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As per Rule 48(4) of CGST Rules, notified class of registered persons to have to prepare invoice by uploading specified particulars of invoice (in FORM GST INV-01) on Invoice Registration Portal (IRP) and obtain an Invoice Reference Number (IRN). After following the above ‘e-invoicing’ process, the invoice copy containing, among other things, the IRN (with QR Code) issued by the notified supplier to a buyer is commonly referred to as an ‘e-invoice’ in GST.
Because of the standard e-invoice schema (INV-01), ‘e-invoicing’ facilitates the exchange of the invoice document (structured invoice data) between a supplier and a buyer in an integrated electronic format. Please note that ‘e-invoice’ in ‘e-invoicing’ doesn’t mean the generation of invoices by a Government portal.
There is not much difference, indeed. Registered persons will continue to create their GST invoices on their Accounting/Billing/ERP Systems. These invoices will now be reported to ‘Invoice Registration Portal (IRP)’. On reporting, IRP returns the e-invoice with a unique ‘Invoice Reference Number (IRN)’ after digitally signing the e-invoice and adding a QR Code. Then, the Invoice can be issued to the receiver (along with QR Code). A GST invoice will be valid only with a valid IRN.
For Registered persons whose aggregate turnover (based on PAN) in any preceding financial year from 2017-18 onwards is more than the prescribed limit (as per relevant notification), e-invoicing is mandatory.
As per Rule 48(5), any invoice issued by a notified person other than the manner specified in Rule 48(4) shall not be treated as an invoice. So, the document issued by a notified person becomes legally valid only with an IRN.
E-invoice has many advantages for businesses, such as auto-reporting invoices into GST returns and auto-generation of the e-way bill (where required).
E-invoicing will also facilitate standardization and inter-operability, reducing disputes among transacting parties, improving payment cycles, reducing processing costs, and greatly improving overall business efficiency.
Businesses will continue to issue invoices as they are doing now. ERP/Accounting and Billing Software providers will make unnecessary changes to e-invoicing requirements (i.e. to enable reporting of invoices to IRP and obtain IRN) by ERP/Accounting and Billing Software providers in their respective software. They need to get the updated version having this facility.
When issued by notified class of taxpayers (to registered persons (B2B) or for Exports) are currently covered under e-invoice. Though different documents are covered, the system is referred to as ‘e-invoicing’ for ease of reference and understanding.
Supplies to registered persons (B2B), Supplies to SEZs (with/without payment), Exports (with/without payment), and Deemed Exports by notified class of taxpayers are currently covered under e-invoicing.
No. Currently, reporting B2C invoices by notified persons is not applicable/allowed currently.
No. A supply bill is issued in those cases and not a tax invoice.
No, only the credit and debit notes issued under Section 34 of the CGST/SGST Act have to be reported.
E-invoicing by notified persons is mandated to supply goods or services or both to a registered person. Thus, where the Government Department doesn’t have any registration under GST (i.e. not a ‘registered person’), e-invoicing doesn’t arise. However, where the Govt. department has a GSTIN (as an entity supplying goods/services/ deducting TDS), the same has to be mentioned as the recipient GSTIN in the e-invoice.
Yes. E-invoicing by notified persons is mandated to supply goods or services or both to a registered person. As per Section 25(4) of CGST/SGST Act, “A person who has obtained or is required to obtain more than one registration, whether in one State or Union territory or more than one State or Union territory shall, in respect of each such registration, be treated as distinct persons for this Act.”
No. These activities/transactions are neither supply of goods nor services, as per Schedule III of CGST/SGST Act.
E-invoice is not applicable for import Bills of Entry.
Yes. As per Foreign Trade Policy, Free Trade & Warehousing Zones (FTWZ) are only a special category of Special Economic Zones, focusing on trading and warehousing.
If the invoice issued by the notified person is in respect of supplies made by him but attracting reverse charge under Section 9(3), e-invoicing is applicable.
For example, a taxpayer (say, a Firm of Advocates having an aggregate turnover in an F.Y. is more than Rs. 500 Cr.) is supplying services to a company (who will be discharging tax liability as a recipient under RCM), such invoices have to be reported by the notified person to IRP.
On the other hand, where a notified person receives supplies from (i) an unregistered person (attracting reverse charge under Section 9(4)) or (ii) through the import of services, e-invoicing doesn’t arise/is not applicable.
