E-Invoicing Under GST explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
E-invoicing applies to registered businesses whose aggregate turnover in any year since 2017-18 has crossed Rs. 5 crore, for their invoices to registered buyers, exports and similar documents. The invoice is still created in your own software. The e-invoice step is reporting it to the government portal and getting an Invoice Reference Number (IRN). This article covers who is caught, who is out, and the post-IRN rules that cause most practical problems.
Under Rule 48(4), a class of registered persons notified by the Government must prepare invoices by uploading FORM GST INV-01 data to the Invoice Registration Portal and obtaining an IRN. The notified limit now stands at aggregate turnover above Rs. 5 crore in any preceding financial year from 2017-18. Under Rule 48(5), an invoice issued in any other manner by such a person is not treated as an invoice. An e-invoice can be cancelled on the portal within 24 hours.
Who must issue e-invoices
The Background Material records a staggered roll-out by turnover:
| Aggregate turnover exceeding | Effective from | Notification |
|---|---|---|
| Rs. 500 crore | 01.10.2020 | 13/2020-CT and 61/2020-CT |
| Rs. 100 crore | 01.01.2021 | 88/2020-CT |
| Rs. 50 crore | 01.04.2021 | 05/2021-CT |
| Rs. 20 crore | 01.04.2022 | 01/2022-CT |
| Rs. 10 crore | 01.10.2022 | 17/2022-CT |
| Rs. 5 crore | 01.08.2023 | 10/2023-CT |
The test is turnover in any preceding financial year from 2017-18 onwards, not only the last year. Once you cross the limit you stay in, even if turnover later falls. Because e-invoice data feeds your monthly outward-supply statement, it is worth aligning it with your GST return filing calendar from day one. Aggregate turnover is worked out on a PAN basis across India, as explained in aggregate turnover and its computation.
E-invoices cover supplies to registered persons (B2B), supplies to government (B2G), exports, reverse-charge invoices, and credit and debit notes. Business-to-consumer invoices are not reported for an IRN at present. If you want the full threshold history, see the e-invoice thresholds post.
Who is excluded
The following are not required to issue e-invoices:
- insurers, banking companies and financial institutions including NBFCs (Rule 54(2));
- goods transport agencies (Rule 54(3));
- passenger transport service providers (Rule 54(4));
- multiplex cinema operators (Rule 54(4A));
- SEZ units;
- government departments and local authorities;
- persons registered under Rule 14 (OIDAR).
Circular 186/18/2022-GST clarifies that the exemption applies to the entity as a whole. A bank that also supplies bullion does not have to e-invoice that supply. Note the opposite case in Circular 198/10/2023-GST: government bodies registered only for TDS under section 51 are treated as registered persons, so a supplier above the limit must e-invoice supplies made to them.
How it works, and what "not an invoice" means
The supplier prepares the invoice in his own system in the standard schema and uploads it to the portal. The portal validates key details, checks for duplicates, generates the IRN, digitally signs the invoice and returns a QR code. The Background Material stresses that an e-invoice is valid only with an IRN.
Rule 48(5) is the sharp edge: an invoice issued by such a person without going through this route is not an invoice. The buyer cannot claim credit on it. That is why the clause (s) declaration in Rule 46 exists for persons who say they are not covered. See Rule 48(5) in detail. Rule 48(6) removes the triplicate or duplicate copy requirement for e-invoices, and no signature is needed on an electronic invoice.
What happens after the IRN
- Cancellation: a document can be cancelled on the portal within 24 hours. The cancellation flows to GST system and a saved record in GSTR-1 is deleted.
- Flow to GSTR-1: reported documents reach the GST system automatically within two days and appear in GSTR-1 tables such as B2B, exports and credit or debit notes, with the source shown as e-invoice and the IRN details.
- Return period follows the document date: not the date of reporting.
- Editing: if you edit an auto-populated record in GSTR-1, the source, IRN and IRN date fields are removed and the record is treated as uploaded separately. Edit only if the record differs from the document you actually issued.
- E-way bill: details can also be forwarded to the e-way bill portal. No physical copy of the invoice needs to accompany goods; the QR code with IRN can be produced electronically (Circular 160/16/2021-GST). See e-invoice and e-way bill auto-population.
Illustration: an invoice dated 28 November 2026 is reported on the portal on 5 December 2026. If GSTR-1 for November has not yet been filed, it appears in the November GSTR-1 because the document date decides the period. If the November GSTR-1 was already filed, it does not auto-populate later and can be downloaded from the GSTR-1 dashboard for that period.
The 30-day reporting limit
Under a GSTN advisory dated 5 November 2024, from 1 April 2025 taxpayers with aggregate turnover of Rs. 10 crore and above cannot report e-invoices older than 30 days from the date of reporting. This applies to invoices, credit notes and debit notes. The Background Material's own example: an invoice dated 1 April 2025 cannot be reported after 30 April 2025. It adds that there is no such restriction for those below Rs. 10 crore "as of now". This limit comes from an advisory and portal validation, not from the wording of Rule 48.
Need help with e-invoicing and returns?
Businesses often find problems only when GSTR-1 does not match their books, because an edited invoice lost its IRN tag or a late invoice missed the reporting window. Our team can look at how your software reports to the portal and tie it to your returns through GST return filing support. For the outward-supply statement itself, see GSTR-1 filing.
Key takeaways
- E-invoicing applies where aggregate turnover exceeded Rs. 5 crore in any year from 2017-18.
- Banks, NBFCs, GTAs, passenger transport, multiplexes, SEZ units, government bodies and OIDAR are excluded.
- An invoice issued outside the prescribed route by a covered person is not an invoice (Rule 48(5)).
- Cancellation on the portal is possible within 24 hours.
- From 1 April 2025, taxpayers at Rs. 10 crore and above cannot report invoices older than 30 days.
Read next
- Tax invoice contents and time limit: Rules 46 and 47
- GSTR-1A: amend GSTR-1 before filing GSTR-3B
- The Rule 46(s) declaration
- Credit note under section 34
Disclaimer: Positions stated as on 30 September 2026, based on the CGST and IGST Acts and Rules as amended, the Finance Act 2026, and the ICAI Background Material on GST (14th Edition, July 2026). Verify current notifications before acting.