E-Invoicing under GST — Complete Compliance Guide for FY 2025-26

E-Invoicing under GST
E-Invoicing under GST: Complete Compliance Guide for FY 2025-26 | ClearTax Advisors
GST Compliance · FY 2025-26

E-invoicing is no longer just for large corporations. With the threshold now at ₹5 crore turnover, lakhs of SMEs across India are covered — and many are still making costly mistakes. If you’re unsure whether your business needs to generate e-invoices, how to get an IRN, or what happens if you don’t comply, this guide is written for you.

1. What is E-Invoicing under GST?

E-invoicing — or electronic invoicing — under GST does not mean creating a PDF invoice and emailing it. Many business owners make this mistake. In the GST context, e-invoicing refers to a specific government-mandated process where every B2B invoice is reported in real time to a designated government portal called the Invoice Registration Portal (IRP), which then returns a unique Invoice Reference Number (IRN) and a digitally signed QR code.

Without this IRN, the invoice is legally invalid — your buyer cannot claim ITC on it, and you are liable for penalties. The IRP authenticates and timestamps every invoice, creating a seamless, auditable digital paper trail.

🔑 Key Concept E-invoicing is not about the format of your invoice — it is about registering it with the government’s IRP in real time and embedding the government-issued IRN and QR code on the document before handing it to your buyer.

This system was introduced by CBIC through Notification No. 70/2019 – Central Tax, dated 13.12.2019, and has since been extended in phases to cover progressively smaller businesses. The legal basis sits in Rule 48(4) of the CGST Rules, 2017, which makes it mandatory for notified taxpayers to prepare e-invoices exclusively through the IRP.

2. Who Must Generate E-Invoices? (Applicability & Turnover Limit)

CBIC has reduced the threshold in multiple phases. Here is the complete rollout history and current applicability as of FY 2025-26:

Phase Turnover Threshold Effective Date Notification
Phase 1₹500 crore and above01 Oct 2020No. 61/2020 – CT
Phase 2₹100 crore and above01 Jan 2021No. 88/2020 – CT
Phase 3₹50 crore and above01 Apr 2021No. 05/2021 – CT
Phase 4₹20 crore and above01 Apr 2022No. 01/2022 – CT
Phase 5₹10 crore and above01 Oct 2022No. 17/2022 – CT
Phase 6 (Current)₹5 crore and above01 Aug 2023No. 10/2023 – CT

For FY 2025-26, the rule is: if your aggregate annual turnover (across all GSTINs, all states) exceeded ₹5 crore in any previous financial year from FY 2017-18 onwards, you are required to generate e-invoices for the transaction types listed below.

Which Transactions Require E-Invoicing?

  • B2B invoices — supply of goods or services to a registered person
  • Exports (with or without payment of IGST)
  • Supplies to SEZ units or SEZ developers (with or without payment of IGST)
  • Credit Notes and Debit Notes issued against e-invoices
  • Deemed exports (supply to EOU, STPI units, etc.)
📌 Important Note The ₹5 crore threshold is checked against aggregate PAN-level turnover — not GSTIN-level. If your company has 3 GSTINs with individual turnovers of ₹2 crore, ₹2 crore, and ₹3 crore, your aggregate PAN turnover is ₹7 crore and you are mandatorily covered.

3. Who is Exempt from E-Invoicing?

Even if a taxpayer exceeds the ₹5 crore threshold, certain categories of registered persons are entirely exempt from the e-invoicing mandate as per CBIC Notification No. 13/2020 – Central Tax (as amended):

  • Insurance companies, banking companies, and financial institutions (including NBFCs)
  • Goods Transport Agencies (GTAs) supplying services for transportation of goods by road
  • Passenger transport service providers (airlines, bus operators, etc.)
  • Multiplexes (cinema halls) issuing admission tickets
  • SEZ units (note: SEZ developers are NOT exempt — only units)
  • Government departments and local authorities

Additionally, certain transaction types are exempt even if the taxpayer is covered:

  • B2C invoices (sales to end consumers / unregistered buyers)
  • Nil-rated, exempted, and non-GST supplies
  • Invoices under the Bill of Supply (composition dealers, exempt goods)
  • Delivery challans
  • Free samples / gifts (where no consideration is charged)

4. IRP Portal and IRN — What They Mean

Government-approved IRP portals for GST e-invoice IRN generation — NIC, ClearTax, Tally
CBIC-approved IRP portals for e-invoice generation — all are interoperable and return the same IRN

What is the IRP (Invoice Registration Portal)?

