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India’s GST e-invoicing system requires eligible suppliers to report specified invoices, debit notes and credit notes to an Invoice Registration Portal (IRP). The portal validates the data, assigns an Invoice Reference Number (IRN) and returns a digitally signed QR code. It is therefore more than creating a PDF or emailing an invoice.
The current general turnover threshold is ₹5 crore, effective 1 August 2023. Applicability is determined using aggregate annual turnover in any preceding financial year from FY 2017–18 onward, together with the taxpayer’s entity status, transaction type and any applicable exemption.
What “e-invoice” means under GST
An e-invoice is a GST invoice registered with an authorised Invoice Registration Portal. A business still creates the invoice in its own accounting, billing or enterprise resource planning (ERP) system. It then reports the specified invoice data to the IRP rather than treating the document as complete when it is merely generated electronically.
After successful reporting, the IRP validates and registers the document, generates a unique Invoice Reference Number (IRN), digitally signs the invoice information and returns it with a QR code. The registered information is also passed into GST systems and is generally auto-populated into the supplier’s GSTR-1.
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This distinction matters in practice. A spreadsheet, PDF, emailed invoice or invoice produced by an ordinary billing application is not automatically an Indian GST e-invoice. The document must go through the prescribed IRP registration process when the supplier and transaction are within the mandate.
Who has to use e-invoicing?
The basic rule applies to a registered supplier whose aggregate annual turnover reaches the notified limit in any relevant preceding financial year, unless an exemption or transaction-specific exclusion applies. Three separate questions must be answered: the turnover test, the taxpayer’s status and the nature of the document or supply.
The current turnover threshold is ₹5 crore
CBIC Notification 10/2023-Central Tax, dated 10 May 2023, changed the threshold from ₹10 crore to ₹5 crore with effect from 1 August 2023. The notification states that the words “ten crore rupees” were replaced by “five crore rupees.” Do not use the older ₹10 crore figure as the current general threshold.
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Repair common Windows errors and clear accumulated junk for a smoother, more stable PC - no reinstall needed.Free scan · no reinstallThe turnover test is not limited to the current financial year. IRP mandate guidance refers to aggregate annual turnover in any preceding financial year beginning with FY 2017–18. A business that crossed ₹5 crore in one of those earlier years may therefore be within the threshold test even if its latest year is lower.
Turnover alone does not settle the question
Crossing ₹5 crore is a starting point, not a complete legal determination. The taxpayer must also check whether its entity category is covered, whether the particular document and supply are within scope, and whether a notified exemption applies.
IRP mandate material describes regular taxpayers and SEZ developers among the entity types for which the system is relevant. It also distinguishes an SEZ developer from an SEZ unit; those terms should not be treated as interchangeable when checking an exemption.
Portal enablement is not the legal test
A GSTIN being technically enabled on an IRP does not by itself prove that the taxpayer is legally required to issue e-invoices. Enablement is an administrative capability. Legal applicability still depends on the turnover history, taxpayer facts, document and transaction type, and applicable exemptions.
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Which documents and supplies are covered?
IRP FAQ guidance describes e-invoicing for specified invoices, credit notes and debit notes in qualifying business-to-business and export situations. The supplier, not the buyer or transporter, is responsible for generating and reporting the e-invoice.
Examples of covered transaction types
- Business-to-business (B2B) supplies.
- Deemed supplies.
- Supplies by an SEZ developer.
- Exports.
- Deemed exports.
- Supplies to government entities or public-sector entities, where the applicable rules bring them within the described scope.
These are general examples from the IRP FAQ. A special arrangement, customer type or supply classification can change the result, so the exact transaction should be checked against current GST and IRP instructions.
Documents and supplies described as outside the scope
- Business-to-consumer (B2C) supplies.
- Bills of supply.
- Job-work transactions, as listed in the FAQ’s exclusions.
- Imports.
- Exempt supplies.
- Financial or commercial credit notes that are not GST credit notes within the e-invoice requirement.
