Who must issue e-invoices
You must e-invoice if your aggregate turnover in any financial year from 2017-18 onwards exceeded ₹5 crore (Notification 70/2020-Central Tax set the “any preceding financial year” test). The ₹5 crore limit has applied since 1 Aug 2023 (Notification 10/2023-Central Tax). Aggregate turnover counts every GSTIN on your PAN together.
It covers documents for:
- supplies to registered persons (B2B),
- exports,
- and, from 1 Jan 2027, purchases from unregistered suppliers where you pay tax under reverse charge, and imports of services (Notification 04/2026-Central Tax).
Invoices, credit notes and debit notes all need an IRN.
Who is left out
| Exempt class | Where it comes from |
|---|---|
| Special Economic Zone units | Notification 61/2020-Central Tax |
| Government departments and local authorities | Notification 23/2021-Central Tax |
| Insurers, banks and financial institutions, including NBFCs | CGST rule 54(2) |
| Goods transport agencies (road) | CGST rule 54(3) |
| Passenger transport services | CGST rule 54(4) |
| Cinema admission in multiplex screens | CGST rule 54(4A) |
Check the current notification if you think you fall in one of these classes. The list has changed over the years.
How it works, step by step
- You make the invoice in your billing software as usual.
- The invoice data goes to an IRP, as a JSON file upload or through an API.
- The IRP checks it, gives it an IRN (Invoice Reference Number), and signs a QR code.
- You print the QR code on the invoice. Rule 48(5) of the CGST Rules says an invoice that must be e-invoiced, but is issued any other way, “shall not be treated as an invoice”.
The IRP does not make the invoice. It registers an invoice you have already made.
Time limits
| Rule | Limit | Source |
|---|---|---|
| Reporting to the IRP, if aggregate turnover is ₹10 crore or more | Within 30 days of the document date | GSTN advisory, 5 Nov 2024 (from 1 Apr 2025) |
| Reporting, if turnover is below ₹10 crore | No 30-day block today | Same advisory |
| Cancelling an IRN | Within 24 hours of generation; not while a valid e-way bill exists | NIC e-invoice API documentation |
| Login to the e-invoice portal | Username, password and OTP for all users | GSTN advisory, 17 Dec 2024 (all users from 1 Apr 2025) |
Worked example. Kaveri Agencies, Mysuru, has an aggregate turnover of ₹14 crore. It issues invoice KA/0412 on 1 Apr for ₹1,18,000 (₹1,00,000 + ₹18,000 GST). The last day to get its IRN is 30 Apr. From 1 May the IRP will refuse it, and an invoice without an IRN is not treated as an invoice, so Kaveri’s buyer cannot rely on it.
Common mistakes
- Wrong GSTIN or state code for the buyer. The IRP refuses it. Check GSTINs when you create the customer.
- Missing HSN codes. If last year’s aggregate turnover was above ₹5 crore, invoices must show 6-digit HSN codes (Notification 78/2020-Central Tax).
- Waiting for month end. With the 30-day limit, batch uploads at month end can miss documents.
- Editing after the IRN. Once an IRN exists, the invoice is fixed. Correct it with a credit or debit note.
How MyRecords helps
- Creates the e-invoice upload file in the IRP’s format, straight from your submitted invoices. You upload it on the portal.
- Records the IRN, acknowledgement number and date back on the invoice, and prints the signed QR. You can also paste the portal’s response as it is.
- Records a cancellation made on the portal within 24 hours. After that, it points you to a credit note.
- Uses the same tax figures as your GSTR-1 file, so the IRN and the return cannot disagree.
- Direct IRN generation on the portal’s API, through NIC direct access or a GST Suvidha Provider, is built and available once you connect your API login. It has not yet made a live call for a client.
See E-invoicing in MyRecords for screens, or check whether e-invoicing applies to you with the free tools.