e-Invoicing under GST refers to the electronic authentication of invoices. Similar to how GST-registered businesses generate e-way bills for the movement of goods, certain registered taxpayers are required to create e-invoices in India. When a GST invoice or credit/debit note is verified by the GSTN-approved Invoice Registration Portal (IRP), it becomes an e-invoice. This system has become an essential compliance requirement for many businesses under GST.
Key Takeaways
- e-Invoice Threshold Limit: Mandatory e-invoicing applies to businesses with an annual turnover exceeding ₹5 crore. This provision has been in force from August 1, 2023, as per GST Notification 10/2023.
- e-Invoice Time Limit: Effective April 1, 2025, businesses with an Annual Aggregate Turnover (AATO) above ₹10 crore must upload invoices to the IRP within 30 days.
- It helps curb fake GST invoices, ensuring that only legitimate input tax credit claims are made.
What is e-Invoicing under GST?
e-Invoicing, or electronic invoicing, is a mechanism where B2B invoices and select other documents are digitally authenticated by the GSTN through the common e-invoicing portal. It does not require businesses to create invoices on the government portal; instead, they must upload their already-prepared invoices in the prescribed format. This enables seamless reporting by entering invoice details only once.
The GST Council first approved the introduction of e-invoicing during its 35th meeting on June 21, 2019. Initially rolled out for large companies, the system now extends to smaller enterprises as well. Once submitted, invoice data flows automatically to both the GST portal and the e-way bill system in real time, removing the need for manual entry while filing GSTR-1 or generating the Part-A of e-way bills.
Who Must Generate an e-Invoice?
The requirement to generate e-invoices is determined by a taxpayer’s Aggregate Annual Turnover (AATO) in a financial year. The e-invoicing threshold limits are outlined below:
Turnover Criteria / e-Invoice Limit
| Phase | Applicable to taxpayers with turnover above | Effective from | Notification No. |
| I | ₹500 crore | 01.10.2020 | 61/2020 – Central Tax, 70/2020 – Central Tax |
| II | ₹100 crore | 01.01.2021 | 88/2020 – Central Tax |
| III | ₹50 crore | 01.04.2021 | 5/2021 – Central Tax |
| IV | ₹20 crore | 01.04.2022 | 1/2022 – Central Tax |
| V | ₹10 crore | 01.10.2022 | 17/2022 – Central Tax |
| VI | ₹5 crore | 01.08.2023 | 10/2023 – Central Tax |
If a business stays below the applicable limit in the previous financial year but crosses it in the current year, e-invoicing becomes mandatory from the start of the next financial year. For instance, taxpayers whose AATO exceeds the applicable limit in FY 2024–25 must follow e-invoicing rules from FY 2025–26. The threshold is calculated based on the total turnover of all GSTINs under one PAN across India.
Where to Generate e-Invoices?
The CBIC has specified common portals for generating e-invoices through Notification No. 69/2019 – Central Tax.
Under this system, each invoice is assigned a unique identification number by an Invoice Registration Portal (IRP), operated by the GSTN. A total of six IRPs are available. The first IRP was launched by NIC at einvoice1.gst.gov.in, followed by einvoice2.gst.gov.in.
