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In India, the notified registered supplier generally generates and reports the e-invoice—even when the recipient pays GST under reverse charge. Reverse-charge tax liability and e-invoice reporting are separate obligations. The main exception is a qualifying purchase from an unregistered supplier: the registered recipient may have to issue a statutory self-invoice, but that document is not an IRP-generated e-invoice.
The short answer
For a reverse-charge supply covered by India’s GST e-invoice mandate, the supplier prepares the tax invoice in its accounting or ERP system and reports it to an Invoice Registration Portal (IRP). The IRP returns an Invoice Reference Number (IRN) and a digitally signed QR code, which the supplier places on the invoice given to the recipient.
This remains true when the recipient, rather than the supplier, is liable to pay GST under reverse charge. The Invoice Registration Portal’s mandate guidance states: “E-invoice can be generated only by suppliers. The recipients and transporters cannot generate e-invoice.” Its reverse-charge FAQ adds: “If the invoice issued by notified person is in respect of supplies made by him but attracting reverse charge under Section 9(3), e-invoicing is applicable.” See the official GST e-invoice mandate and IRP FAQ.
Do not apply this answer universally to every VAT or GST system. The rules below concern Indian GST, principally supplies covered by section 9(3) of the Central Goods and Services Tax (CGST) Act.
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Why reverse charge does not transfer e-invoice reporting
Reverse charge answers one question: who pays the tax to the government? E-invoicing answers another: who must report a covered invoice and obtain an IRN? In a notified supplier’s section 9(3) transaction, those answers can be different.
- The supplier makes the outward supply and issues the ordinary tax invoice.
- The recipient accounts for and pays the reverse-charge GST, subject to the applicable law.
- The notified supplier still reports the invoice to the IRP and obtains the IRN and signed QR code.
The recipient’s payment obligation therefore does not, by itself, make the recipient the e-invoice generator. Nor does reverse-charge wording on an invoice remove the supplier’s e-invoice requirement when the supply and supplier are within the notified scope.
The two situations that must be separated
| Situation | Supplier status | Who issues the underlying document? | Who reports an e-invoice to the IRP? | Key rule |
|---|---|---|---|---|
| Section 9(3) reverse-charge outward supply by a notified supplier | Registered and within the notified e-invoice class | Supplier issues the tax invoice | Supplier reports it and receives the IRN and signed QR code | IRP FAQ says e-invoicing applies to the notified person’s section 9(3) supply |
| Registered recipient receives a covered supply from an unregistered supplier | Supplier is unregistered on the date of receipt | Recipient issues a statutory self-invoice where section 31(3)(f) applies | IRP FAQ says e-invoicing does not arise for supplies received from an unregistered supplier | Self-invoice duty is separate from IRP e-invoicing |
The second row is why the statement “the recipient never issues an invoice under reverse charge” is too broad. A recipient can have a self-invoicing obligation for a qualifying receipt from an unregistered supplier, but that is not the same as generating an IRP e-invoice.
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Case 1: a notified registered supplier makes a section 9(3) supply
What the supplier does
The supplier first creates the normal tax invoice with the required particulars. If the supplier is a notified taxpayer and the transaction is not excluded, it then reports the invoice data to an IRP. The portal validates the submission, generates the IRN and signs the QR code. The supplier provides the resulting invoice to the recipient.
What the recipient does
The recipient records the purchase and discharges the reverse-charge tax according to the applicable GST rules. The recipient does not log in as the e-invoice reporter merely because it bears the tax liability. It should retain the supplier’s IRN-bearing invoice and separately complete its reverse-charge accounting and reporting duties.
What the invoice should show
Because the invoice is still a tax invoice for the supplier’s outward supply, it must contain the particulars required by the CGST Rules. The invoice should identify the supplier and recipient, carry a unique serial number and date, describe the goods or services, show taxable values and tax details, and indicate that the tax is payable on reverse charge. The IRP’s signed QR code and IRN are added when e-invoice reporting applies.
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Case 2: a registered recipient buys from an unregistered supplier
Section 31(3)(f) of the CGST Act requires a registered person who is liable to pay tax under reverse charge to issue an invoice for a supply received from an unregistered supplier, where the statutory conditions are met. This is commonly called a self-invoice.
The self-invoice is the recipient’s document for recording the receipt and reverse-charge liability. It should not be described as an IRP-generated e-invoice. The IRP FAQ specifically says e-invoicing does not arise for supplies received from an unregistered supplier. Read the CGST Act, 2017 for the statutory invoice obligation.
Section 9(4) has its own conditions and notifications, so do not assume every purchase from an unregistered person automatically creates a current reverse-charge liability. First establish that tax is actually payable under the applicable provision and notification; then determine whether section 31(3)(f) requires the recipient’s invoice.
How to decide who must generate the document
- Identify the jurisdiction. Confirm that the transaction is governed by Indian GST, not another country’s VAT or e-invoice rules.
- Identify both parties’ registration status. Record the supplier’s GST registration and the recipient’s registration as of the supply or receipt date. The unregistered-supplier self-invoice rule depends on this status.
- Classify the reverse-charge basis. Determine whether the outward supply attracts section 9(3), or whether the recipient’s liability arises in an unregistered-supplier situation under section 9(4) and the relevant notification.
- Check whether the supplier is in the notified e-invoice class. The current IRP mandate page states that aggregate annual turnover of ₹5 crore or more, measured in any preceding financial year from FY 2017–18 onward, applies from 1 August 2023 under Notification 10/2023 dated 10 May 2023. Confirm the current notification, taxpayer category and any later changes for the transaction date.