The Invoice Registration Portal is a government-designated digital gateway maintained by NIC (National Informatics Centre) and certain CBIC-authorised private operators. When you upload your invoice data in the prescribed JSON format, the IRP validates it, assigns a unique IRN, generates a digitally signed QR code, and sends the data to the GST system (for auto-population of GSTR-1) and to the e-way bill system (if applicable).

CBIC has approved multiple IRP operators:

  • NIC IRP — einvoice1.gst.gov.in (Free, government portal)
  • Clear (formerly ClearTax) — einvoice.cleartax.in (Private IRP)
  • Tally Solutions — via TallyPrime integration
  • Infosys, MasterGST, and others (CBIC-approved)

All IRPs are interoperable — the IRN generated is unique and valid regardless of which portal you use.

What is an IRN?

The Invoice Reference Number (IRN) is a 64-character alphanumeric hash generated by the IRP using the following parameters: your GSTIN + financial year + document type + document number. It is unique for every invoice. No two invoices — even from different taxpayers — can have the same IRN. The IRN, along with the embedded QR code, must be printed on every e-invoice you issue.

5. Step-by-Step: How to Generate an E-Invoice

  • Prepare Invoice Data in Your Accounting Software

    Generate the invoice as usual in your software (Tally, Zoho Books, Busy, etc.). Most modern GST-compliant software supports direct IRP integration. Ensure all mandatory fields are filled — GSTIN of supplier and buyer, HSN/SAC codes, invoice value, GST amounts, place of supply.

  • Generate JSON in the CBIC-Prescribed Format

    Your software will export the invoice data in the e-invoice JSON schema (version 1.1 as of FY 2025-26). This schema is defined by CBIC and available at einvoice1.gst.gov.in. If you don’t use integrated software, you can manually upload the JSON on the NIC IRP portal.

  • Upload JSON to IRP via API or Portal

    Submit the JSON to your chosen IRP — either directly through the web portal or via API integration built into your accounting software. The IRP performs real-time validation: GSTIN existence, PAN match, duplicate check, and schema validation.

  • IRP Returns IRN + Signed JSON + QR Code

    Upon successful validation, the IRP returns a signed JSON file containing the IRN (64-character hash), a digitally signed QR code, and the SignedInvoice payload. This entire response is stored by the IRP for 24 hours (after which it is not accessible from IRP — you must store it yourself).

  • Print IRN and QR Code on Invoice

    Embed the IRN and QR code on the final invoice PDF/printout handed to your buyer. The QR code must be machine-readable and contain supplier GSTIN, buyer GSTIN, invoice number, date, value, number of line items, HSN of main item, and the IRN itself.

  • Invoice Flows Automatically to GSTR-1

    The IRP pushes validated invoice data to the GST portal in real time. This auto-populates your GSTR-1 (Table 4A/4B/6A/7). No need for separate manual entry — this is one of the biggest compliance benefits of e-invoicing.

✅ Pro Tip If you are using Tally.ERP 9 (Release 6.6+) or TallyPrime, e-invoice generation is built in. In TallyPrime, just enable GST e-Invoice in the Company GST Details screen, and Tally handles JSON generation and IRP communication automatically. You won’t need to log into the IRP portal manually.

6. Mandatory Fields in an E-Invoice

The CBIC e-invoice schema has over 100 data fields, but only a subset are mandatory. Missing even one mandatory field will cause the IRP to reject the JSON upload with an error code. Here are the critical ones:

Section Mandatory Fields
Supplier Details GSTIN, Legal Name, Address (building, location, pin, state code)
Buyer Details GSTIN, Legal Name, Place of Supply (state code), Delivery address
Invoice Header Invoice Type (B2B, EXPWP, EXPWOP, SEZWP, SEZWOP, DEXP), Invoice Number, Invoice Date
Item Details HSN/SAC Code, Quantity, Unit Price, Discount (if any), Taxable Value, GST Rate, CGST/SGST/IGST Amount
Invoice Value Total Invoice Value (sum of taxable value + GST + other charges – discounts)
⚠️ Common Rejection Cause If the GSTIN of the buyer is inactive or cancelled on the date of invoice, the IRP will reject the JSON with error code 2150 (“Supplier GSTIN is not Active”) or 2151 for buyer. Always verify buyer GSTIN on gst.gov.in before generating the invoice.

