The GST Network (GSTN) has announced significant E-Way Bill and E-Invoice system updates effective from 1st January 2025. These changes are designed to enhance compliance, security, and integration with other systems. Below is a detailed summary of the new validations and updates.

1. Document Date Restrictions for E-Way Bill Generation

To ensure accuracy and prevent misuse, strict rules are being implemented concerning the document date for E-Way Bill generation:

• 180-Day Validity Rule:
  E-Way Bills cannot be generated for documents dated more than 180 days before the date of E-Way Bill generation.
  Example: For an E-Way Bill generated on 1st January 2025, the document date must not be earlier than 5th July 2024.
  This rule also applies to:
  a. EWB Generation along with or by IRN
  b. Part-A slips.
  c. Consolidated E-Way Bills where Part-A slip details are updated with Part-B information.

Impact :

Taxpayers ensure timely preparation and validation of documents to meet the 180-day E-Way Bill generation limit.

Transporters coordinate with businesses for timely document availability to avoid disruptions in goods movement.

Goods in godowns, warehouses, or hubs with pending Part B should be checked frequently, with regular coordination between suppliers and buyers to ensure smooth operations.

2. Extension Limitations for E-Way Bills

The extension period for E-Way Bills is capped at 360 days from their original generation date.

• Validation Details:
  a. On the day of extension, if the difference between the E-Way Bill generation date and the current date exceeds 360 days, the extension will be denied.
  b. If the difference between the current date and the ‘ewayBillDate’ is less than 360 days, the extension is allowed. However, if the new validity date after the extension exceeds 360 days, the system will cap the validity to the maximum permissible period of 360 days.
  Example: For an E-Way Bill generated on 28th December 2023 and extended on 17th December 2024 (355 days later), the remaining distance of 2000 km would typically allow a 10-day extension, making the validity 27th December 2024. However, due to the 360-day restriction, the validity will be capped at 22nd December 2024, regardless of the distance.

Impact :

Taxpayers with complex supply chains must plan logistics to meet the extension limit, as delays may increase operational pressure.

Transporters must optimize routes and schedules, as long delays may no longer be accommodated.

3. Multi-Factor Authentication (MFA)

To bolster security, GSTN is expanding the use of Multi-Factor Authentication (MFA). MFA requires users to log in with a username, password, and a One-Time Password (OTP) sent to their registered mobile number or other approved platforms like the Sandes app or the NIC-GST Shield app.

• Implementation Timeline:
  a. Mandatory for taxpayers with Annual Aggregate Turnover (AATO) exceeding ₹20 Crores starting 1st January 2025.
  b. From 1st February 2025, it will apply to taxpayers with AATO exceeding ₹5 Crores.
  c. Effective 1st April 2025, MFA will be compulsory for all taxpayers and users.

Taxpayers are encouraged to activate MFA immediately to ensure seamless access to the systems.

Note: OTP authentication is tied to individual user accounts, with sub-users of a GSTIN having separate authentication based on their registered mobile numbers in the e-Way Bill and e-Invoice systems. Once registered for 2-Factor Authentication, it applies to both systems seamlessly.

Impact :

Taxpayers must update their registered mobile numbers and enable MFA to ensure smooth access.

Transporters generating E-Way Bills must activate MFA to avoid login disruptions.

For users of IRIS as their service provider, there is no impact. You can continue accessing IRIS GST and IRIS Logix without disruptions.

4. Integration with Railways for PWB/RR/Leased Wagon Receipt No

E-Waybill has been integrated with Railways for goods sent through Parcel and FOIS system. Hence, it is mandatory to specify the category of goods sent. They can be classified as P-PMS, F-FOIS and L-Leased Wagons. During generation of E-way Bill, if the mode of transport is Rail (“transMode” = 2) then “transDocNo” should be passed with the following format where Part-B is updated. The PWB for PMS is 10 digits and RR No. for FOIS is 9 digits.
Note: Presently, PWB/RR/LWR No format along with parameters such as Transport Document Number, Transport Doc Date, Document No, Document Date, Supplier GSTIN, Buyer GSTIN, and Total Invoice Value, is being verified, and alerts are given in response. In a few days, instead of alerts, it will be made mandatory to pass the valid PWB/RR/LWR No and also in the specified format.

Impact :

Transporters must ensure accurate entry of the RR number/eT-RRs in the EWB system to ensure smooth tracking and verification of goods transported via Indian Railways. Incorrect entries could lead to delays, complications, and issues with compliance, affecting the timely movement of goods.

The new system introduces error codes and alerts for validation purposes:

• Error Codes:
  a. 820: E-Way Bill cannot be generated for document dates older than 180 days.
  b. 821: E-Way Bill extensions are limited to 360 days.
  c. 4043: E-Way Bill cannot be generated via E-Invoice API for document dates older than 180 days.

Alerts for Railway Document Numbers:
Incorrect format or mismatched details will trigger alerts. Examples include:
a. “Incorrect RR No. format.”
b. Alerts indicating mismatched fields such as TransDocNo, fromGstin, or totInvValue.

Call to Action for Taxpayers and Businesses

Taxpayers and businesses must familiarize themselves with these updates to ensure compliance. Testing environments are available for early adoption. The GSTN urges taxpayers to:

• Update compliance processes.
• Activate MFA for secure access.
• Verify document dates and extensions before generating or modifying E-Way Bills.

These E-way Bill and E-Invoice system updates signify a robust step towards streamlined and secure tax compliance in India. This comprehensive overview ensures that all critical updates and validations are incorporated, aligning your business processes with the latest requirements.