“Outside the described e-invoice scope” does not mean that no GST document, accounting record or reporting obligation exists. It means the document is not covered by the particular IRP e-invoice requirement described in that guidance.
Entity and service exemptions listed by the IRP FAQ
The FAQ lists categories that are exempt from the e-invoicing requirement, including:
- Banks, insurance companies and financial institutions, including non-banking financial companies (NBFCs).
- Goods transport agencies.
- Suppliers of passenger transport services.
- Certain services for admission to film exhibitions in multiplex screens.
- SEZ units.
- Input service distributors.
- Specified online information database access and retrieval (OIDAR) registrants.
Exemption lists can be amended. Confirm that the entity still fits the relevant category and that any conditions attached to it are met. In particular, verify whether the taxpayer is an SEZ unit or an SEZ developer, because the FAQ treats those statuses differently.
How the e-invoicing process works
The IRP workflow adds a registration step to the supplier’s existing invoicing process; it does not require the supplier to abandon its accounting or ERP system.
- Create the GST invoice in your existing system. Prepare the invoice in the accounting, billing or ERP application normally used by the business.
- Identify documents that require IRP reporting. Apply the turnover, entity, transaction and exemption checks before sending the document.
- Report the specified data to an authorised IRP. The supplier submits the required invoice information from its system or through an approved integration or portal workflow.
- Allow the IRP to validate and register it. The IRP checks and registers the reported data when the submission is accepted.
- Receive the IRN and QR code. On successful reporting, the IRP generates the unique IRN, digitally signs the invoice information and returns the registered invoice data with a digitally signed QR code.
- Use the registered document in the downstream GST workflow. The registered data is passed to GST systems and is generally auto-populated into the supplier’s GSTR-1 after successful reporting.
The practical control point is the IRP response. A document that has only been created in the internal system, but has not been successfully registered and assigned an IRN when registration is required, has not completed the e-invoicing step.
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How to decide whether a particular business is covered
Use the following sequence for each GSTIN and, where necessary, for each type of supply:
- Check the turnover history. Review aggregate annual turnover for every preceding financial year from FY 2017–18 onward, not only the current year. Determine whether the relevant record reaches ₹5 crore.
- Confirm the taxpayer’s status. Identify whether the GSTIN is a regular taxpayer, SEZ developer, SEZ unit, bank, insurer, financial institution, goods transport agency, passenger transport supplier, input service distributor, OIDAR registrant or another listed category.
- Classify the document. Decide whether it is an invoice, GST credit note or GST debit note, rather than a bill of supply or a financial/commercial adjustment outside the described scope.
- Classify the transaction. Check whether it is B2B, export, deemed export, a government or public-sector supply, deemed supply or another category identified by current guidance.
- Apply exclusions and exemptions. Record the reason when an exemption or out-of-scope classification is used, and retain the supporting facts for internal review.
- Check current official instructions. The threshold and exemptions can be amended. Use the latest CBIC notification and GST/IRP instructions rather than relying on an old software setting or a historical FAQ entry.
Threshold timeline and handling conflicting information
| Item | What the official material says | How to use it |
|---|---|---|
| Earlier general threshold | ₹10 crore appeared in older e-invoicing guidance. | Treat it as historical, not as the current general threshold. |
| Current amended threshold | ₹5 crore, substituted by CBIC Notification 10/2023-Central Tax. | Apply from 1 August 2023, subject to entity, transaction and exemption checks. |
| Turnover period | Aggregate annual turnover in any preceding financial year from FY 2017–18 onward. | Review the historical turnover record; do not check only the present year. |
| Corroborating listing | The GST Council’s listing for Notification 10/2023-Central Tax identifies the ₹5 crore measure and its effective date. | Use the Gazette notification as the primary legal wording when resolving a conflict. |
Some portal FAQ pages still contain the former ₹10 crore description. The later Gazette notification controls the amendment. A compliance procedure should therefore carry the effective date and notification number, rather than copying an undated threshold from an old FAQ.
