Summary: Notification No. 04/2026–Central Tax, dated 26 October 2026, expands GST e-invoicing requirements from 1 January 2027 to cover self-invoices issued for supplies received from unregistered persons where tax is payable under reverse charge, as well as imports of services. The notification amends Notification No. 13/2020–Central Tax under Rule 48(4) of the CGST Rules, 2017. It does not change the existing turnover threshold of ₹5 crore or the exemptions available to specified categories of registered persons. Under the amended framework, eligible recipients must report the newly covered self-invoices through the Invoice Registration Portal and obtain an Invoice Reference Number and QR code. The existing requirement for e-invoicing on B2B supplies and exports continues, while ordinary B2C transactions remain outside this particular mandate. The change is particularly relevant to businesses making reverse charge payments to unregistered advocates, directors, landlords and scrap suppliers, as well as those importing software, consultancy and other services. Businesses should identify affected transactions, update their accounting systems, establish timely self-invoicing procedures and reconcile reverse charge liabilities with input tax credit claims. Section 31(3)(f), Rule 47A and Rule 48 are relevant to compliance. Failure to generate prescribed e-invoices may create documentation and ITC disputes, although the underlying reverse charge liability remains payable. The amendment requires advance preparation by businesses already covered by GST e-invoicing.
The change in short
From 1 January 2027, businesses that already issue e invoices will also have to generate e invoices for two more kinds of documents: self invoices raised for purchases from unregistered persons under reverse charge, and self invoices for import of services.
This comes from Notification No. 04/2026 Central Tax dated 26 October 2026, issued under Rule 48(4) of the CGST Rules on the recommendation of the GST Council. It amends the main e invoice notification, No. 13/2020 Central Tax dated 21 March 2020.
First, what is an e invoice and who must issue it
An e invoice is not a new kind of bill. You prepare your invoice as usual, but before giving it, you upload its details to the government’s Invoice Registration Portal (IRP). The portal gives back a unique number (IRN) and a QR code. Only then is the invoice valid.
E invoicing applies to a registered person whose aggregate turnover in any financial year from 2017 to 18 onwards has crossed ₹5 crore. Some categories are kept out by the same notification, such as SEZ units, banking companies, NBFCs and insurance companies, goods transport agencies, passenger transport service providers and multiplex cinema admissions. Notification 04/2026 does not touch this turnover limit or these exclusions. It only adds new kinds of transactions for those who are already covered.
What changes on 1 January 2027
Until now, the e invoice notification applied only “in respect of supply of goods or services or both to a registered person or for exports”. That covered B2B sales and exports. Self invoices were outside it.
The amended wording now covers four things:
1. supply of goods or services or both to a registered person;
2. supply of goods or services or both for exports;
3. supply of goods or services or both received from an unregistered person, where the recipient pays tax under reverse charge; and
4. import of services.
Items 3 and 4 are new.
| Transaction | Till 31.12.2026 | From 01.01.2027 |
|---|---|---|
| Sale to a registered buyer (B2B) | E invoice | E invoice |
| Export | E invoice | E invoice |
| Purchase from unregistered person under reverse charge (self invoice) | Not required | E invoice |
| Import of services (self invoice) | Not required | E invoice |
| Sale to an ordinary consumer (B2C) | Not required | Not required |
In both new cases it is the buyer who prepares the document, because the seller is either unregistered or sitting abroad. So it is the buyer who will now have to upload it to the IRP.
Where you will meet this in daily business
Under Section 31(3)(f), when a registered person pays tax under reverse charge on a purchase from an unregistered person, he has to issue an invoice to himself. This is the self invoice. Some common cases in a company with turnover above ₹5 crore:
1. Fees paid to an individual advocate who is not registered under GST.
2. Sitting fees or other payments to directors.
3. Rent paid to an unregistered owner for a commercial building used for business.
4. Metal scrap bought from an unregistered person.
5. Subscription for software or cloud services bought from a foreign company.
6. Fees to a consultant or agency located outside India.
The first four are reverse charge purchases from unregistered persons. The last two are imports of services. Till now, the company prepared these self invoices in its books and reported the tax in GSTR 3B. From 1 January 2027, each such self invoice must also carry an IRN from the IRP.
What to do before January 2027
There are two months. That is enough time if you start now.
1. Make a list of every reverse charge expense and every foreign payment you make in a year. Most accounts teams know the big ones but forget the small ones, like a director’s sitting fee or a software subscription paid on a company card.
2. Speak to your software vendor. Your ERP or billing package must be able to send self invoices to the IRP and print the IRN and QR code on them. The GSTN is likely to issue an advisory on the schema for these documents; watch for it.
3. Fix one person responsible. Self invoices are usually raised at the month end in a rush. An e invoice that is not generated in time can lead to an invoice being treated as invalid, with penalty exposure and questions on ITC.
4. Keep your reverse charge payment, the self invoice and the ITC claim matching each other month by month.
The idea behind the change is simple. The department wants every reverse charge and import transaction to be visible on its system the day it happens, just like a normal B2B sale. For honest taxpayers it means a little more work at the start, and fewer mismatch notices later.