7. Cancellation of E-Invoice — Rules & Time Limit

Once an IRN is generated, it cannot be edited or amended on the IRP. The only option is cancellation. Here are the rules:

  • Time Limit: An e-invoice can be cancelled on the IRP only within 24 hours of IRN generation.
  • Partial Cancellation: Not allowed — you must cancel the entire invoice.
  • After 24 Hours: Cancellation is not possible on the IRP. You must issue a Credit Note referencing the original IRN to reverse the transaction.
  • E-Way Bill Link: If an e-way bill has been generated against the IRN, you must first cancel the e-way bill before cancelling the e-invoice.
  • GSTR-1 Impact: A cancelled IRN will appear in GSTR-1 as a cancelled document. Ensure your GSTR-1 reflects the cancellation before filing.
📋 Real Client Scenario

A Mumbai-based electronic components distributor (turnover ₹18 crore) generated an e-invoice for ₹4.2 lakh but entered the buyer’s GSTIN incorrectly. By the time they noticed, it was 30 hours after generation. They could no longer cancel on the IRP. They issued a credit note with proper IRN citing the original, corrected the buyer details, and generated a fresh e-invoice.

Lesson: Always double-check buyer GSTIN before generating the IRN. Post-generation corrections require a credit note + new e-invoice, doubling the documentation workload.

8. How E-Invoicing Impacts GSTR-1 and GSTR-3B

E-Invoice IRN generation leads to GSTR-1 auto-population and buyer's ITC in GSTR-2B
E-Invoice → GSTR-1 auto-populated → Buyer’s GSTR-2B updated → ITC claimed in GSTR-3B

GSTR-1 Auto-Population

When you generate an IRN, the IRP pushes the invoice data directly to the GST portal. This auto-populates GSTR-1 (Table 4A for B2B, Table 6A for exports) in real time. You do NOT need to manually re-enter invoice details in GSTR-1 — this significantly reduces errors and saves time, especially for businesses with high invoice volumes.

However, you should always review auto-populated data in GSTR-1 before filing. Occasionally, data mismatches or IRP validation differences can cause issues. Login to the GST portal (gst.gov.in), go to Returns → GSTR-1 → Auto-populated section to verify.

Impact on Buyer’s GSTR-2B and ITC

For your buyers, e-invoiced supplies show up automatically in their GSTR-2B as eligible ITC. Buyers of e-invoiced goods and services can claim ITC with much higher confidence, as the IRP validation chain ensures supplier compliance. This is a major driver for B2B buyers preferring vendors who issue proper e-invoices — any supplier not complying with e-invoicing may face pressure from their buyers, who risk losing ITC.

E-Way Bill Integration

For consignments where an e-way bill is required (typically goods valued above ₹50,000 moving more than 50 km), the IRP also generates the e-way bill simultaneously using the invoice data, provided you include the transport details in the JSON. This eliminates the need to separately log into the e-way bill portal for invoices that already have an IRN.

9. Penalties for Non-Compliance

⚠️ Consequences of Not Generating E-Invoices

  • Penalty under Section 122(1)(a) CGST Act: ₹10,000 per invoice or 100% of the tax due on the supply, whichever is higher. For a single invoice with GST of ₹50,000, the penalty could be ₹50,000 — just for that one invoice.
  • Buyer Loses ITC: An invoice without a valid IRN is not a valid “tax invoice” under Rule 48(4). The buyer cannot claim ITC on it. This can seriously damage your business relationships, especially with large clients who are fastidious about ITC compliance.
  • GST Scrutiny and Notices: GSTN’s AI-driven mismatch detection compares e-invoice data, GSTR-1, and GSTR-3B. Consistent non-generation of e-invoices can trigger Section 61 scrutiny notices or Section 65/66 GST audits.
  • E-Way Bill Complications: From April 2023, CBIC has linked e-way bill generation to IRN — if you haven’t generated an IRN for a consignment that requires an e-invoice, you may face issues generating the e-way bill.
  • Input Tax Credit Reversal Demand: If a GST officer determines that the supplier was liable but failed to generate e-invoices, and the buyer claimed ITC, the department can demand reversal + interest from the buyer under Section 74.

