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Yes, an Indian seller can sometimes take online goods orders without GST registration, but only under the narrow exemption created by Notification 34/2023-Central Tax. Your aggregate turnover must remain within the applicable section 22 threshold, you must make only intra-State goods supplies, use an electronic-commerce operator (ECO) in one State or Union territory, complete portal enrolment and obtain an enrolment number before the first supply. For each order, issue an ordinary commercial invoice or bill—not a GST tax invoice. Show the product, quantity, price, discount, delivery details and amount paid or due, but do not add a GST rate or GST amount. The exemption is conditional, does not cover every online business model, and must be reassessed when your geography, turnover or sales channel changes.
Can you invoice online orders without GST registration?
You can issue invoices without GST registration when you are an unregistered goods seller operating within the conditions of Notification 34/2023-Central Tax. The notification was issued on 31 July 2023 and took effect on 1 October 2023. It is a conditional waiver from mandatory registration, not a general permission for every online seller.
The rule is aimed at small suppliers of goods making intra-State sales through a qualifying ECO. It does not create a blanket exemption for services, for inter-State goods sales, or for every website and social-commerce arrangement. Before accepting an order, check the current registration threshold for your State or Union territory and whether the transaction and platform satisfy every condition.
What document should the customer receive?
Send a normal commercial invoice or bill for each order. It is evidence of a sale and payment obligation, not a GST tax invoice. A seller who is not registered should not print the words tax invoice, show a GST rate, add a separately collected GST amount, or suggest that the document gives the customer input-tax credit.
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Why is this different from a GST tax invoice?
Section 31 of the Central Goods and Services Tax law requires a registered person supplying taxable goods to issue a tax invoice before or at removal or delivery. Rule 46 lists the particulars of that registered-person invoice, including the supplier’s GSTIN and a consecutive serial number. Those provisions explain why an unregistered seller should use a commercial sales document instead of imitating a registered taxpayer’s invoice.
What conditions does Notification 34/2023 require?
The exemption has eight linked conditions. Missing one can remove the protection, so treat the list as a pre-sale eligibility check rather than a formality.
- Stay within the applicable threshold. Your aggregate turnover must remain within the section 22 registration threshold that applies to your State or Union territory and circumstances. Thresholds and later amendments can differ by jurisdiction and business category; verify the current position before relying on the exemption.
- Sell goods, not services under this notification. The measure concerns suppliers of goods using an ECO. A service business needs a separate GST analysis.
- Make no inter-State supply of goods. Notification 34/2023 expressly says that eligible persons shall not make any inter-State supply of goods. A buyer, delivery address or supply that crosses a State or Union territory boundary requires reassessment.
- Use an ECO in only one State or Union territory. The notification does not permit the same unregistered supplier to use an ECO in more than one State or Union territory under this procedure.
- Have a PAN. The PAN is used for the enrolment and validation process.
- Declare your details on the common portal. Provide your PAN, business address and the State or Union territory from which you intend to make supplies.
- Pass portal validation. The declared information must be successfully validated through the common portal.
- Obtain an enrolment number before supplying. No goods may be supplied through the ECO until the portal has granted the enrolment number. The notification specifically prohibits making a supply before that number is issued.
The GST Council meeting record describes the 2023 notifications as creating a waiver and a special procedure for unregistered goods suppliers and composition taxpayers using ECOs. A government year-end release likewise describes the reform as facilitating intra-State goods supplies through ECOs for small taxpayers. Neither statement turns the exemption into a universal online-selling licence.
Does the exemption cover your online sales channel?
It is safest to separate a qualifying marketplace arrangement from a direct online shop. Notification 34/2023 specifically addresses goods supplied through an ECO, while a seller’s own website or social channel may involve a different legal and payment structure. Do not assume that putting a product catalogue online automatically qualifies.
Marketplace or other ECO
A marketplace is the clearest use case for the notification, provided it supports the unregistered-seller enrolment process and you operate in one State or Union territory only. Confirm the platform’s current onboarding policy before listing products: the notification does not require every ECO to accept unregistered sellers, and platform procedures can change.
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Your own website or social channel
A direct website or social-media sale must be analysed on its own facts. Determine whether the channel is an ECO under the GST law, who collects the customer’s consideration, where the supply is made, and whether you are actually using the notification’s marketplace procedure. If those answers are unclear, obtain professional advice before advertising the exemption.
Questions to compare before choosing a route
- Geography: Can every order remain intra-State, or will your catalogue invite orders from another State or Union territory?
- Consideration: Does the operator collect the customer’s money, or do you receive it directly?
- Onboarding: Does the operator have a documented process for declaring PAN, address and intended State and for recording the enrolment number?
- Settlement reporting: Will you receive order, return, refund and tax-collected-at-source (TCS) reports that can be reconciled?
