In India, an e-invoice is a GST invoice that the supplier reports to an authorised Invoice Registration Portal (IRP). The portal validates the data, assigns a unique Invoice Reference Number (IRN), digitally signs the record and returns a QR code. Creating an invoice in accounting software, saving it as a PDF or emailing it to a customer does not, by itself, make it an e-invoice.
The general turnover threshold is ₹5 crore. Under CBIC Notification 10/2023-Central Tax, the earlier ₹10 crore threshold was replaced with ₹5 crore with effect from 1 August 2023. The test uses aggregate annual turnover in any preceding financial year from FY 2017–18 onward. Turnover alone is not the complete test: the taxpayer’s entity status, document type, transaction and any applicable exemption also matter.
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What e-invoicing means under GST
E-invoicing is a reporting and authentication system layered onto the normal GST invoicing process. A business still prepares the invoice in its own accounting, billing or enterprise resource planning (ERP) system. For covered transactions, it then sends the specified invoice data to an IRP before treating the document as a compliant e-invoice.
The IRP checks and registers the submission, creates the IRN and returns the registered information with a digitally signed QR code. The QR code lets the invoice be verified against the registered data. Thus, “electronic” describes the reporting workflow, not merely the file format. A spreadsheet, PDF, printed invoice scanned into a computer or invoice sent by email is not an IRP-registered e-invoice unless the required data has been reported and an IRN has been generated.
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IRP guidance describes the workflow this way: taxpayers continue to create GST invoices in their existing accounting, billing or ERP systems, and those invoices are reported to the Invoice Registration Portal. After reporting, the IRP generates a unique IRN, digitally signs the e-invoice and returns it with a QR code.
Who has to use e-invoicing?
The basic rule applies to registered suppliers whose aggregate annual turnover reached the notified threshold in any relevant preceding financial year and whose supply is a covered transaction. For the current general threshold evidenced by CBIC Notification 10/2023-Central Tax, that amount is ₹5 crore, effective 1 August 2023.
“Preceding financial year” is important. IRP mandate guidance says the review covers any financial year beginning with FY 2017–18. A business that crossed ₹5 crore in an earlier year cannot assume that a lower turnover in the current year removes the requirement. Conversely, crossing the threshold does not automatically settle every invoice: exemptions and transaction rules must still be checked.
Applicability checklist
- Calculate the business’s aggregate annual turnover for each financial year from FY 2017–18 onward, using the GST rules applicable to aggregate turnover.
- Check whether the relevant GST registration and taxpayer category falls within the notified class. IRP mandate guidance refers to regular taxpayers and SEZ developers among the entity types using the system.
- Identify the document and transaction: invoice, credit note or debit note; B2B, export or another specified supply.
- Check the exemption list and any transaction-specific exclusion.
- Confirm that the invoice is reported by the supplier to an authorised IRP and that an IRN and QR code are returned.
Portal enablement is not the legal test. A GSTIN may be technically enabled to access an IRP even when the taxpayer’s facts do not make every transaction subject to e-invoicing. Conversely, a business should not treat the absence of a portal prompt as proof that it is exempt.
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What the ₹5 crore threshold changed
CBIC Notification 10/2023-Central Tax, dated 10 May 2023, substituted “five crore rupees” for “ten crore rupees” with effect from 1 August 2023. The notification is the controlling primary source for that change. A GST Council listing independently identifies the measure as implementing the ₹5 crore threshold from the same date.
Some older FAQ pages still show the former ₹10 crore figure. That historical text should not be used as the current general threshold. The practical rule is ₹5 crore, subject to the look-back test, entity status, transaction scope and exemptions. Later government notifications or portal instructions can change the rules, so businesses should check current CBIC and GST portal directions when making a compliance decision.
Which documents and transactions are covered?
IRP FAQ guidance describes e-invoicing for specified invoices, credit notes and debit notes issued by the supplier. The examples below are general categories from that guidance; an unusual transaction should be checked against the latest applicable notification and portal instructions.
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| Generally described as covered | What that means in practice |
|---|---|
| B2B supplies | Supplies to another GST-registered business where the prescribed conditions apply. |
| Exports | Export invoices and related covered documents reported by the exporting supplier. |
| Deemed exports | Transactions treated as deemed exports under GST rules, when within the applicable reporting scope. |
| Supplies to government or public-sector entities | Specified supplies to government departments or public-sector bodies. |
| SEZ developer supplies | Supplies made to or by an SEZ developer where the e-invoice rules apply; an SEZ unit is treated differently in the exemption list. |
| Credit notes and debit notes | Relevant notes connected with covered supplies, rather than every commercial adjustment called a “credit note.” |
Examples described as outside the e-invoice scope
- B2C supplies.
- Bills of supply.
- Job-work transactions in the category identified by the FAQ.
- Imports.
- Exempt supplies.
- Financial or commercial credit notes that are not GST credit notes.
These are source-backed examples, not a substitute for classifying a complex transaction. For example, the label “credit note” is not enough: the tax treatment and the underlying supply determine whether a GST document must be reported.
Who is exempt or treated differently?
