Sandipan Mitra is the CEO and co-founder of Pice. He boasts eight years of experience in the B2B and fintech sector. Sandipan's journey includes significant roles at multiple Indian Unicorns Including Product at PayU, and as founding member / VP, Product at Open Financial Technologies.
22 Aug 25
5 mins
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Form GST REG 12: Suo-Moto GST Registration Process 2025
Form GST REG-12 enables Suo-Moto GST registration through a Temporary Registration Number (TRN) issued by tax authorities.
Tax officers initiate GST REG-12 when unregistered businesses are found making taxable supplies under GST law.
Businesses must apply for permanent GSTIN within 90 days of receiving temporary registration via GST REG-12.
Suo-Moto GST registration ensures tax compliance, prevents revenue leakage, and brings unregistered businesses under GST.
GST REG-12 compliance includes filing returns, paying taxes, and ITC eligibility until permanent registration is granted.
Are you are looking for temporary GST registration process or Suo-Moto registration? If so, the use of revised Form GST REG-12 under the Central Goods and Services Tax Rules of 2025 is something to consider. The Ministry of Finance Notification No. 07/2025 came with this mechanism.
The form is specifically used for generating a Temporary Registration Number or TRN, allowing such persons to pay tax liabilities and make payments via the GST Portal.
This article discusses the applicability, procedural necessity, and implications of the Suo-Moto registration process in terms of GST law.
Form GST REG 12 Applicability
Read the following to understand the applicability of Form GST REG-12:
Under the CGST Act 2017, the Proper Officer (also termed Tax official) may carry out a survey/inspection and enquiry on any person suspected or believed to have made taxable supplies without being registered under GST.
Condition 2:
Based on the findings, the tax authorities may determine that the individual is liable for registration but has not applied. In such a case, the Department of Revenue authorises the officer to initiate a Suo-Moto registration, granting a Temporary Registration Number through Form GST REG-12.
It is temporary registration and only comes into effect when the form is issued. It also has a Reference Number for follow-up and compliance.
Action on Receipt of An order in Form GST REG-12
Once the temporary registration is issued, the individual must take the following steps:
Action 1:
Within 90 days of receiving the temporary registration, the individual must file a formal application for GST registration. Upon verification of submitted documents and business details, a registration certificate with a permanent Goods and Services Tax Identification Number (GSTIN) is issued.
Action 2:
Alternatively, the individual may appeal the issuance of temporary registration. If the appellate authority upholds the order, the person must file a proper application for GST registration within 30 days of receiving the appellate decision.
During this process:
The business premises may be inspected.
All personal and bank account details must be submitted.
A full verification procedure is conducted before final approval.
The registration certificate becomes effective from the date of issuance of Form GST REG-12.
Related Compliance and Filing Requirements
Once registered, the person becomes liable to comply with standard GST obligations such as:
Filing the Annual Return.
Paying Central Tax and availing input tax credit if applicable.
Ensuring regular updates through the GST Portal.
Use the Unique Identity Number (UIN) or Unique Identification Number (if applicable, especially for UN agencies or diplomatic missions).
If the person wishes to extend the registration validity, an Application for Extension of Registration Period must be submitted within the specified timeline.
In some cases, if the registration is not validated or extended, the proper officer may initiate an Order for Cancellation of Registration.
The Suo-Moto or provisional GST registration on Form GST REG-12 is a regulation under GST law. This prevents any taxable entity from avoiding the tax net. It allows unregistered persons or businesses to meet their commitments provisionally until they undertake the normal registration process.
The format records exhaustive business details such as the business place, banking details, and grounds for provisional registration. Through a bound-by-rules and well-structured method, the government maintains the integrity of the GST regime with the ability to enforce flexibility through mechanisms like Form GST REG-12.
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FAQs
What is Form GST REG-12 under GST law?
Form GST REG-12 is a prescribed form under the Central Goods and Services Tax Rules, 2025. It is issued by the tax department for initiating Suo-Moto GST registration of a person who is liable to be registered but has failed to apply. Through this form, a Temporary Registration Number (TRN) is generated, enabling the taxpayer to comply with GST obligations until a permanent GSTIN is allotted.
When is Suo-Moto GST registration through Form GST REG-12 applicable?
Suo-Moto registration applies when the tax authorities discover taxable supplies made without GST registration. If an unregistered person is found liable to register, the officer issues Form GST REG-12, granting a Temporary Registration Number (TRN). This ensures that the business comes under the tax net and begins compliance with GST law immediately.
What are the compliance requirements after receiving Form GST REG-12?
Once Form GST REG-12 is issued, the person must apply for a permanent GST registration within 90 days. During this period, the person must also comply with standard GST rules such as filing GST returns, paying tax dues, and availing Input Tax Credit (ITC) if eligible. The Suo-Moto GST registration process ensures that businesses cannot escape their tax obligations.
Can a person appeal against Suo-Moto GST registration under Form GST REG-12?
Yes, the person can appeal against Suo-Moto GST registration if they believe they are not liable under GST law. If the appellate authority upholds the officer’s decision, the person must file a proper GST registration application within 30 days. However, during the appeal, the Temporary GST registration (TRN) remains valid, and compliance must still be maintained.
Why is Suo-Moto GST registration important for GST compliance in 2025?
The Suo-Moto GST registration process using Form GST REG-12 ensures that no taxable business remains outside the GST framework. It prevents tax evasion, protects government revenue, and ensures fair competition among registered businesses. By issuing a Temporary Registration Number (TRN), authorities guarantee that unregistered entities fulfill their GST compliance obligations until they receive a permanent GSTIN
Sandipan Mitra is the CEO and co-founder of Pice. He boasts eight years of experience in the B2B and fintech sector. Sandipan's journey includes significant roles at multiple Indian Unicorns Including Product at PayU, and as founding member / VP, Product at Open Financial Technologies.
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