On fulfilling prescribed conditions, the obligation to issue an e-invoice in Rule 48(4) (i.e. reporting invoice details to IRP, obtaining IRN and issuing an invoice with Q.R. Code) lies with the concerned taxpayer.
However, as a facilitation measure, all the taxpayers who had crossed the prescribed turnover in a financial year from 2017-18 onwards have been enabled to report invoices to IRP. One can search for the enablement of a GSTIN on the e-invoice portal: https://einvoice1.gst.gov.in/ > Search > e-invoice status of a taxpayer.
This listing of GSTINs is solely based on the turnover of GSTR-3B as reported to the GST System. It may contain exempt entities or those for whom e-invoicing is not applicable for some other reason. So, it may note that enablement status on the e-invoice portal doesn’t automatically mean that the taxpayer is supposed to do e-invoicing.
If e-invoicing does not apply to a taxpayer, they need not be concerned about the enablement status and may ignore it. Further, the turnover slab of taxpayers can also be ascertained through the “Search Taxpayer” / “Know Your Supplier” Sections on the GST portal. If any registered person is required to prepare an invoice in Rule 48(4) but is not enabled on the portal, they may request enablement: ‘Registration – > e-Invoice Enablement’.
It is difficult to make a precise list of taxpayers who are required to issue e-invoices, as the fulfilment of conditions prescribed for e-invoicing (e.g. crossing of a turnover threshold, exemptions, nature of supplies made etc.) is dynamic.
However, the eligible GSTINs and generating IRNs are published on IRP and updated periodically. Please visit https://einvoice1.gst.gov.in/Others/GSTINsGeneratingIRN.
Further, the onus is on the concerned taxpayer to check the conditions and follow the law. At the same time, the recipient shall confirm this fact with his suppliers, as the list may contain the names of exempt entities and who might have been shown as enabled for e-invoice.
Invoice Registration Portal (IRP) is the website for uploading/reporting invoices by the notified persons. Vide notification no. 69/2019-Central Tax dated 13.12.2019, ten portals were notified to prepare the invoice in Rule 48(4).
The first Invoice Registration Portal (IRP) is active and can be accessed at: https://einvoice1.gst.gov.in/. More portals will be made available in due course.
No signature (DSC) of the supplier not mandatory while reporting an e-invoice to IRP.
Yes, if such suppliers selling through an e-Commerce entity are otherwise notified and supposed to report invoices under Rule 48(4). For more details, please see this detailed document.
A system/utility to report e-invoice details in JSON format to IRP and to receive signed
Yes. Entities without ERP/Software solutions can use the free offline utility (‘bulk generation tool’) downloadable from the e-invoice portal. Through
Multiple modes are available so that taxpayers can use the best mode based on their needs:
Yes. It is possible. The offline utility (‘bulk generation tool’) serves this purpose. Further, the ERP or accounting systems used by large taxpayers can be designed so that they can report invoices in bulk to IRP.
So, IRN will be generated in sub-200 millisecond duration. The server capacity is robust enough to handle simultaneous uploads. Further, multiple IRPs will be made available to distribute the load of invoice registration.
No. IRP will only be a pass-through portal that performs prescribed validations on invoice data and generates IRN. It will not store or archive e-invoice data.
A localized mechanism to provide relaxation in such contingent situations is prescribed according to Rule 48(4) of CGST Rules. It reads as: “…Commissioner may, on the recommendations of the Council, by notification, exempt a person or a class of registered persons from issuance of invoice under this sub-rule for a specified period, subject to such conditions and restrictions as may be specified in the said notification.”
‘Schema’ means a structured template or format. ‘e-invoice’ schema is the standard format for electronic invoices. It is notified as ‘Form GST INV-1’.
E-Invoice Schema is based on PEPPOL/Universal Business Language (UBL) with certain customizations to cater to Indian business practices and legal requirements.
No. e-invoice schema is a single standard applicable to all businesses in the country. Many optional fields are available in the schema to cater to specific businesses and practices followed by industry and trade in India.
Invoice details in the prescribed schema (INV-01) have to be reported to IRP in JSON format. ‘JSON’ stands for JavaScript Object Notation. It can be a common language for systems/machines to communicate and exchange data.
As the ERP or Accounting software will generate it, taxpayers need not worry about it. This format is also used in the GST system for reporting all data to GST System.