10. Common Mistakes to Avoid

Based on common compliance issues faced by SMEs, here are the most frequent e-invoicing errors:

Mistake Impact How to Avoid
Generating e-invoice only for some B2B invoices (not all) Selective non-compliance; triggers mismatch between GSTR-1 and e-invoice data Ensure your billing software mandates IRN for all B2B invoices automatically
Printing the invoice before IRN generation Invoice handed to buyer without valid IRN/QR code — legally invalid Set process: IRN generated first, then PDF printed with embedded IRN
Wrong GSTIN of buyer entered IRP rejects, or IRN generated against wrong GSTIN — buyer can’t claim ITC Verify buyer GSTIN on gst.gov.in before generating invoice
Incorrect HSN code (2-digit instead of 4/6-digit) IRP rejection; GSTR-1 HSN mismatch Use CBIC’s HSN search on cbic.gov.in to confirm correct code
Attempting to amend an e-invoice directly IRP does not allow amendments; amended invoices are legally invalid Cancel within 24 hrs, or issue credit note + new IRN
Not archiving IRP response (Signed JSON) IRP stores data for only 24 hours — loss of signed data means re-registration is impossible Store all signed JSON responses in your system immediately on generation

E-Invoicing Compliance Checklist for SMEs

  • Verified that aggregate PAN-level turnover exceeds ₹5 crore in any prior FY
  • Accounting software integrated with IRP (or using NIC IRP web portal)
  • All B2B invoices, credit notes, debit notes, export invoices are covered
  • IRN is generated before the invoice is dispatched or emailed to the buyer
  • QR code and IRN are printed/embedded on every invoice
  • Signed JSON from IRP stored in your records for each invoice
  • Cancelled invoices: cancelled on IRP within 24 hours, or credit note issued after
  • GSTR-1 auto-populated data reviewed every month before filing
  • Team trained — accounts staff understand the 24-hour cancellation window

11. Frequently Asked Questions

Q1. What is the turnover limit for e-invoicing in FY 2025-26?
As of FY 2025-26, all registered taxpayers with aggregate annual turnover exceeding ₹5 crore in any preceding financial year (from FY 2017-18 onwards) must generate e-invoices for B2B supplies, exports, and supplies to SEZ units/developers.
Q2. Is e-invoicing mandatory for B2C transactions?
No. E-invoicing is currently mandatory only for B2B transactions, exports, credit/debit notes, and supplies to SEZ units. B2C invoices are exempt from the e-invoicing mandate. However, CBIC is expected to extend it to B2C in future phases.
Q3. My turnover crossed ₹5 crore only in FY 2024-25. Do I need e-invoicing from FY 2025-26?
Yes. Since your turnover exceeded ₹5 crore in FY 2024-25 (a preceding financial year), you are mandatorily covered from 1 April 2025. The rule triggers as soon as your aggregate PAN-level turnover crosses the threshold in any previous year.
Q4. Can I cancel an e-invoice after 24 hours?
No. Cancellation on the IRP is available only within 24 hours of IRN generation. After this window, you must issue a Credit Note referencing the original IRN to reverse the transaction. Then generate a fresh e-invoice with the correct details.
Q5. Does e-invoicing apply to composition dealers?
No. Composition dealers issue a Bill of Supply (not a tax invoice), and they are not required to charge GST on their supplies. E-invoicing does not apply to composition dealers.
Q6. My software doesn’t support IRP integration. What do I do?
You can use the NIC IRP web portal (einvoice1.gst.gov.in) to manually upload invoice JSON or use the web form. However, this is error-prone for high-volume businesses. We strongly recommend switching to GST-compliant software like Tally, Zoho Books, or Busy that has built-in IRP integration.
Q7. Will e-invoicing eliminate the need to file GSTR-1?
Not entirely. E-invoicing auto-populates B2B invoice data in GSTR-1, but you still need to log in and file GSTR-1 each month. You must also manually add B2C data, HSN summary, and any adjustments. The filing requirement remains — e-invoicing just reduces the manual entry workload significantly.
🔗 Official Resources

NIC E-Invoice Portal — Generate IRN, verify IRN, cancel e-invoice
GST Portal (gst.gov.in) — Verify GSTIN, file returns, access GSTR-2B
CBIC Official Website — All GST notifications and circulars
GST Helpdesk Tutorials — Video guides for e-invoicing process

Not Sure If You’re Fully Compliant?

E-invoicing errors are silent — they don’t show up until a GST notice arrives or your buyer loses ITC. Our team reviews your current billing process, software setup, and filing history to identify gaps before the department does.

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