Transactions & Documents Covered Under e-Invoicing
The following documents and transactions fall under the scope of e-invoicing:
Documents
- Tax invoices
- Credit notes and debit notes under Section 34 of the CGST Act
Transactions
- B2B taxable supplies of goods or services
- B2G taxable supplies
- Exports and deemed exports
- Supplies to SEZ (with or without tax)
- Stock transfers or services supplied to distinct persons
- Supplies to SEZ developers
- Supplies notified under reverse charge as per Section 9(3) of the CGST Act
Exclusions from e-Invoicing
Regardless of turnover, the following registered persons are currently exempt from e-invoicing as per Notification No. 13/2020 – Central Tax (with amendments):
Notified Businesses
- Insurers, banks, and financial institutions, including NBFCs
- Goods Transport Agencies (GTA)
- Providers of passenger transportation services
- Businesses offering admission to cinema screenings in multiplexes
- SEZ units (as excluded by Notification 61/2020 – Central Tax)
- Government departments and local authorities (excluded under Notification 23/2021 – Central Tax)
- Persons registered under Rule 14 of CGST Rules (OIDAR services)
Documents Not Covered
- Delivery challans
- Bills of supply
- Financial or commercial credit/debit notes
- Bills of entry
- ISD invoices
Excluded Transactions
- B2C supplies
- Exempt, nil-rated, or non-taxable B2B and B2G supplies
- Imports, high sea sales, and bonded warehouse sales
- FTWZ transactions
- Reverse charge supplies under Section 9(4) of the CGST Act
Time Limit to Generate e-Invoice
According to the GSTN advisory issued on 5 November 2024, the 30-day time limit for reporting e-invoices has been extended for taxpayers with AATO of ₹10 crore and above. This rule will apply from 1 April 2025 to ensure adequate preparation time.
Timeline of e-Invoice Reporting Requirements
| Period | Reporting Requirement | Applicability (AATO Threshold) |
| Till 30 Apr 2023 | No fixed deadline for reporting e-invoices | All taxpayers under e-invoicing |
| 1 May 2023 – 31 Oct 2023 | Government proposed a 7-day limit (not enforced) | AATO ≥ ₹100 crore (kept in abeyance) |
| From 1 Nov 2023 | Mandatory reporting within 30 days | AATO ≥ ₹100 crore; extended to AATO ≥ ₹10 crore from 1 Apr 2025 |
Process of Getting an e-Invoice
Under the e-invoicing framework, the method of generating and uploading invoice information remains unchanged. Invoice details can be imported through an Excel tool/JSON file or via API integration, either directly or through a GST Suvidha Provider (GSP). Once uploaded, the data flows automatically for preparing GSTR-1 and generating e-way bills. The e-invoicing system is central to enabling this automated process.
Below are the steps involved in implementing e-invoicing and generating an e-invoice:
Step 1: Update ERP to Match the e-Invoice Format
The taxpayer must ensure that the ERP system is updated according to the PEPPOL standards. This may require coordinating with software providers to incorporate the prescribed e-invoice schema and include all mandatory fields specified by the CBIC.
Step 2: Select the Method for IRN Generation
Taxpayers can choose between two primary methods:
- Whitelist the computer system’s IP address on the e-invoice portal and integrate directly via API.
- Use the bulk generation tool to upload multiple invoices at once. The tool will create a JSON file, which can then be uploaded to the e-invoice portal to generate IRNs in bulk.
Step 3: Upload Invoice Details to the IRP
After choosing the preferred method, the invoice must be created through the ERP or billing software. All required details—such as billing name and address, supplier GSTIN, transaction value, item details, applicable GST rate, and tax amounts—must be entered. From 1 April 2025, all taxpayers must use 2FA for both e-invoice and e-way bill generation.
Once ready, the invoice data must be uploaded to the IRP via JSON, application service provider, GSP, or direct API. The IRP serves as the main registrar for invoice authentication and supports multiple modes of interaction, including SMS and mobile apps.
Step 4: IRP Verification of Invoice
The IRP validates the essential invoice details, checks for duplicates, and generates an Invoice Reference Number (IRN). The IRN is generated based on four parameters: the supplier’s GSTIN, invoice number, financial year (YYYY-YY), and document type (INV/DN/CN).
The IRP then digitally signs the invoice, assigns the IRN, and provides a QR code in the Output JSON. If an email address is included in the invoice, the seller receives a notification of successful e-invoice generation.
Step 5: Sharing of e-Invoice Information
Once authenticated, the IRP forwards the invoice details to the GST portal for return filing. If relevant, the data is also sent to the e-way bill portal. The information auto-populates the supplier’s GSTR-1 for the appropriate tax period, helping determine tax liability.
