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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchIn India, the notified registered supplier normally generates and reports the e-invoice even when the recipient pays GST under reverse charge. Reverse-charge liability and e-invoice reporting are separate obligations. For a supplier’s section 9(3) outward supply, the supplier prepares the tax invoice, reports it to an Invoice Registration Portal (IRP), and gives the recipient the IRN- and QR-code-enabled invoice.
A different rule applies when a registered recipient is liable to reverse charge on a qualifying purchase from an unregistered supplier. Under section 31(3)(f) of the CGST Act, the recipient issues a statutory self-invoice; the IRP FAQ says e-invoicing does not arise for supplies received from an unregistered supplier. The answer below concerns Indian GST, not VAT or GST systems in other countries.
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The two reverse-charge situations you must keep separate
The phrase “reverse-charge supply” can describe two document flows. First, a registered supplier may make an outward supply covered by section 9(3), with the recipient responsible for paying the tax. If that supplier falls within the notified e-invoice class and the transaction is otherwise covered, the supplier still reports its invoice to the IRP. The Invoice Registration Portal’s FAQ states: “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.”
Second, a registered person may have to account for reverse-charge tax on a supply received from an unregistered supplier. In that case, section 31(3)(f) requires the registered recipient to issue an invoice for the receipt when the statutory conditions are met. That self-invoice is not an IRP-generated e-invoice, because the supplier is unregistered and cannot be the notified supplier reporting an outward e-invoice.
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At-a-glance decision table
| Supplier and transaction | Who issues the ordinary invoice? | Who reports an e-invoice to the IRP? | What to verify |
|---|---|---|---|
| Registered supplier in the notified e-invoice class; outward supply attracts section 9(3) reverse charge | The supplier issues the tax invoice. | The supplier reports it and obtains the IRN and signed QR code. | Current notification, turnover basis, transaction scope and exceptions. See the IRP mandate guidance and IRP FAQ. |
| Registered recipient liable under an applicable section 9(3) or 9(4) provision; supplier was unregistered when goods or services were received | The registered recipient issues the section 31(3)(f) self-invoice. | No IRP e-invoice arises for the unregistered-supplier receipt, according to the IRP FAQ. | Confirm that the reverse-charge provision applies and that the supplier was unregistered on the receipt date. Read section 31(3)(f) in the CGST Act. |
| Registered supplier, but outside the notified e-invoice class or transaction exception applies | The supplier follows ordinary GST invoicing rules. | Usually no e-invoice under the exception or non-applicability, subject to the current notification. | Do not rely only on portal status; check the legal class and transaction facts. |
| B2C, import, exempt or another listed exclusion | Document requirements depend on the transaction and GST rules. | The IRP FAQ lists these categories among e-invoice exclusions. | Check the current notification and the specific exemption or exclusion. |
Why reverse charge does not transfer e-invoice reporting to the customer
Reverse charge answers who pays the tax. E-invoicing answers which supplier must report a covered invoice and obtain an Invoice Reference Number. Those questions can have different answers on the same transaction.
For a notified supplier’s outward supply, the invoice remains the supplier’s document. The recipient’s payment of GST does not turn the recipient into the e-invoice reporter. The IRP’s mandate guidance puts the point directly: “E-invoice can be generated only by suppliers. The recipients and transporters cannot generate e-invoice.”
The supplier must therefore create the invoice in its accounting or enterprise-resource-planning system, transmit the required invoice data to an IRP, and use the returned IRN and signed QR code on the invoice delivered to the recipient. The recipient’s reverse-charge accounting and tax payment occur separately.
Case 1: a notified registered supplier makes a section 9(3) supply
Step 1: identify the supplier’s legal status
Confirm that the supplier is GST-registered and falls within the e-invoice class notified for the relevant period. The current IRP mandate page states a threshold of aggregate annual turnover of ₹5 crore or more, effective 1 August 2023, measured using any preceding financial year from FY 2017–18 onward. Turnover is not the only test: taxpayer type, transaction category and specific exclusions also matter.
