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Most Owners Think May Has One Compliance Deadline. It Has Eight.

May closes Q4 of the old year and opens the new one — filings come through both doors at once. Here is every date before May 31, and why the biggest one is the TDS return most businesses forget.

Deadlines8 before 31 May
The big oneQ4 TDS — 31 May
Penalty₹200/day per form
Forms24Q, 26Q, 27Q

The story

Rajan runs a small manufacturing unit in Gurugram’s IMT Manesar — twelve employees on payroll, GST-registered, a TDS deductor, EPFO and ESIC registered. In his mind, May’s compliance is simple: GSTR-3B by the 20th. That is the one date on his whiteboard every May.

May 2026 has seven more deadlines he has not written anywhere. The biggest is 31 May — the quarterly TDS return filing, unlike anything he files the rest of the year. For most employers and deductors the largest deadline of the month is 31 May, when the Q4 TDS returns for January–March 2026 are due in Forms 24Q, 26Q and 27Q.

If he misses it: ₹200 per day per return. For three returns that is ₹600 per day, accumulating with no ceiling, until the returns are filed. This blog is Rajan’s whiteboard for May 2026.

Why owners chronically underestimate May

May feels quiet. The financial year just closed, annual-return season is months away, advance tax doesn’t start until 15 June, and ITR season is July. But May is the month that closes Q4: quarterly TDS returns across every form, PF and ESI for April payroll, the first GST returns of the new year, and several other filings landing quietly between the 10th and the 31st.

Think of May as the month where both doors are open at once — the exit door of the old financial year and the entrance door of the new one. If you are only watching the entrance (GSTR-3B on the 20th), everything coming through the exit door piles up unnoticed until the last week.

The complete May 2026 compliance map

DateFilingWho filesLate penalty
7 May (passed)TDS/TCS deposit — April 2026All TDS deductors1.5% per month interest
11 MayGSTR-1 — April 2026Monthly filers (AATO > ₹5 cr)₹50/day
13 MayGSTR-7 / GSTR-8GST TDS deductors / e-commerce TCS collectors₹50/day
15 MayPF + ESI — April payrollAll EPFO + ESIC employers12–25% p.a. interest
15 MayForm 27EQ — Q4 TCS returnTCS collectors₹200/day
20 MayGSTR-3B — April 2026Monthly GST filers₹50/day + 18% interest
25 MayPMT-06 — April 2026QRMP scheme taxpayers18% interest
30 MayLLP Form 11 — FY 2025-26All LLPs (even nil)₹100/day — no ceiling
31 MayQ4 TDS returns 24Q + 26Q + 27QAll TDS deductors₹200/day per form — 3 forms = ₹600/day

The key deadlines explained

11 May — GSTR-1 (monthly filers): every invoice, credit and debit note issued in April. Your buyers depend on it for GSTR-2B; if you are late, their ITC is short and — under the new ITC Hard Block — their own GSTR-3B may be blocked. Above ₹5 cr AATO, every invoice should already carry an IRN.

15 May — PF + ESI: both employee and employer shares for April salary. Delayed PF attracts 12–25% p.a. interest, and Aadhaar/PAN validation on the ECR is mandatory or the contribution won’t credit correctly.

20 May — GSTR-3B (the one Rajan knows): the summary return for April. Under the ITC Hard Block active from 1 April 2026, if your ITC claim exceeds the GSTR-2B figure the portal blocks filing entirely — reconcile against your purchase register first and defer unmatched ITC rather than risk a blocked return.

30 May — LLP Form 11: the LLP annual return for FY 2025-26, with details of designated partners, contributions and any change in composition. ₹100/day with no cap — and even a nil-transaction LLP must file.

31 May — the Q4 TDS returns most owners miss

The largest deadline of the month — Forms 24Q, 26Q and 27Q for January–March 2026.

  • Form 24Q (salary TDS): Q4 is the most data-intensive quarter, including Annexure-II with annual employee-wise reconciliation of salary, deductions, tax regime and total TDS. This generates Form 16 Part B via TRACES — so late Q4 filing directly delays Form 16, disrupting employees’ ITR filing, home-loan applications and visa documentation.
  • Form 26Q (non-salary TDS): all TDS on vendor payments — contractors, professional fees, rent, interest — between January and March 2026.
  • Form 27Q (non-resident TDS): any payments to foreign vendors, consultants or suppliers in the same quarter.
Critical 2026 transition note: Q4 returns use ITA 1961 — while April 2026 deductions use ITA 2025. Forms 24Q/26Q/27Q for Q4 must reference ITA 1961 sections (192, 194C, 194J, 194I), not ITA 2025 (392, 393). The governing Act is set by when the income was earned, not when the return is filed.

Key takeaways

Key compliance pointWhat you must do
31 May is the largest deadline — Q4 TDS returns (24Q, 26Q, 27Q)Start Q4 data reconciliation today — salary data, vendor payments and PAN verification must be clean before filing
Q4 TDS returns are filed under ITA 1961, not ITA 2025Use old section numbers: 192 (salary), 194C (contracts), 194J (professional fees) — not Section 392/393
Form 16 issuance depends on the 31 May Q4 filingLate Q4 filing pushes Form 16 past 15 June — disrupting employees’ ITR, home-loan and visa documentation
LLP Form 11 due 30 May — often missedEvery LLP, even with no transactions, must file — ₹100/day, no ceiling

But here is the other side…

For very small businesses — sole proprietorships, small traders on the GST composition scheme, businesses without employees — May’s load is genuinely lighter. A composition taxpayer’s CMP-08 for Q4 was due 18 April, so nothing major in May. A business without employees has no PF, ESI or Form 24Q; one with no non-resident vendors skips Form 27Q. The eight deadlines don’t all apply to every business at once — but every GST-registered, TDS-deducting employer with at least one vendor is managing six or more simultaneously, and the only safe assumption is that each one applies until you have confirmed it does not.

May 31 is three weeks away — start the Q4 data pull today

The Q4 TDS process — especially Form 24Q with Annexure-II — is the most data-intensive filing in the annual calendar. It needs employee-wise salary reconciliation, regime-wise deduction mapping, PAN verification for every deductee, and month-by-month reconciliation against challans deposited from January to March. Starting this on 29 May is not starting it. Starting it today is what makes 31 May manageable.

WeConsult India handles Q4 TDS return filing — Forms 24Q, 26Q and 27Q — for companies across Gurugram’s IMT Manesar, Sector 37 and Udyog Vihar, and manages Form 16 generation and TRACES download for all employees after Q4 filing. If you haven’t started your Q4 reconciliation, contact us today.

Stay compliant. Stay protected. — WeConsult India

This blog is for informational purposes only and does not constitute legal or professional advice. Please consult a qualified Company Secretary or Chartered Accountant before acting on any compliance matter.
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