officer.
Mistake 4 – Using Amendment When PAN Has Changed
A change in constitution resulting in a new PAN requires fresh registration rather than ordinary amendment.
Mistake 5 – Providing Incomplete Documents
For core amendments, incomplete or incorrect supporting documents can result in a clarification notice and potentially rejection.
Mistake 6 – Ignoring the Notice
If a taxpayer receives FORM GST REG-03 and does not provide the required response within the prescribed period, the amendment application may be rejected.
Mistake 7 – Assuming State Approval and CGST Approval Are Completely Separate
Section 28(3) provides a deemed effect for approval or rejection under the State GST or UTGST Act.
Section 28 and GST Compliance
Keeping registration details updated is an important part of GST compliance.
For example, a taxpayer’s:
- GST certificate
- Invoices
- E-way bill information
- E-invoicing records, where applicable
- GST returns
- Business records
should generally be consistent with the taxpayer’s actual registration particulars.
An amendment is therefore not merely an administrative exercise. Correct registration information can help prevent inconsistencies across GST compliance records.
Section 28 – Important Forms
| Form | Purpose |
|---|---|
| FORM GST REG-14 | Application for amendment in registration particulars |
| FORM GST REG-15 | Order of amendment issued after approval of applicable amendments |
| FORM GST REG-03 | Notice seeking clarification/additional information/documents |
| FORM GST REG-04 | Reply to clarification or notice |
| FORM GST REG-05 | Order of rejection of application |
| FORM GST REG-01 | Fresh registration where a change in constitution results in change of PAN |
The current Rule 19 framework identifies FORM GST REG-14 as the amendment application and FORM GST REG-15 as the order of amendment.
Section 28 vs Section 29
| Basis | Section 28 | Section 29 |
|---|---|---|
| Main subject | Amendment of registration | Cancellation or suspension of registration |
| Purpose | Update existing registration particulars | End or suspend registration in specified circumstances |
| Example | Change of address | Business discontinued |
| PAN change due to constitution | Fresh registration required | Existing registration may need cancellation as applicable |
| Application | Amendment application | Cancellation application or officer proceedings |
| Key issue | Correcting/updating registration details | Whether registration should continue |
Section 28 is therefore relevant when the registration continues but its particulars need to be updated.
Section 28 – Key Takeaways
The most important points of Section 28 are:
- Section 28 deals with amendment of GST registration particulars.
- Every registered person and UIN holder must report eligible changes in the prescribed manner.
- Under Rule 19, the amendment application is generally required within 15 days of the change.
- FORM GST REG-14 is the application for amendment in registration particulars.
- Core-field amendments generally require verification and approval by the proper officer.
- Core fields include legal name, principal place of business, additional places of business and specified changes in persons responsible for day-to-day business affairs.
- The proper officer generally has 15 working days to approve a core amendment.
- FORM GST REG-15 is the order of amendment.
- Non-core amendments generally do not require separate officer approval.
- Certain changes in mobile number or email address of the authorised signatory require online verification.
- If the proper officer raises an objection, FORM GST REG-03 may be issued.
- The taxpayer can respond through FORM GST REG-04.
- If the response is unsatisfactory or not submitted within the prescribed period, the amendment may be rejected through FORM GST REG-05.
- Before rejection, Section 28 requires that the person be given an opportunity of being heard.
- If the proper officer does not take action within the prescribed period, the registration certificate can stand amended to the extent applied for, subject to Rule 19.
- If a change in business constitution results in a change of PAN, fresh GST registration is required.
- Approval or rejection under the State GST or UTGST Act is deemed to be approval or rejection under the CGST Act.
Conclusion
Section 28 of the CGST Act, 2017 provides the legal framework for keeping GST registration particulars updated when there is a change in the information furnished by a registered person or UIN holder.
The provision is particularly important because GST registration details can change during the life of a business. A company may shift its principal place of business, open or close an additional location, change its legal name, add or remove partners or directors, update authorised signatory details or make other eligible changes.
Under Rule 19, the registered person generally has to submit an amendment application in FORM GST REG-14 within 15 days of the change, along with the relevant documents. Core-field amendments such as legal name, business address and specified changes in persons responsible for the business require verification and approval by the proper officer, while eligible non-core amendments can generally be updated without separate officer approval.
Section 28 also provides an important procedural safeguard. The proper officer cannot reject an amendment application without giving the taxpayer an opportunity of being heard. Further, approval or rejection under the corresponding State GST or Union Territory GST law is deemed to be approval or rejection under the CGST Act.
One of the most important distinctions is between an amendment and fresh registration. If a change in the constitution of a business results in a change of PAN, the taxpayer has to apply for fresh GST registration rather than merely amending the existing registration.
Therefore, Section 28 helps ensure that the GST registration database accurately reflects the taxpayer’s current business structure and particulars. Registered persons should report eligible changes promptly, submit the correct supporting documents and respond to any clarification notice within the prescribed time.
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