- Returns: How will cancellations, reverse logistics and refunds be shown in your order file?
- Registration trigger: What happens if turnover rises above the applicable threshold, you add a State, or your model changes?
What should a non-GST commercial invoice contain?
Build one clear sales document for every order. The following fields give the buyer and your records enough information without pretending that GST has been charged.
| Invoice field | What to show | Why it matters |
|---|---|---|
| Seller identity | Your legal or trading name and business address | Identifies the person who made the sale and matches the portal declaration. |
| Buyer identity | Customer name and delivery address | Connects the document to the specific order and destination. |
| Document number | A unique invoice or order number | Lets you match the invoice to the marketplace order, payment and shipment. |
| Issue date | The date the invoice or bill is issued | Creates a chronological sales record. |
| Product description | A plain-language description of each good | Shows exactly what was supplied. |
| Quantity and unit price | Units sold and price per unit | Makes the calculation checkable. |
| Discounts | Any order, coupon or line-item discount | Explains how the final amount was reached. |
| Shipping or delivery charge | Freight or delivery amount, if charged | Separates delivery from the product price. |
| Total amount | Total paid or total due | States the customer’s actual commercial obligation. |
| Payment status and method | Paid, partly paid or due, plus the payment method | Supports settlement and refund reconciliation. |
| Returns terms | Your applicable cancellation, return and refund terms | Gives the customer the conditions that apply after delivery. |
What must be left off?
- Do not show a GST percentage or a GST rupee amount.
- Do not label the document GST tax invoice or imply that it supports input-tax credit.
- Do not invent or display a GSTIN. An enrolment number is a different identifier and is not a GST registration number.
- Do not describe marketplace TCS deducted from your settlement as GST charged to the customer on your invoice.
You may add a short, accurate note such as: Seller is not registered under GST; this is a commercial invoice and no GST has been charged. Keep the wording factual and avoid claiming that the buyer can claim credit.
How do you invoice an order step by step?
Use the following workflow for each new selling cycle and repeat the eligibility checks whenever your business changes.
- Check eligibility before accepting orders. Confirm your aggregate turnover against the current State or Union territory threshold. Confirm that the goods will be supplied only within that State or Union territory and that your chosen ECO supports the unregistered-seller process.
- Complete enrolment first. On the common portal, declare your PAN, business address and intended State or Union territory. Wait for successful validation and the enrolment number. Do not dispatch or otherwise supply goods through the ECO before the number is granted.
- Configure your order system. Set the document type to Invoice or Bill, not GST Tax Invoice. Add the seller and buyer fields, item details, discounts, shipping, total, payment status and return terms listed above. Disable any automatic GST-rate or GST-amount line.
- Issue one document per order. Give the buyer the invoice with the order confirmation or shipment notice. Use a unique number that your team can match to the platform order and payment settlement.
- File the supporting records. Store the invoice, order confirmation, payment settlement, shipping proof, returns, refunds and marketplace reports together. This file is the evidence you need to reconcile turnover and identify a condition that has stopped being true.
- Reconcile after settlement. Compare the amount shown as paid by the buyer with the operator’s settlement, deductions, refunds and TCS entries. Resolve mismatches before closing the period.
- Recheck at every expansion point. Pause and reassess before adding another State, shipping across a State boundary, joining a second ECO in another State or Union territory, crossing the threshold, or changing from goods to services.
How does marketplace TCS affect your invoice?
Tax collected at source (TCS) is an amount an ECO collects on the net value of taxable supplies when it collects the customer’s consideration. It is a settlement and reporting item, not a GST line that an unregistered seller should pass through to the customer.
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The GST Council Law Committee FAQ updated 30 November 2018 states a notified rate of 0.5% under the CGST Act plus 0.5% under the SGST or UTGST Act for intra-State supplies, or 1% under the IGST Act. The ECO must be registered for this TCS mechanism. Rates and procedures can be amended, so verify the current notification and the operator’s statement for the period you are reconciling.
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| Supply shown in the FAQ | Rate structure stated by the GST Council FAQ | Where you use it |
|---|---|---|
| Intra-State supply | 0.5% CGST plus 0.5% SGST or UTGST | Reconcile the deduction in the ECO settlement report; do not add it as GST on your commercial invoice. |
| Inter-State supply | 1% IGST | An inter-State goods supply is also outside the Notification 34/2023 exemption, so do not rely on this rate to continue unregistered selling. |
For each settlement, match gross orders, cancellations, returned goods, refunds, platform fees and TCS entries to your own order file. If the platform’s report uses a different period or netting method, retain both reports and document the reconciliation rather than changing the customer invoice to force a match.
What happens when an order crosses a State boundary?