The IRP FAQ lists several categories outside the described mandate. The exemption is connected to the taxpayer category and service, not simply to the fact that the entity has a GST registration.
| Category listed in IRP guidance | Qualification |
|---|---|
| Banks, insurance companies and financial institutions | Includes non-banking financial companies (NBFCs) identified in the guidance. |
| Goods transport agencies | Suppliers operating as the specified GTA category. |
| Passenger transport service suppliers | Entities providing the passenger transport service described by the exemption. |
| Admission services for film exhibitions in multiplex screens | The exemption is for the specified admission-service category, not every entertainment service. |
| SEZ units | The FAQ distinguishes an SEZ unit from an SEZ developer. Do not treat the two labels as interchangeable. |
| Input service distributors | ISDs are listed separately from ordinary registered suppliers. |
| Specified OIDAR registrants | Only the OIDAR registrants covered by the stated category are included. |
Exemption lists can be amended. A company that operates more than one business line should test each registration and supply rather than applying one blanket conclusion to the entire organisation.
How to generate an e-invoice
The supplier does not replace its accounting system with the IRP. The usual process is a hand-off from the existing invoicing system to the portal and back.
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Repair common Windows errors and clear accumulated junk for a smoother, more stable PC - no reinstall needed.Free scan · no reinstall- Create the invoice in the normal system. Enter the GST invoice data in the accounting, billing or ERP application. Use the data structure and mandatory fields required for IRP reporting.
- Send the covered document to an authorised IRP. The supplier, not the buyer or transporter, reports the invoice, credit note or debit note. Software may connect through an approved integration, or the taxpayer may use the methods made available by the IRP.
- Allow the IRP to validate and register it. The portal checks the submission and generates the unique IRN when registration succeeds.
- Receive the registered data and QR code. The IRP returns the invoice information with its digital signature and QR code. Preserve the returned values in the accounting record and place the required QR code on the invoice issued to the recipient.
- Complete downstream GST reporting. According to the FAQ, successfully reported data is generally auto-populated into the supplier’s GSTR-1. Review the return data rather than assuming every downstream field is correct without reconciliation.
What the buyer and transporter do
The supplier owns the e-invoice-generation step. The buyer may verify the IRN or QR code and retain the document, but does not generate the supplier’s e-invoice. A transporter may use invoice details for movement documentation, but is not the party responsible for reporting the covered sales invoice to the IRP.
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What a business needs before switching on the workflow
- Turnover records: Keep a year-by-year view from FY 2017–18 so the look-back test is reproducible.
- GST registration mapping: Map each GSTIN, legal entity and business line to the invoices it issues.
- Document classification: Separate B2B, export, B2C, exempt, import, job-work and other transaction types in the billing system.
- Exemption evidence: Record why a listed exemption applies to the entity or service and review it when the business model changes.
- IRP connectivity: Confirm that the accounting, billing or ERP system can submit the required fields and store the returned IRN, QR code and signed response.
- Reconciliation controls: Compare successful IRP responses with issued invoices and GSTR-1 data so rejected, duplicated or unreported documents are found promptly.
Accounting or ERP software is an operational aid, not a replacement for the legal process. Choosing software that can communicate with an authorised IRP may reduce manual entry, but the taxpayer remains responsible for classifying the transaction and reporting the correct data.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Common misunderstandings and practical fixes
“Any electronic invoice is an e-invoice.”
Fix: Look for the IRN and digitally signed QR code returned after IRP registration. A PDF or email attachment without that registration is only an electronic copy of an invoice.
“The threshold is still ₹10 crore.”
Fix: Use the ₹5 crore threshold effective 1 August 2023 under Notification 10/2023-Central Tax, and apply the preceding-year look-back.
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Fix: Review every preceding financial year from FY 2017–18 onward. The relevant historical turnover can keep the requirement in scope.
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“If the portal lets us log in, every invoice must be reported.”
Fix: Separate technical enablement from legal applicability. Check the taxpayer category, document type, transaction and exemptions.
“The buyer or transporter can generate the supplier’s e-invoice.”
Fix: The supplier reports the covered document. Other parties can receive or use the registered details but do not replace the supplier’s reporting responsibility.
“Every credit note is covered.”
Fix: Distinguish GST credit notes and debit notes for covered supplies from financial or commercial credit notes listed outside the described scope.
A decision framework for a particular GSTIN
For a defensible internal decision, document the answer to these questions in order:
- Did aggregate annual turnover reach ₹5 crore in any preceding financial year from FY 2017–18 onward?
- Is the GSTIN a regular taxpayer, SEZ developer or another entity category to which the mandate applies?
- Is the document an invoice, GST credit note or GST debit note?
- Is the underlying supply B2B, export, deemed export, government/public-sector or another listed covered type?
- Does a category exemption apply, such as a bank, insurer, GTA, passenger transport supplier, SEZ unit, ISD or specified OIDAR registrant?
- Can the system submit the required data and retain the IRN, QR code and IRP response?
If the answers are mixed—for example, a group is above the threshold but has both exempt and taxable supplies—classify each document rather than issuing one group-wide instruction.
What to verify when rules or portal procedures change
The ₹5 crore threshold and its 1 August 2023 effective date come from the CBIC notification. Operational details, portal interfaces and exemption wording can be updated separately. Before relying on an old FAQ or software setting, compare it with the latest CBIC notification, GST portal instruction and IRP guidance. Keep the date of that review in the company’s compliance file.
For a taxpayer-specific conclusion, the decisive evidence is the turnover history, GSTIN and entity status, supply classification, document type and exemption basis. This article explains the general framework; it cannot determine liability for an individual business without those facts.
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