Step 2: prepare the ordinary tax invoice
The supplier prepares the invoice before IRP reporting. CBIC’s Rule 46 material identifies core particulars such as:
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- the supplier’s and recipient’s legal name, address and GST registration details where applicable;
- a consecutive invoice serial number and invoice date;
- a description of the goods or services, with quantity or other applicable unit information;
- taxable value, tax rate and tax amount, together with other value fields required for the transaction;
- the place-of-supply and other prescribed particulars where relevant; and
- a clear indication that the supply attracts reverse charge.
Use the current wording and data requirements in CBIC’s tax-invoice and credit/debit-note rules. Reverse-charge treatment should be visible on the underlying invoice; it is not a reason to omit the normal invoice particulars.
Step 3: report the invoice to the IRP
- Submit the prepared invoice data through the permitted IRP channel used by the supplier’s system.
- Validate the response and receive the Invoice Reference Number (IRN) and signed QR code.
- Attach or print the returned IRN and QR code on the invoice supplied to the recipient, following the applicable technical format.
- Send the completed invoice to the recipient, who uses it for its reverse-charge accounting and tax-payment process.
The IRP is a registration step for the supplier’s invoice; it does not change who is liable to pay reverse-charge tax.
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When the recipient must self-invoice
Section 31(3)(f) of the CGST Act requires a registered person liable to pay tax under an applicable section 9(3) or 9(4) reverse-charge provision to issue an invoice for goods or services received from an unregistered supplier. The supplier’s registration status must be assessed for the date on which the goods or services are received.
This is a recipient-issued statutory invoice, often called a self-invoice. It should not be described as an e-invoice merely because the recipient creates it in accounting software. The IRP FAQ specifically says e-invoicing does not arise for supplies received from an unregistered supplier.
What this means operationally
- Verify the supplier’s unregistered status and the reverse-charge provision that makes the recipient liable.
- Create the section 31(3)(f) invoice using the recipient’s records and the particulars required by the GST rules for that document.
- Account for the reverse-charge tax and complete the applicable return and payment steps.
- Do not attempt to obtain an IRN for the unregistered supplier’s receipt as though it were a notified supplier’s outward e-invoice.
The exact taxability of purchases from unregistered suppliers depends on the reverse-charge notifications and the facts of the supply. Section 31(3)(f) should therefore be read with the currently applicable section 9(3) or 9(4) provision, rather than treated as a blanket rule for every unregistered purchase.
How to test whether e-invoicing applies
Use the current threshold and notification
The IRP mandate page records ₹5 crore or more as the stated threshold from 1 August 2023 and says aggregate annual turnover in any preceding financial year from FY 2017–18 onward is considered. A firm’s current-year sales alone are not the complete test. Review the supplier’s turnover history, registration type and any notification-specific conditions.
An FAQ example involving a firm with turnover above ₹500 crore is illustrative only. It is not the general legal threshold and should not be used as a substitute for the current mandate.
Check the transaction category
The IRP FAQ identifies B2B supplies and exports among categories covered by e-invoicing when the supplier is otherwise in scope. It also lists exclusions such as B2C supplies, imports and exempt supplies, along with specified entity classes. The correct result depends on the transaction’s legal classification, not simply on the fact that reverse charge is mentioned on an invoice.
Separate portal enablement from legal applicability
A taxpayer may be technically enabled on an IRP even when a particular invoice is outside the legal mandate, and a portal account status does not itself establish liability to issue e-invoices. The IRP FAQ expressly cautions that enablement is not proof of legal applicability. Keep the notification and transaction analysis supporting your decision.
A practical decision procedure for accounts teams
- Identify both parties. Record the supplier’s GST registration status, the recipient’s status and the registration details used on the transaction.
- Classify the reverse charge. Decide whether this is an outward supply by a supplier whose invoice attracts section 9(3), or a receipt from an unregistered supplier for which the recipient may owe tax under section 9(3) or 9(4).