- Check the document and transaction scope. The IRP FAQ identifies B2B supplies and exports among covered categories, while listing exclusions such as B2C supplies, imports, exempt supplies and specified entity classes. Apply the current exceptions to the actual facts.
- Assign the reporting duty. If a notified registered supplier is making the section 9(3) supply, that supplier reports the invoice. If the recipient is self-invoicing for a receipt from an unregistered supplier, the IRP FAQ’s position is that no e-invoice arises for that receipt.
Turnover, notification and portal status
Do not decide applicability from the value of one invoice or from the recipient’s reverse-charge payment alone. The IRP mandate page bases the stated threshold on aggregate annual turnover in any preceding financial year from FY 2017–18 onward. It records the ₹5 crore threshold as effective 1 August 2023. That figure is a threshold for the notified class, not a guarantee that every taxpayer above it must e-invoice every document: transaction exclusions and specified entity exceptions still matter.
The IRP FAQ also warns that technical enablement on an e-invoice portal does not, by itself, prove legal liability to issue e-invoices. Conversely, a portal account that is not enabled should not be treated as permission to ignore a legal mandate. Review the applicable notification and the taxpayer’s facts, then retain the basis for the conclusion.
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What the supplier’s e-invoice workflow looks like
1. Prepare the tax invoice
Create the invoice in the supplier’s accounting, billing or ERP system before submitting data to the IRP. Include the supplier and recipient GST details, invoice number and date, item or service description, quantity where relevant, taxable value, rate and amount of tax, place-of-supply details where applicable, and the reverse-charge indicator. CBIC’s Tax Invoice, Credit and Debit Notes page reproduces Rule 46 requirements.
2. Submit the invoice data to an IRP
The supplier or its authorised software sends the prescribed invoice fields to an IRP. The IRP generates a unique IRN and applies a digital signature to the QR code. The portal registration step does not replace the supplier’s responsibility for accurate source data.
3. Validate the returned identifiers
Store the IRN and signed QR response with the accounting record. Check that the returned details correspond to the invoice number, supplier GSTIN, document type and date. Correcting a data error generally requires following the prescribed cancellation or amendment process rather than silently changing an already registered invoice.
4. Issue the IRN-bearing invoice
Give the recipient the invoice containing the required particulars, IRN and signed QR code. The recipient uses it for purchase records and reverse-charge accounting; the recipient does not generate a second IRP e-invoice for the same supplier document.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Invoice particulars and reverse-charge marking
Rule 46 requires more than an IRN. The tax invoice must carry the supplier’s legal name, address and GSTIN; the recipient’s details when registered; a consecutive serial number and date; a description of goods or services; values and tax amounts; and other prescribed information. It must clearly indicate when tax is payable under reverse charge. Consult the CBIC invoice-rules guidance for the complete particulars applicable to the document type.
An IRN or QR code cannot cure a basic invoice defect. Conversely, a correctly prepared self-invoice for an unregistered-supplier receipt does not become an IRP e-invoice merely because the recipient prints it electronically.
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Common mistakes and how to correct them
“The customer pays GST, so the customer must generate the e-invoice.”
That confuses tax payment with reporting. For a notified supplier’s section 9(3) outward supply, the supplier reports the invoice. The recipient’s job is to account for and pay reverse-charge tax.
“Every reverse-charge transaction needs an IRP e-invoice.”
Not necessarily. A receipt from an unregistered supplier that requires a recipient self-invoice is expressly distinguished by the IRP FAQ; e-invoicing does not arise for that receipt. Transaction exclusions and entity exceptions can also remove a document from the mandate.
“Portal enablement proves the legal answer.”
It does not. Treat enablement as a technical condition. Determine legal applicability from the current notification, turnover history, taxpayer type, transaction category and exclusions.
“The ₹500 crore example is the threshold.”
It is not. The FAQ example is illustrative. The IRP mandate page states a ₹5 crore threshold effective 1 August 2023, measured using any preceding financial year from FY 2017–18 onward, subject to the current rules and exceptions.
“A self-invoice and an e-invoice are interchangeable terms.”
They are different documents serving different rules. A self-invoice arises from the recipient’s statutory duty for a qualifying unregistered-supplier receipt. An e-invoice is an invoice reported by a notified supplier to an IRP and assigned an IRN and signed QR code.
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- The supplier’s GST registration details and evidence of notified-status analysis.
- The reverse-charge notification or provision relied on, including whether the case is section 9(3) or a section 9(4) receipt.
- The original invoice data submitted to the IRP and the returned IRN and signed QR response.
- The final invoice supplied to the recipient, including the reverse-charge indicator.
- For an unregistered-supplier receipt, the recipient’s self-invoice, receipt evidence and basis for concluding that section 31(3)(f) applies.
- Documentation of any transaction or entity exception used to determine that e-invoicing is not required.
For broader reverse-charge explanations, CBIC’s Sectoral FAQs on Reverse Charge Mechanism provide additional statutory context. Because notifications and exemptions can change, verify the rule in force on the invoice date rather than relying on an old threshold timeline.
Decision rule
If a notified registered supplier issues an invoice for its own section 9(3) supply, the supplier generates and reports the e-invoice, even though the recipient pays the reverse-charge GST. If a registered recipient receives a qualifying supply from an unregistered supplier, the recipient may have to issue a section 31(3)(f) self-invoice, but the IRP FAQ says an e-invoice does not arise for that receipt. Always test the current mandate, exclusions and taxpayer facts before filing or issuing the document.
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