India e-Invoicing Guide

India requires GST-registered businesses whose aggregate turnover exceeded Rs 5 crore in any preceding financial year from 2017-18 to register their B2B invoices, credit notes and debit notes on an Invoice Registration Portal before issuing them. The portal returns an Invoice Reference Number (IRN) and a digitally signed QR code. Supplies to registered persons, including SEZs, and exports are in scope.

The mandate began on 1 October 2020 for taxpayers with aggregate turnover above Rs 500 crore and has stood at Rs 5 crore since 1 August 2023. There is no separate B2G regime, and B2C invoices are not reported, although large suppliers must include a Dynamic QR code on them.

E-invoicing started on 1 October 2020 at Rs 500 crore, then the threshold fell to Rs 100 crore on 1 January 2021, Rs 50 crore on 1 April 2021, Rs 20 crore on 1 April 2022, Rs 10 crore on 1 October 2022 and Rs 5 crore on 1 August 2023. Since 1 April 2025, taxpayers with annual aggregate turnover of Rs 10 crore and above cannot report a document older than 30 days. On 8 October 2026 the 57th GST Council recommended extending e-invoicing to reverse charge supplies received from unregistered persons and to imports of services; this is a recommendation, not law. It has not yet been notified, and no date has been set.

Under CGST Rule 48(4) and Notification 13/2020-Central Tax as amended, the turnover test is aggregate turnover exceeding Rs 5 crore in any preceding financial year from 2017-18. Supplies to a government body fall under the same B2B rule when the body holds a GST registration, including one held only to deduct tax at source, per Circular 198/10/2023-GST.

Some taxpayers are outside e-invoicing altogether: insurers, banks and other financial institutions including NBFCs, goods transport agencies, and suppliers of passenger transport or multiplex cinema admission, by reference to CGST Rule 54. Special Economic Zone units are exempt, though SEZ developers remain in scope, and government departments and local authorities do not have to e-invoice their own supplies. B2C invoices are not reported; since 1 December 2020, suppliers whose aggregate turnover exceeded Rs 500 crore in any preceding financial year from 2017-18 must include a Dynamic QR code on them under Notification 14/2020-Central Tax, as amended by Notification 71/2020-Central Tax.

India follows a clearance model. The supplier sends invoice data in JSON under the e-invoice schema (INV-01) to one of the Invoice Registration Portals, run by NIC and private operators. The portal validates the data, checks for duplicates and returns an IRN with a digitally signed QR code.

Under CGST Rule 48(5), an invoice issued without following this procedure is not treated as an invoice. The data then flows to GSTR-1 and the e-way bill system. The portals validate and return documents but do not archive them, so the taxpayer keeps accounts and records for 72 months from the due date of the annual return, under section 36 of the CGST Act.

Penalties sit in the CGST Act rather than in e-invoicing rules. Failing to issue an invoice as the Act and its rules require falls under section 122, and a missing Dynamic QR code on B2C invoices falls under the general penalty in section 125. The 57th GST Council recommended cutting the section 125 maximum, which needs an amendment to the Act before it takes effect.