Mandatory GST E-Invoicing: Rules & Deadlines

A. Introduction:

To minimize GST Evasion and revenue leakage digitalization of standardization of documents issued to B2B Taxable supplies and Zero rated supplies have been implemented in phase manner starting from 1^st October, 2020 commonly known as “E-Invoice.

The registered taxpayers upload their Tax invoice/ Export Invoice including Debit Notes and Credit Notes details in the standard e-invoice schema to the Invoice Registration Portal (IRP) to generate an Invoice Reference Number (IRN) and obtain a digitally signed invoice with QR code.

B. Applicability and Thresholds:

1. E-invoicing is applicable PAN-wise (aggregate turnover across all GSTINs of a legal entity). From 1st August, 2023 Every registered Taxpayers whose aggregate turnover in any preceding financial year starting from FY 2017-18 exceeds Rs. 5 crores required to Generate E-Invoices. These thresholds were introduced in a phased manner:

2. E-Invoice will be applicable for All the GSTIN registered on the Same Pan [Other than SEZ units].

3. Once, E-Invoice gets applicable it stays applicable till the business GSTIN Exists.

C. Generation OF E-INVOICE:

1. Websites notified for the generation of E-Invoice: einvoice1.gst.gov.inand www.einvoice2.gst.gov.in 

2. Multiple modes will be made available so that taxpayer can use the best mode based on his/her need. The modes given below are envisaged at this stage under the proposed system for e-invoice, through the IRP (Invoice Registration Portal):

3. Pre-requisite for generation of e-invoice

The person who generates e-invoice should be a registered person on the GST portal and e-invoice system or e-way bill system. The documents such as tax invoice or debit notes or credit notes must be available with the person who is generating the e-invoice.

4. Time of Generation of E-Invoice:

> From 1^st April, 2025, taxpayers with aggregate annual turnover (AATO) of Rs. 10 crores restricted to generate E-Invoices beyond 30 days from the date of Tax Invoice/Debit Note/Credit Note. [Previously the limit was for taxpayers with aggregate annual turnover (AATO) of Rs. 100 crores]

> There is no change in the timing of generation E-invoice; it will be same as per section 31 and hence The best suggested practice to follow generation of E-Invoice in line with generation of Normal Tax Invoice/Debit Note/ Credit Note.

5. Printing of Invoice: –

The Registered Person can continue to print his paper invoice including logo and other information. E-invoice schema only mandates what will be reported in electronic format to IRP.

6. Cancellation/ Amendment: –

> E-Invoice generated once can be cancelled in entirety within 24 hours only.

> E-Invoice once generated cannot be updated/ modified. Relevant changes in accordance with the facts can be done while filing GSTR-1. Necessary documentation should be preserved for the scrutiny.

7. Verification and Authenticity:

The Authenticity of an E-invoice can be verified by uploading the signed JSON or scanning the QR code on the GST e-invoice system.

The system prevents duplicate IRNs; IRN cannot be generated for the same invoice document from the same supplier in a fiscal year.

8. Integration with GST Returns and E-way Bills:

> Details of e-invoices with IRN gets auto-populated in the GSTR-1 return.

> While filing GSTR-1, reconciliation of Invoices auto reflected v/s Invoices accounted in the Books must be done.

> E-Invoice has to be generated before the e-waybill. On the same line, if IRN is req. to be cancelled, the first e-way bill has to be cancelled and then IRN.

> It is not required to carry a physical copy of an e-invoice if the e-invoice with QR Code can be shown on a digital device i.e. mobile etc. to the proper officer.

9. Mandatory 2 factor Authentication.

D. Mandatory Fields of E-Invoice:

E. E-Invoice Generation on Invoices including Debit Notes and Credit Notes:

The Registered Taxpayer is required to generate E-invoices for Following Domestic Taxable Supplies made and Zero rated supplies effected:

1. Business-to-business (B2B) supplies [Includes Supply to Govt. Entity holding TDS registration, supplies where recipient is liable to discharge GST under RCM]

2. Supplies to SEZ developers with or without tax payment

3. Exports (B2B) with or without tax payment

4. Deemed exports

Note: E-Invoice Generation not applicable for B2C Taxable Supplies [Excluding Export], Nil-rated/Non-GST Supplies.

F. Entities not Required to Generate E-invoice:

1. Insurance companies

2. Banking companies (including NBFCs)

3. Goods Transport Agencies (GTAs)

4. Passenger transportation service providers

5. SEZ units

6. Multiplex theatres for film exhibition services

7. Government departments and local authorities

8. Persons rendering OIDAR services

9. Input Service Distributor

10. Any Person Whose aggregate turnover in any preceding financial year from 2017-18 onwards does not exceed Five Crore Rupees

Note: If SEZ and non-SEZ units exist under the same PAN and aggregate turnover exceeds threshold, e-invoicing applies only to non-SEZ units.

G. Non-Compliance Consequences:

> According to rule 48(5) of the CGST Rules, failure to generate an IRN (e-Invoice) will be considered as a ‘failure to issue an invoice’.

> Penalty for Contravention to the Supplier:

> Penalty on recipient for Receipt of the Goods with E-Invoice [Where Applicable]:

H. Key Take-aways:

1. Supplier:

> Integration of ERP/Accounting software to avoid errors.

> Generate IRN before issuing invoice and ensure embedding of QR Code. Keep backup of IRN invoices.

> Reconcile monthly with GSTR-1.

2. Recipient:

> Confirm vendor’s e-invoicing compliance.

> Verify QR code or signed JSON.

> Take supplier declaration [Wherever E-Invoices not generated] to safeguard ITC.

I. Conclusion:

E-invoicing under GST marks a pivotal shift toward digital accountability and streamlined compliance. With IRNs, QR codes, and auto-population in returns, it minimizes errors and enhances transparency. More than a regulatory tool, it fosters operational clarity, trust, and digital maturity. Businesses embracing this system early have found themselves future-ready, aligned with a vision of smarter governance and seamless tax ecosystems where every transaction contributes to a more transparent, efficient, and trustworthy GST framework.

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Disclaimer

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