E-Invoice Under GST — Who Must Generate It, When, and How

E-invoicing under GST is no longer just a large-business requirement. With the turnover threshold now at ₹5 crore, a large number of MSMEs and traders across India are covered — and many don't even know it. This guide explains exactly who must generate e-invoices, when, the process, and the consequences of non-compliance.

What Is E-Invoicing Under GST?

E-invoicing does NOT mean creating your invoice on a government website. It means uploading your already-prepared invoice to the Invoice Registration Portal (IRP) and getting an Invoice Reference Number (IRN) and a QR code in return. That IRN-stamped invoice is the valid e-invoice for GST purposes. Once the IRN is generated, the invoice data is automatically pushed to the GST portal and pre-populates your GSTR-1 and e-way bill (if applicable).

Who Must Generate E-Invoices? — Turnover Thresholds

▸ ₹500 Crore and above — Mandatory from 1 October 2020 ▸ ₹100 Crore and above — Mandatory from 1 January 2021 ▸ ₹50 Crore and above — Mandatory from 1 April 2021 ▸ ₹20 Crore and above — Mandatory from 1 April 2022 ▸ ₹10 Crore and above — Mandatory from 1 October 2022 ▸ ₹5 Crore and above — Mandatory from 1 August 2023 (CURRENT THRESHOLD)

⚠ The ₹5 crore threshold is calculated on AGGREGATE turnover across ALL GSTINs under the same PAN — not just one registration. If your group's combined turnover crosses ₹5 crore, every GSTIN in that group is covered.

Which Documents Require E-Invoicing?

REQUIRED (B2B, Exports, SEZ): ✓ Tax Invoices ✓ Credit Notes linked to B2B invoices ✓ Debit Notes linked to B2B invoices NOT REQUIRED: ✗ B2C invoices (sales to unregistered buyers) ✗ Nil-rated or exempt supplies ✗ Input Service Distributor (ISD) invoices ✗ Banking, insurance, financial institutions ✗ Passenger transportation services ✗ Multiplex cinema tickets

How to Generate an E-Invoice — Step by Step

Step 1 — Prepare your invoice in your billing software with all mandatory fields: supplier GSTIN, recipient GSTIN, HSN code, taxable value, GST rate and amount, place of supply. Step 2 — Upload to IRP via: (a) GST-enabled accounting software like Tally, Busy, Zoho Books which auto-push to IRP; (b) NIC IRP portal at einvoice1.gst.gov.in; or (c) API integration for high-volume businesses. Step 3 — IRP validates the invoice, generates IRN (64-character hash), digitally signs it, and returns a QR code. Process takes seconds. Step 4 — Print the IRN and QR code on your invoice before issuing to buyer. Step 5 — IRP automatically shares data with GST portal, pre-populating GSTR-1 and generating e-way bill if consignment exceeds ₹50,000.

Can You Cancel an E-Invoice?

Yes — but only within 24 hours of IRN generation. After 24 hours, you must issue a Credit Note to reverse the transaction. Partial cancellation is not allowed. Once cancelled, that IRN can never be reused.

Consequences of Not Generating E-Invoice

🔴 For the Supplier: Invoice is invalid under GST law. Penalty under Section 122 — ₹10,000 per invoice or tax amount, whichever is higher. 🔴 For the Buyer: ITC on an invalid e-invoice is not admissible. Always verify IRN on invoices you receive. 🔴 GSTR-1 Impact: Without IRN, invoice won't auto-populate in GSTR-1. Manual B2B entry is blocked for covered taxpayers from FY 2024-25 onwards.

Key Compliance Points for FY 2025-26

✓ 30-day IRN time limit: Mandatory for turnover above ₹100 Cr. Expected to extend to ₹5–100 Cr range soon. ✓ 5 authorised IRPs: NIC, Clear, Cygnet, E&Y, IRIS — use any one. ✓ IMS Integration: E-invoice data flows into IMS allowing buyers to accept/reject/defer — directly affecting ITC. ✓ Export Invoices: E-invoicing mandatory, integrates with ICEGATE customs system.

Quick Reference Summary

WHO: Aggregate turnover ≥ ₹5 Crore (all GSTINs under same PAN) WHAT: B2B Tax Invoices, Credit Notes, Debit Notes, Export Invoices WHERE: Any of 5 authorised IRPs WHEN: At time of invoice (30-day limit for ₹100Cr+) PENALTY: ₹10,000 per invoice or tax amount — whichever is higher BUYER RISK: ITC lost if supplier fails to generate valid IRN

Need to check if your business is covered under e-invoicing? Visit gstvala.com for our free E-Invoice Eligibility Checker and compliance guides.