- Test supplier mandate status. Apply the current ₹5 crore turnover test, the preceding-financial-year rule, taxpayer-type conditions and any current notification.
- Test transaction scope. Check whether the invoice is B2B or export and whether an exclusion such as B2C, import, exempt supply or a specified entity category applies.
- Choose the document owner. For a notified registered supplier’s section 9(3) outward invoice, the supplier reports to the IRP. For the qualifying unregistered-supplier receipt, the registered recipient issues the statutory self-invoice and does not generate an IRP e-invoice.
- Complete the invoice data. Include Rule 46 particulars and the reverse-charge indicator on the supplier’s tax invoice, or the prescribed details for the recipient’s self-invoice.
- Reconcile the result. For an e-invoice case, match the IRN and signed QR code to the final invoice. For a self-invoice case, retain the document with the purchase and reverse-charge records.
Common mistakes and how to correct them
Mistake: assuming the recipient always generates the invoice
Reverse-charge payment does not by itself make the recipient the e-invoice reporter. Correct the workflow by first asking whether the supplier is registered, notified and making the outward supply covered by section 9(3).
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Mistake: treating every reverse-charge invoice as exempt from e-invoicing
The IRP FAQ expressly says e-invoicing applies to a notified person’s invoice for that person’s section 9(3) supply. Marking such an invoice “reverse charge” is not a substitute for IRP reporting when the mandate applies.
Mistake: submitting a self-invoice from an unregistered supplier to the IRP
The recipient’s section 31(3)(f) document and the supplier-reported e-invoice are different legal mechanisms. For the unregistered-supplier receipt, follow the self-invoice requirement and the FAQ’s position that e-invoicing does not arise.
Mistake: relying on a portal flag or an old turnover assumption
Portal enablement is technical, not conclusive. Recheck the current notification, the ₹5 crore threshold framework, the preceding-financial-year turnover history and transaction exclusions before deciding that an invoice is covered.
Mistake: omitting the reverse-charge indication or core particulars
An IRN does not cure an incomplete underlying invoice. Use Rule 46’s supplier, recipient, serial-number, date, description, value and tax particulars, and identify the reverse-charge treatment clearly.
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Example 1: notified registered supplier
A GST-registered service provider that meets the applicable e-invoice conditions supplies a service to a registered customer. The service is one for which the customer pays GST under section 9(3). The provider issues the tax invoice, marks the reverse-charge treatment, reports the invoice to the IRP and gives the customer the invoice with its IRN and signed QR code. The customer pays the reverse-charge tax; it does not replace the provider as e-invoice reporter.
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Example 2: qualifying receipt from an unregistered supplier
A registered business receives a supply from a supplier that is unregistered on the receipt date, and a currently applicable section 9(3) or 9(4) provision makes the recipient liable. The recipient issues the section 31(3)(f) self-invoice and handles the reverse-charge tax. Because the supplier is unregistered, the IRP FAQ says an e-invoice does not arise for that receipt.
Example 3: portal enabled, transaction excluded
A taxpayer’s IRP account is enabled, but a particular transaction falls within an applicable exclusion, such as a B2C or exempt category. Enablement alone does not decide the result. The taxpayer should document the transaction classification and the current notification supporting non-applicability.
Where to verify the rule
For the current turnover threshold, notified taxpayer classes and mandate language, consult the Invoice Registration Portal’s GST e-invoice mandate page. For reverse-charge examples, exclusions and the distinction between a notified supplier and an unregistered supplier, consult the IRP FAQ powered by IRIS IRP.
For the statutory recipient self-invoice duty, read section 31(3)(f) in the Central Goods and Services Tax Act. For invoice particulars, use CBIC’s tax-invoice rules. CBIC’s Reverse Charge Mechanism sectoral FAQs can help with general RCM context, but the transaction’s current notification and facts control the final answer.
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