Who is legally required to issue a GST e-invoice, and what is the current threshold?
Under Rule 48(4) of the CGST Rules, 2017, e-invoicing is mandatory for every registered business whose aggregate annual turnover exceeded ₹5 Crore in any preceding financial year from 2017-18 to the present. Applicable taxpayers must upload their invoice JSON payload to an authorized Invoice Registration Portal (IRP) to obtain a unique 64-character Invoice Reference Number (IRN) and a digitally signed QR code before issuing the invoice to a B2B buyer.
1. CBIC Turnover Slabs & Phased Implementation History
The Central Board of Indirect Taxes and Customs (CBIC) implemented electronic invoicing in carefully graduated phases to allow Indian enterprises to upgrade their accounting and ERP infrastructure:
| Phase | Notification No. | Turnover Limit | Effective Date | Status |
|---|---|---|---|---|
| Phase I | 13/2020-CT | Above ₹500 Crore | 01 October 2020 | Active |
| Phase II | 88/2020-CT | Above ₹100 Crore | 01 January 2021 | Active |
| Phase III | 05/2021-CT | Above ₹50 Crore | 01 April 2021 | Active |
| Phase IV | 01/2022-CT | Above ₹20 Crore | 01 April 2022 | Active |
| Phase V | 17/2022-CT | Above ₹10 Crore | 01 October 2022 | Active |
| Phase VI (Current) | 10/2023-CT | Above ₹5 Crore | 01 August 2023 | Mandatory Nationwide |
Aggregate turnover includes all taxable supplies, exempt supplies, exports of goods or services, and interstate supplies of persons having the same PAN, computed on an all-India basis. If your turnover crossed ₹5 Crore in FY 2021-22, but dropped to ₹3 Crore in FY 2024-25, you are still legally mandated to issue e-invoices because the rule applies if turnover exceeded the threshold in any previous financial year since GST rollout.
2. Entities and Sectors Exempted from E-Invoicing
Regardless of their aggregate annual turnover, the following specialized sectors are expressly exempted from generating e-invoices under Rule 48(4):
SEZ manufacturing and service units are exempt. However, SEZ Developers are not exempt and must issue e-invoices if crossing ₹5 Crore.
Scheduled commercial banks, non-banking financial companies, and insurance firms are exempted from generating IRNs on their financial services statements.
GTAs supplying transportation of goods by road in consignment notes are exempt from the e-invoicing mandate.
Suppliers of passenger transport services and multiplex movie screen operators issuing computerized booking admission tickets are exempt.
3. JSON Schema (INV-01) & How the IRN is Generated
E-invoicing does not mean creating an invoice on the government portal. Rather, you generate the invoice inside your local ERP or billing software (such as GST Munshi), export it as a standardized INV-01 JSON payload, and submit it to an approved Invoice Registration Portal (IRP).
Your billing tool formats the invoice with mandatory fields: Supplier GSTIN, Buyer GSTIN, Document Type, Non-overlapping Invoice Number, 6/8-digit HSN codes, Item Taxable Values, and CGST/SGST/IGST breakdown.
The IRP (e.g. NIC, Clear, Cygnet) runs an SHA-256 cryptographic hash on: Supplier GSTIN + FY + Doc Type + Doc Number. This creates the unique 64-character hexadecimal IRN, guaranteeing zero duplicate invoices across India.
The IRP returns the validated payload with a digital signature, the generated IRN, and a 500-byte digitally signed QR code containing key invoice vitals for offline verification by tax officers.
4. B2B Signed QR Code vs B2C Dynamic QR Code
Many accountants confuse the mandatory B2B e-invoice QR code with the B2C Dynamic UPI QR code. Here is the legal distinction:
| Feature | B2B E-Invoice QR Code | B2C Dynamic QR Code |
|---|---|---|
| Governing Provision | Rule 48(4) of CGST Rules | Notification 14/2020-Central Tax |
| Applicability Turnover | Above ₹5 Crore | Above ₹500 Crore |
| Contents of QR Code | Supplier & Buyer GSTIN, Invoice No, Date, Value, HSN, IRN, IRP Digital Signature | Merchant UPI ID, Invoice Amount, Invoice Date, Bank IFSC, Payment URL |
| Purpose | Tax compliance & ITC authentication | Digital payment facilitation for end-consumers |
5. 30-Day Reporting Time Limit & Integrated E-Way Bill Generation
The National Informatics Centre (NIC) and GSTN have enforced strict time windows for reporting documents to the Invoice Registration Portals:
Must upload tax invoices, credit notes, and debit notes to the IRP within 30 days of the invoice date. The IRP will reject any invoice dated more than 30 days prior to the submission timestamp.
While the 30-day hard block is currently prioritized for large taxpayers, MSMEs must generate IRNs prior to goods dispatch because goods cannot be legally transported without an e-way bill linked to a valid IRN.
When generating an e-invoice with dispatch details (Transporter ID, Vehicle Number, Distance), the IRP automatically generates the 12-digit E-Way Bill Number simultaneously with the IRN. You do not need to log into the E-Way Bill portal separately.
6. Severe Penalties for Non-Issuance Under Section 122
Operating under the mistaken belief that e-invoicing can be postponed invites punitive statutory actions:
Section 122(1)(i): ₹10,000 or 100% of the tax due on the invoice, whichever is higher, for failing to issue an invoice with an IRN.
Section 122(3)(e): Up to ₹25,000 per invoice for issuing an invoice without the mandatory digitally signed QR code.
Under Rule 48(5), the buyer cannot take credit. During scrutiny under Section 44AB tax audit, auditors will disallow all expenses.
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7. Frequently Asked Questions (FAQs)
Can I print an e-invoice on my standard office printer?▼
Yes. You can print the e-invoice on standard A4 paper, letterhead, or thermal receipt rolls. The only legal requirement is that the IRN and the 500-byte digitally signed QR code generated by the IRP must be clearly legible and scannable by optical scanners.
Does e-invoicing eliminate the need to file GSTR-1?▼
No. E-invoicing automatically populates Table 4A (B2B supplies) and Table 6B/6C (Exports) of your GSTR-1. However, you must still review, verify B2C sales, Nil-rated supplies, and formally submit and file your monthly or quarterly GSTR-1 return.
What should I do if an invoice has a minor typo after generating an IRN?▼
If the error is caught within 24 hours, cancel the IRN on the IRP and generate a fresh invoice with a new invoice number (never reuse the cancelled invoice number). If 24 hours have passed, issue a formal Credit Note with an IRN to nullify the invoice, and generate a new correct invoice.
How does GST Munshi automate e-invoicing for small businesses?▼
GST Munshi includes an institutional e-invoicing pipeline that connects directly to the NIC IRP APIs. When you click "Save & Generate Invoice", it validates your HSN codes, calculates taxes, uploads the payload to the IRP, fetches the IRN, embeds the signed QR code, and generates the PDF in under 1.5 seconds.
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