Elements of an invoice internal to the business, such as the company logo etc., are not part of the e-invoice schema.
After reporting invoice details to IRP and receipt of IRN, at the time of issuing an invoice to a receiver (e.g., generating as PDF and printing a paper copy or forwarding via e-mail etc.), any further customization, i.e., insertion of company logo, additional text etc., can be made by respective ERP/billing/accounting software providers.
The limit is kept at 1000 presently. Will enhance it based on the requirement in the future.
The QR code will consist of the following key particulars of the e-invoice:
Yes. IRP can reject an invoice.
IRP will check whether the Invoice was already reported and exists in the GST System. (This validation is based on the combination of the Supplier’s GSTIN-InvoiceNumberTypeOfDocument-Fin.Year, which is also used for the generation of IRN). If the same Invoice (document) has already been reported earlier, IRP will reject it.
Will also perform Certain other key validations on the portal. In case of failure, registration of Invoice won’t be successful, IRN won’t be generated and will reject Invoice along with relevant error codes (which give an idea about reasons for rejection.)
IRP will return only the signed JSON. Will return No PDF. On receipt of signed JSON, the respective ERP or Accounting & Billing software system is to generate PDFs, if needed.
Upon successful registration of the invoice on IRP, it will return a signed e-invoice JSON to the supplier with IRN and QR Code.
The Invoice Reference Number (IRN) is unique (also known as hash) generated by the e-invoice system using a hash generation algorithm.
For every document, viz., an invoice or debit or credit note to be submitted on the e-invoice system, a unique 64-character Invoice Reference Number (IRN) shall be generated, which is based on the computation of hash of GSTIN of the supplier of a document (invoice or credit note etc.), Year, Document type and Document number.
This shall be unique to each Invoice and hence will be the unique identifier for each Invoice for the entire financial year in the entire GST System for a taxpayer.
There are two modes for the generation of IRN
No, only a unique invoice from a taxpayer will be accepted by the e-invoice system. The E-invoice system will check in the Central Registry of the GST system to ensure that the same Invoice from the same supplier for the same financial year is not being uploaded again to generate one more IRN.
Once the e-invoice system has validated and registered an IRN, it will be made available to the taxpayer for reference on the e-invoice system for only 24 hours.
Anyone can verify the authenticity or the correctness of an e-invoice by uploading the signed JSON file or Signed QR Code into the e-invoice system.
You can select ‘Verify Signed Invoice’ under the Search option, and then the signed JSON file can be uploaded and verified. Similarly, the QR Code Verify app may be downloaded and used to verify the QR Code printed on the Invoice.
Anyone can verify the authenticity or the correctness of an e-invoice by uploading the signed JSON file or Signed QR Code into the e-invoice system.
You can select ‘Verify Signed Invoice’ under the Search option, and then the signed JSON file can be uploaded and verified. Similarly, the QR Code Verify app may be downloaded and used to verify the QR Code printed on the Invoice.
The IRP has digitally or electronically signed the digitally signed Invoice after receiving the invoice details from the supplier. The government authenticates the genuineness of the taxpayer's invoice details submitted/registered.
The IRP has digitally or electronically signed the digitally signed Invoice after receiving the invoice details from the supplier. The government authenticates the genuineness of the taxpayer's invoice details submitted/registered.
The different supply types that can be reported are B2B: Business to Business, SEZWP: To SEZ with Payment, SEZWOP: To SEZ without Payment, EXPWP: Export with Payment, EXPOWAP: Export without Payment, DEXP: Deemed Export.
IRN is a unique 64-character hash, e.g.
35054cc24d97033afc24f49ec4444dbab81f542c555f9d30359dc75794e06bbe
Yes. Once the IRP returns the signed JSON, your ERP/Accounting/Billing System is into PDF and printed, if required. Businesses that don’t have their own ERP/Accounting Software will download and use the free offline utility (‘bulk generation tool’) to upload invoice data on the invoice portal and obtain signed invoices (in JSON). In this scenario also, there is a facility on the e-invoice portal to generate a ‘human-readable’ PDF copy of the invoice (for save/print/e – mail etc.).
No. It’s optional. IRN is anyway embedded in the QR Code, which is one of the mandatory particulars on the invoice.
The QR code is part of the signed JSON returned by the IRP. It is a string (not an image), which the ERP/accounting/billing software shall read and convert into a QR Code image for placing on the invoice copy.