FAQs on e-Invoicing under GST
1. Can an e-invoice be cancelled partially or fully?
An e-invoice cannot be cancelled in parts; it can only be cancelled entirely. Once cancelled, it must be reported to the IRN system within 24 hours. After this window, cancellation is no longer allowed on the IRN portal, and the taxpayer must cancel it manually on the GST portal before filing returns.
2. Is there a facility to generate e-invoices on the common GST portal?
No. Businesses must create invoices using their own ERP or billing software. These invoices should comply with the prescribed e-invoice schema and include all mandatory fields. The government currently has no plan to enable direct invoice creation through the common GST portal.
3. What types of documents need to be reported to the IRP?
Suppliers must report tax invoices, credit notes, and debit notes issued under GST law, along with any other documents specifically notified by the government, to the IRP for e-invoice generation.
4. Why is e-invoicing mandatory?
Eligible businesses must generate e-invoices to officially notify supply transactions to the government. Any invoice issued without a valid IRN is treated as invalid under GST and is considered as “not issued” according to Rule 48(5) of the CGST Rules. This may lead to penalties for non-compliance.
5. What is the turnover limit for mandatory e-invoicing?
Taxpayers with an Annual Aggregate Turnover (AATO) of ₹5 crore or more are required to issue e-invoices from 1 August 2023 onwards.
6. What are the available modes for generating e-invoices?
Businesses can generate e-invoices through several methods, including:
- Web-based IRP portals
- Direct API integration or via a GST Suvidha Provider (GSP)
- Uploading JSON or Excel files
- Mobile app or SMS-based submission
- Offline utilities for data entry
- Third-party GSP software solutions
These options allow businesses to choose a mode that suits their systems and operations.
7. Who is required to follow e-invoicing rules?
Under the sixth phase of implementation, any business whose turnover exceeds ₹5 crore in any financial year from 2017–18 onwards must generate e-invoices. Turnover across all GSTINs under a single PAN is aggregated for this calculation.
8. Is e-invoicing compulsory for businesses with ₹5 crore turnover?
Yes. Businesses crossing the ₹5 crore threshold in any year from 2017–18 onward must comply, unless they fall under the list of exempted categories.
9. Can an e-invoice be generated for an unregistered recipient?
No. Only GST-registered suppliers can generate e-invoices, and they are applicable mainly for B2B transactions with registered recipients. Supplies made by unregistered persons, even under reverse charge, do not require e-invoicing.
10. Who is exempt from issuing e-invoices?
The following taxpayers are exempt:
- Insurance companies, banks and financial institutions, including NBFCs
- Goods Transport Agencies (GTA)
- Registered persons providing passenger transport services
- Registered persons offering admission to cinematographic films in multiplexes
- SEZ units (as per Notification No. 61/2020 – CT)
- Government departments and local authorities (Notification No. 23/2021 – CT)
- OIDAR service providers registered under Rule 14
11. What is the 7-day (now updated) time limit for generating e-invoices?
Earlier, taxpayers with AATO of ₹100 crore or more were required to generate e-invoices within 7 days of invoice issuance. This rule was deferred. From 1 November 2023, a 30-day reporting window has been mandated for these taxpayers for submitting invoices, credit notes, and debit notes to any IRP.
12. Can an e-invoice be amended after IRN generation?
An e-invoice cannot be edited after the IRN is generated. Any corrections must be made by issuing a credit note, debit note, or cancelling the invoice (within the permitted time).
13. Is e-invoicing required for B2C supplies?
No. E-invoicing is currently applicable only for B2B, B2G, and export documents. B2C invoices do not require IRN generation.
14. What happens if an e-invoice fails IRP validation?
If an e-invoice is rejected by the IRP due to incorrect or incomplete data, the taxpayer must correct the details in their ERP and resubmit it for IRN generation.
15. Is an e-invoice required for delivery challans?
No. Delivery challans are not part of the e-invoice system unless specifically notified in future.