Cross-border shipping within India is the most important warning sign. The notification says an eligible person shall not make any inter-State supply of goods. The fact that a marketplace arranged the courier, collected payment or delivered the parcel does not remove that condition.
Illustrative compliant pattern
A seller located in State A stays below the applicable threshold, completes portal enrolment for State A, uses one ECO and accepts only deliveries whose supply remains within State A. The seller issues commercial invoices without GST and keeps the order, shipment and settlement records together.
Illustrative non-compliant change
The same seller later accepts an order requiring supply to State B, joins an ECO account tied to another State, or keeps selling after crossing the threshold. Before taking that order, the seller should stop relying on the exemption and obtain professional advice on registration, invoicing and any resulting tax obligations. Do not backdate an enrolment number or add a GST amount to an old commercial invoice without a lawful basis.
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When should you switch to GST registration?
Registration becomes a live issue when your aggregate turnover exceeds the applicable threshold, when you begin inter-State goods supplies, when you use an ECO in a second State or Union territory, or when you can no longer maintain the portal-enrolment conditions. A change from goods to services also requires a fresh analysis because this notification is specifically about goods.
Plan the transition before the first transaction that breaks a condition. Ask a tax professional to confirm the effective date, marketplace onboarding steps, tax-invoice format, pricing and treatment of existing orders. Once registered, the section 31 and Rule 46 tax-invoice framework applies, including the registered supplier’s GSTIN and the other prescribed particulars.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What are the most common invoicing mistakes?
- Calling a bill a tax invoice: Rename the template and remove GST-specific labels while you are unregistered.
- Adding GST because the buyer asks: You cannot turn a commercial bill into a GST tax invoice by typing a percentage. Register first if your business needs to charge GST lawfully.
- Using the marketplace’s GSTIN: The operator’s registration does not make you a registered supplier and cannot replace your own GSTIN.
- Supplying before enrolment: Listing or dispatching before the enrolment number is granted conflicts with the notification’s explicit timing condition.
- Ignoring the delivery State: A buyer’s location and the actual supply can create an inter-State transaction even when your warehouse and marketplace account stay in one State.
- Treating TCS as customer GST: TCS is deducted and reported by the ECO; it is not a tax line to print on your unregistered commercial invoice.
- Losing the audit trail: A PDF invoice without the order, payment, shipment and refund records makes threshold and turnover checks unreliable.
- Assuming every platform accepts this model: The notification does not guarantee marketplace onboarding. Confirm the operator’s current policy and technical fields before taking paid orders.
How should you maintain records and review the arrangement?
Keep a single order file or linked digital record for each sale. At minimum, retain the commercial invoice, order confirmation, payment or cash-on-delivery status, shipping proof, delivery address, return or refund evidence, ECO settlement and TCS report. Use the same unique order or invoice number across those records.
Review the file at regular closing intervals and whenever a new product, warehouse, courier route, marketplace or payment method is introduced. Recalculate aggregate turnover using the records rather than relying only on the marketplace dashboard. A dashboard can omit cancelled orders, refunds or settlements posted in a later period.
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The exemption and the 2018 TCS FAQ are not substitutes for checking later amendments, product-specific restrictions, the current State or Union territory threshold, or the ECO’s present seller policy. Treat those checks as part of your operating procedure, especially before an expansion.
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What is the practical bottom line for an unregistered online seller?
Use the exemption only when every condition is demonstrably satisfied: goods, threshold compliance, one-State intra-State supplies, a qualifying ECO, PAN and portal declarations, successful validation, and enrolment before the first supply. Issue a plainly labelled commercial invoice with no GST amount, reconcile the ECO’s settlement and TCS reports, and reassess before any inter-State sale, second-State ECO activity, threshold crossing or business-model change.
Frequently Asked Questions
Can I put the enrolment number in the GSTIN field on my invoice?
No. The enrolment number only records your permission to supply under the special unregistered-seller procedure; it is not a GST registration number. Keep it in your internal and marketplace records, and do not label it as GSTIN on a customer invoice.
Can I sell services using the same no-registration online invoicing rule?
Notification 34/2023 is framed for suppliers of goods through an ECO. Services can have different registration rules and thresholds, so a service invoice should be assessed separately rather than copied from this goods workflow.
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If a marketplace ships to another State for me, does that remain intra-State?
The logistics provider or marketplace does not decide the exemption by itself. If the supply is inter-State, the notification’s condition is not met, even when the platform collected payment and arranged delivery; obtain advice before accepting that order.
Are the marketplace TCS percentages permanent?
The 0.5% plus 0.5% intra-State structure and 1% IGST figure come from the GST Council Law Committee FAQ updated 30 November 2018. Check current notifications and the operator’s settlement statement because rates and reporting procedures can be amended.
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