Yes. The QR code (containing, among other things, the IRN), which comes as part of a signed JSON from IRP, shall be extracted and printed on the invoice. This is one of the mandatory particulars of invoices under Rule 46 of CGST Rules. However, the printing of QR codes on separate paper is not allowed. While the printed QR code shall be clear enough to be readable by a QR Code reader, the size and its place on the invoice are up to the businesses’ preference.
Where e-invoicing is applicable, there is no need to issue invoice copies in triplicate/duplicate. This is specified in Rule 48(6).
It depends on the ERP/Accounting/Billing Software providing you with the service. It can store the signed JSON on handheld devices, also.
However, signed invoice JSON will not be available for download from IRP or GST System. Hence, it is advisable to properly store the signed e-invoice received from IRP.
As per Rule 56(16) of CGST Rules, “Accounts maintained by the registered person together with all the invoices, bills of supply, credit and debit notes, and delivery challans relating to stocks, deliveries, inward supply and outward supply shall be preserved for the period as provided in section 36….” The same applies to e-invoicing also.
The penal provisions are provided in Section 122 of the CGST/SGST Act, read with CGST Rules.
Notification No. 14/2020-Central Tax dated 21st March 2020 (amended) mandates entities with aggregate turnover > Rs. Five hundred crores in any preceding financial year from 2017-18 onwards, to include a dynamic Quick Response Code (QR Code) on their B2C invoices. It is also specified that a Dynamic QR code made available to buy through a digital display (with payment cross-reference) shall have a QR code.
The Dynamic QR Code is not relevant to ‘e-invoicing,’ as envisaged under Rule 48(4). The said rule applies to B2B Supplies and exports by notified class of taxpayers.
Yes. Apart from the QR code relating to IRN, the Supplier is free to place any other QR code required as per business needs or otherwise mandated by any other statutory requirement. In such cases, the QR Codes need to be marked clearly to be distinguished easily.
No. IRP will not do this. Upon receiving signed JSON from the IRP, the supplier can share the e-invoice (along with QR Code, etc.) in the agreed format with the receiver.
A suggested mechanism may be to exchange the PDF of the JSON received from IRP (including the QR code) as the best-authenticated version of the e-invoice for business transactions.
However, a mechanism to enable system-to-system exchange of e-invoices through ecosystem partners will be made available.
No. As per Rule 138A(2) of CGST Rules, where e-invoicing is applicable, “the Quick Reference (QR) code having an embedded Invoice Reference Number (IRN) in it, may be produced electronically, for verification by the proper officer, instead of the physical copy of such tax invoice.”
Amendments are not possible on IRP. Any changes in the invoice details reported to IRP can be carried out on the GST portal (while filing GSTR-1). If GSTR-1 has already been filed, use the amendment mechanism provided under GST. However, will flag these changes to the proper officer for information.
Yes. Can trigger the cancellation request through the ‘Cancel API’ within 24 hours of reporting the invoice to IRP. However, if the connected e-way bill is active or verified by an officer during transit, cancellation of IRN will not be permitted. In case of cancellation of IRN, GSTR-1 also will be updated with such ‘cancelled’ status.
No. Once an IRN is cancelled, you cannot use the concerned invoice number again to generate another e-invoice/IRN (even within the permitted cancellation window). If it is used again, then the same will be rejected when it is uploaded on IRP. IRN is a unique string based on the Supplier’s GSTIN, Document Number, Type of Document & Financial Year.
No. It has to be cancelled. No partial cancellation of reported e-invoice allowed. The cancellation of invoices is governed by Accounting Standards and other applicable rules/regulations.
Yes. While transporting goods, wherever the e-way Bill is needed, the requirement continues to be mandatory.
Yes. On successful reporting of invoice details to IRP, the invoice data (payload), including IRN, will be saved in GST System. The GST system will auto-populate them into GSTR-1 of the supplier and GSTR-2A of respective receivers.
The source marked as ‘e-invoice’ will also show IRN and IRN date in GSTR-1 and GSTR-2A.
If both Part-A and Part-B of the e-Way Bill are provided while reporting invoice details to IRP, we will use them to generate the e-way Bill. In case Part-B details are not provided when reporting the invoice to IRP, the same will have to be provided by the user through the ‘e-way bill’ tab in IRP log in, or e-Way Bill Portal generate e-Way Bill.
