Form ENR-03 Guide for Unregistered Dealers to Generate E-Way Bills

With the introduction of Form ENR-03, unregistered dealers can now seamlessly enroll on the E-Way Bill (EWB) portal and generate e-Way Bills for the movement of goods. This development, effective from February 11, 2025, is in line with GST Notification No. 12/2024 dated July 10, 2024. In this article, we will explore the significance of Form ENR-03, its step-by-step application process, penalties for non-compliance for non generational of EWB, and how unregistered dealers can benefit from this enrolment feature.

What is Form ENR-03?

Form ENR-03 is a newly introduced facility that allows unregistered dealers and persons engaged in goods transportation to enroll on the EWB portal. This enrolment provides them with a unique 15-character Enrolment ID, which can be used in place of a GSTIN to generate e-Way Bills. The objective is to streamline compliance for businesses and individuals who do not have GST registration but are involved in goods movement.

Who Needs to Enroll Using Form ENR-03?

Unregistered persons (URPs) engaged in the movement of taxable goods must enroll using Form ENR-03 if they wish to generate e-Way Bills. This is particularly relevant for:

Unregistered Suppliers (selling goods without GST registration)
Unregistered Buyers (purchasing and transporting goods)
Casual Taxable Persons (occasional sellers, trade fairs, exhibitions)
Any entity not GST registered transporting goods in India

Step-by-Step Guide to Enrolling on the EWB Portal Using Form ENR-03

1. Accessing Form ENR-03 on the EWB Portal

To begin the enrolment process, follow these steps:

Visit the E-Way Bill portal.
Navigate to the ‘Registration’ tab in the main menu.
Select ‘Enrolment for Unregistered Persons (ENR-03)’.

2. Filling Out Form ENR-03

Once you have accessed Form ENR-03, complete the following fields:

State Selection: Choose the state where your business operates.
PAN Verification: Enter your PAN, which will be validated against the database.
Type of Enrolment: Select the nature of enrolment (e.g. Unregistered Supplier of Goods Unregistered Recipient of Goods etc.)
Address Details: Provide a valid business or operational address.
Email Address: Enter a valid email address.
Mobile Number & OTP Verification: Enter a mobile number, which will be verified through an OTP.

3. Creating Login Credentials

Choose a username and check its availability.
Set a password for future login.
Submit the form. Upon successful enrolment, a 15-character Enrolment ID will be generated.
A confirmation acknowledgment will be displayed on the screen.

4. Generating an E-Way Bill Using Enrolment ID

Once enrolled, the unregistered person can generate an e-Way Bill as follows:

Log in to the EWB portal using the newly created credentials.
Click on ‘Generate New’.
The Enrolment ID will automatically populate in place of a GSTIN.
Enter other necessary details and proceed with e-Way Bill generation.

Penalties for Non-Compliance

Failure to comply with e-Way Bill requirements, including the use of Form ENR-03, can lead to strict penalties:

Monetary Penalties: Transporting goods without an e-Way Bill can result in a fine of Rs. 10,000 or the tax amount evaded, whichever is higher.
Goods Confiscation: Authorities have the right to seize goods until EWB is generated and levy penalties.
Legal Consequences: Repeated violations may attract further legal action.

Key Benefits of Form ENR-03

Avoids Unnecessary GST Registration – Unregistered persons can generate e-Way Bills without registering under GST.
Simplifies Compliance – Reduces the burden on small businesses and casual traders.
Reduces Dependency on Transporters – No need to rely on transporters for e-Way Bill generation.
Enhances Goods Movement Tracking – Helps the government monitor and formalize the economy.
Legal Recognition: Provides a structured framework for businesses operating outside the GST regime.
Prevents Penalties: Proper enrolment using Form ENR-03 helps businesses avoid fines and legal issues.

Conclusion

The introduction of Form ENR-03 marks a significant step in simplifying e-Way Bill compliance for unregistered dealers. By obtaining an Enrolment ID, unregistered persons can now legally and efficiently generate e-Way Bills, ensuring smoother business operations.