Key takeaways
- Threshold testing uses aggregate turnover across PAN and looks back to FY 2017-18 onward.
- The mandate applies to covered document/supply types, not every retail invoice.
- Notified entity classes remain excluded even if turnover exceeds the threshold.
- A valid IRN and signed QR code are central to a covered e-invoice.
- AATO ₹10 crore+ taxpayers face a 30-day reporting restriction from 1 April 2025.
How is e-invoice applicability tested?
First calculate PAN-level aggregate turnover for every financial year from 2017-18 onward. Once the notified threshold has been crossed in any relevant year, test the entity exclusion and document/supply type. Falling below ₹5 crore later does not automatically switch the mandate off.
| Test | Question |
|---|---|
| Turnover | Did PAN AATO exceed ₹5 crore in any relevant FY? |
| Entity | Is the supplier in a notified excluded class? |
| Document | Invoice, credit note or debit note? |
| Supply | B2B, export, deemed export or another covered category? |
| Date | Is the reporting within the IRP time restriction? |
What does the IRP do?
The supplier sends schema-valid invoice data to an authorised IRP. The IRP validates it, creates a unique Invoice Reference Number, digitally signs the payload and returns a signed QR code. Data is shared with GST/e-way bill systems. The supplier must still issue the invoice with all required particulars.
What is the 30-day reporting restriction?
From 1 April 2025, taxpayers with annual aggregate turnover of ₹10 crore and above cannot report covered invoices, credit notes or debit notes more than 30 days after the document date. The IRP rejects older records. This is an operational hard stop, so back-dated invoicing and month-end delays need preventive controls.
Which exclusions require careful classification?
The exclusion is entity/class based, not transaction-label based. For example, an SEZ unit is excluded while an ordinary unit of the same legal entity may require separate analysis; SEZ developers have also required careful distinction under CBIC clarification. Keep registration constitution and notified-class evidence.
How are cancellations and corrections handled?
An IRN may generally be cancelled on the IRP within 24 hours if the entire invoice is cancelled. It cannot be edited. After the window, issue the legally appropriate credit note or corrected document and align GSTR-1/GSTR-1A. Never reuse a cancelled document number contrary to invoice rules.
What are the common failures?
Errors include testing turnover GSTIN-wise, ignoring an earlier high-turnover year, treating B2C as e-invoice, assuming all SEZ-related supplies are excluded, reporting after 30 days, printing a self-generated QR instead of the signed IRP QR, and correcting GSTR-1 without fixing the IRP/document trail.
What controls should be automated?
Maintain a permanent applicability flag by GSTIN, validate recipient type and document date, block dispatch without IRN where required, alert before day 30, reconcile IRP to sales register and GSTR-1, and review cancellations daily. Preserve acknowledgement payloads for audit.
Primary sources
Frequently asked questions
What is the current e-invoice turnover threshold?
The general threshold is aggregate turnover exceeding ₹5 crore in any financial year from 2017-18 onward, subject to the current notification and excluded entity classes.
Does the threshold apply GSTIN-wise?
No. Aggregate turnover is PAN-based across registrations, while operational enablement and invoice reporting occur for the relevant GSTINs.
Which documents are commonly covered?
Covered B2B supplies, exports, deemed exports, credit notes and debit notes are within the mandate, subject to notification scope. Ordinary B2C invoices are not e-invoices.
Who is excluded?
Notified classes include specified insurers, banking/financial institutions, GTA, passenger-transport suppliers, multiplex admission suppliers, SEZ units and certain government bodies. Check the exact current notification and entity status.
What is the 30-day rule?
For taxpayers with AATO of ₹10 crore or more, covered invoices, credit notes and debit notes cannot be reported to the IRP more than 30 days after document date from 1 April 2025.
How long can an IRN be cancelled?
IRP cancellation is generally permitted within 24 hours. After that, use the legally permitted credit-note/amendment process; an IRN cannot simply be edited.
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