E-invoicing under GST: who it applies to and the turnover limit

By the FundRaksha Book team · Updated

Short answer

E-invoicing under GST is compulsory for businesses whose aggregate turnover has crossed ₹5 crore in any financial year from 2017-18 onwards. This limit has applied since 1 August 2023. It covers B2B invoices, exports, and credit and debit notes, not bills to ordinary consumers. A shop or wholesaler whose turnover has never crossed ₹5 crore does not need e-invoicing and can keep issuing normal GST invoices.

What e-invoicing is

E-invoicing does not mean making invoices on a government website. You still make the invoice in your own billing or accounting software. The invoice details are then reported to an Invoice Registration Portal (IRP), which checks them and returns:

  • an Invoice Reference Number (IRN), a unique number for that invoice, and
  • a digitally signed QR code, which must be printed on the invoice.

For a business covered by e-invoicing, a B2B invoice without an IRN is not treated as a valid tax invoice.

The turnover limit

E-invoicing was brought in for the largest businesses first and the limit was lowered in steps. Since 1 August 2023 it applies to registered persons whose aggregate turnover exceeded ₹5 crore in any financial year from 2017-18 onwards.

  • Aggregate turnover is counted PAN-wise, for all your GSTINs across India together.
  • It is "any year from 2017-18", not just last year. If you crossed ₹5 crore once, e-invoicing continues to apply even if turnover falls later.
  • If you cross the limit for the first time this year, e-invoicing applies from the start of the next financial year.

The limit has been lowered several times since 2020. Before acting, confirm the current limit on the GST portal or the e-invoice portal (einvoice1.gst.gov.in), or ask your CA.

Which documents are covered

DocumentE-invoice needed?
Tax invoice to a GST-registered buyer (B2B)Yes
Export invoiceYes
Credit note or debit note to a registered buyerYes
Bill to an unregistered customer (B2C)No
Bill of supplyNo
Delivery challanNo

Who is exempt even above the limit

Some classes of suppliers are kept out of e-invoicing whatever their turnover. These include SEZ units, insurers, banks and other financial institutions including NBFCs, goods transport agencies, passenger transport services, multiplex cinema admission, and government departments and local authorities. Check the notification or ask your CA if you think you fall in one of these classes.

Small shops below the limit

If your aggregate turnover has never crossed ₹5 crore in any year since 2017-18, e-invoicing does not apply to you. You do not need an IRN or a QR code. A normal GST tax invoice with the mandatory fields under Rule 46, or a bill of supply if you are a composition dealer, is fully valid.

A buyer cannot insist on an e-invoice from a supplier who is below the limit. If a large customer asks, tell them your turnover is below the e-invoicing limit; some buyers ask for a short written declaration to that effect.

For shops in this group, billing software such as FundRaksha Book is enough: GST billing, purchases, barcode labels, stock and customer credit, with the first 300 invoices free and ₹999 a year after that.

Time limit for reporting

The GST network has set a time limit of 30 days from the invoice date for reporting invoices to the IRP for larger taxpayers. This limit was first applied to businesses with very high turnover and later extended to a lower turnover band. If e-invoicing applies to you, check the current advisory on the e-invoice portal for the band you fall in.

An IRN can be cancelled on the IRP only within 24 hours of generation. After that, the correction is made with a credit note.

E-invoice and e-way bill are different

An e-invoice registers the invoice. An e-way bill covers the movement of goods. They are separate requirements with separate limits. Having one does not remove the need for the other, although the e-invoice system can be used to generate the e-way bill at the same time.

Frequently asked questions

What is the e-invoicing turnover limit?

Aggregate turnover above ₹5 crore in any financial year from 2017-18 onwards. This limit has applied since 1 August 2023.

Is e-invoicing required for sales to consumers (B2C)?

No. E-invoicing covers B2B invoices, exports and credit and debit notes. Bills to unregistered customers are not reported to the IRP.

My turnover is ₹2 crore. Do I need e-invoicing?

No, provided your aggregate turnover has not crossed ₹5 crore in any financial year since 2017-18. You continue with normal GST invoices.

My turnover crossed ₹5 crore in an earlier year but is lower now. Does e-invoicing still apply?

Yes. The test is whether turnover crossed the limit in any financial year from 2017-18, so it continues to apply.

What happens if a covered business issues an invoice without an IRN?

The invoice is not treated as a valid tax invoice, the buyer may be unable to claim input tax credit on it, and the supplier can face a penalty.

Does a composition dealer need e-invoicing?

A composition dealer issues bills of supply, not tax invoices, and bills of supply are outside e-invoicing.

This guide is general information for Indian businesses, not tax advice for your specific case. GST rules, limits and dates change; confirm the current position with your CA or on the GST portal (gst.gov.in) before acting.

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