Who has to generate GST e-invoices?

1Who must generate e-invoices

The rule is based on aggregate turnover, not your current year alone:

• If your aggregate turnover crossed ₹5 crore in ANY financial year since GST began (2017-18 onwards), e-invoicing is mandatory
• Once you become liable, you remain liable even if turnover later falls below ₹5 crore
• It applies to your B2B supplies, exports, and credit/debit notes

2How e-invoicing works

E-invoicing doesn't mean the government generates your invoice — you still create it in your own system, then register it:

• You upload the invoice details to the Invoice Registration Portal (IRP)
• The IRP validates it and returns a unique Invoice Reference Number (IRN) and a digitally signed QR code
• You print the IRN and QR code on the invoice — only then is it a valid tax invoice
• The data auto-populates your GSTR-1 and can auto-generate the e-way bill, reducing manual work

3What's exempt

Some supplies and entities are outside e-invoicing even above the threshold:

• B2C (business-to-consumer) invoices are currently not covered
• Specified entities are exempt — banks, insurers, NBFCs, goods transport agencies, passenger transport, and cinema admission
• SEZ units (though SEZ developers are covered)

4The 30-day reporting limit

Being liable to e-invoice is not the whole obligation. There is now a deadline for reporting each document, and missing it cannot be fixed.

From 1 April 2025, a taxpayer with aggregate annual turnover of ₹10 crore or more cannot report an invoice, credit note or debit note to the Invoice Registration Portal more than thirty days after the document date. The threshold was ₹100 crore before that.

The portal simply rejects the document. Since an invoice without an IRN is not a valid tax invoice, a document that misses the window cannot be regularised — the practical answer is to cancel and reissue, which creates its own reconciliation problems.

5What e-invoicing actually is, mechanically

The name misleads. You do not create the invoice on a government portal, and the portal does not store your invoices.

You raise the invoice in your own accounting system in the prescribed schema, upload it to the IRP, and receive an Invoice Reference Number and a signed QR code back. That IRN is what makes the document a valid tax invoice under rule 48(4).

The benefit is downstream: the reported data auto-populates your GSTR-1 and the buyer's GSTR-2B, and can generate the e-way bill Part A. Errors therefore propagate — an e-invoice with the wrong GSTIN affects the buyer's credit as well as your return.

6What happens if you should have and did not

Rule 48(5) is blunt: where e-invoicing applies, an invoice issued without an IRN is not an invoice at all.

That has two consequences. The supplier faces penalty under section 122 for issuing an incorrect invoice. More painfully for the commercial relationship, the buyer's input tax credit is exposed, because credit requires a valid tax invoice — and the buyer will usually discover the problem at reconciliation, months later.

Liability is also sticky. Once turnover has crossed the threshold in any financial year since 2017-18, the obligation continues even if turnover subsequently falls.

7How the turnover for the threshold is actually computed

Most disputes about whether e-invoicing applies come down to computing aggregate turnover, which is wider than the sales figure in your accounts.

Aggregate turnover is computed on a PAN basis across all GST registrations in India, not per GSTIN. It includes taxable supplies, exempt supplies, exports and inter-state supplies to your own other registrations, and excludes GST itself and inward supplies on which you paid tax under reverse charge.

The test is applied to any financial year from 2017-18 onwards. So a business whose turnover peaked in an earlier year and has since fallen is liable now on the strength of that earlier year, which is the point most often missed.