Common mistakes and how to correct them
Calling any electronic invoice an e-invoice
Problem: An emailed PDF or internally generated electronic document is treated as registered.
Correction: For a covered transaction, report the data to the IRP and retain the returned IRN and digitally signed QR code with the invoice record.
Using the obsolete ₹10 crore threshold
Problem: A team relies on older software documentation or an unchanged FAQ.
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Checking only current-year turnover
Problem: A business below ₹5 crore this year assumes it can ignore earlier years.
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Correction: Review each preceding financial year from FY 2017–18 onward when assessing the threshold.
Assuming portal access proves liability
Problem: Enablement is treated as a legal conclusion.
Correction: Perform the separate turnover, entity, transaction and exemption analysis for the GSTIN.
Making the buyer or transporter responsible
Problem: The supplier waits for the customer or logistics provider to generate the IRN.
Correction: The supplier reports the covered invoice, credit note or debit note. Coordinate data exchange with the buyer or transporter, but keep responsibility with the issuing supplier.
Applying an exemption without checking the entity definition
Problem: An SEZ unit and an SEZ developer are treated as the same, or a service provider assumes a broad industry exemption.
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What accounting or ERP software must do
The described workflow begins with invoice creation in the business’s own accounting, billing or ERP system. Operationally, the system or its integration should be able to prepare the specified invoice data, send it to an authorised IRP, receive the IRN and digitally signed QR code, and preserve the registered response alongside the original document.
Software is an operational aid, not a substitute for legal compliance. Buying or enabling an accounting package does not itself register an invoice, determine whether the taxpayer is exempt, or replace the supplier’s responsibility to classify the transaction correctly. Before deployment, confirm that the workflow supports the relevant GSTINs, historical turnover review, exception handling and retention of IRP responses.
Worked examples for internal review
Business above the threshold with a B2B supply
A registered supplier’s aggregate annual turnover reached ₹6 crore in a preceding financial year from the period beginning FY 2017–18. It issues a B2B invoice and is not in a listed exempt category. The turnover test is met and the transaction is one of the covered examples, so the supplier should report the invoice to the IRP and obtain the IRN and QR code.
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Business below the threshold in every relevant year
A registered supplier has remained below ₹5 crore in every preceding financial year from FY 2017–18 and issues a document that is otherwise a B2B invoice. On the facts given, the turnover limb of the general mandate is not met. The business should still check whether a later notification or a different legal basis changes that result.
Exempt entity with a high turnover
A financial institution exceeds ₹5 crore but falls within the exemption category listed by the IRP FAQ. High turnover by itself does not remove the exemption. The entity should document its status and verify the current exemption wording before excluding the document from IRP reporting.
Pre-issue checklist
- Confirm the GSTIN and legal entity status.
- Review aggregate annual turnover in all preceding financial years from FY 2017–18 onward.
- Use the current ₹5 crore threshold effective 1 August 2023, unless a newer notification changes it.
- Classify the document as an invoice, GST credit note, GST debit note or an excluded document type.
- Classify the supply as B2B, export, deemed export, government/public-sector supply, deemed supply, B2C or another category.
- Check every applicable exemption, including the distinction between an SEZ unit and an SEZ developer.
- Send covered documents to an authorised IRP from the accounting, billing or ERP workflow.
- Verify that the response contains the IRN and digitally signed QR code.
- Confirm that successful reporting reaches the GST workflow and is reflected in the expected GSTR-1 process.
- Retain the classification decision and IRP response for internal and tax review.
What to verify when rules change
E-invoicing is a notification-driven compliance area. Before changing a process, compare the latest CBIC notification with current GST and IRP portal instructions. Pay particular attention to the turnover threshold, the financial years used for the lookback, the list of exempt entities, the documents covered and any revised reporting procedure. Historical portal text can remain visible after a rule changes, so an undated webpage or old software manual should not override the later legal notification.
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