With e-invoicing notifications, the Government notifies the e-invoicing system rules, its applicability and date from when the notified rules will be effective.
The E-invoicing mandate is made applicable to all the companies having more than Rs. 20 Cr. turnover from 1st April, 2022 onwards. An invoice will be considered as a valid invoice for companies falling under the mandate only if it has IRN(Invoice Registration Number) on it. A summary of all the e-invoicing notifications released till date is as below:
24th Feb 2022: As per CGST Notification 01/2022-Central Tax dated 24-02-2022, GST e-invoice has been made mandatory for entities with turnover of Rs. 20 Cr and above.
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08 March 2021: From 1st April 2021, entities having turnover above Rs. 50 Cr. are required to generate E-Invoice as per GST Notification 05/2021-Central Tax, dt. 08-03-2021. The sandbox testing for e-invoice portal was enabled for companies with turnover above Rs. 50 CR – Rs 100 Cr.
1st Jan 2021: E-Invoicing becomes mandatory for companies with Rs. 100 Cr and above turnover.
29 November 2020: Penalty for non compliance with QR Code on B2C transactions waived from 1st December 2021 till 31st March 2021 provided compliance with the said provision is adhered from 1st April 2021 – GST notification 89/2020-Central Tax,dt. 29-11-2020
10th Nov 2020: E-invoicing is mandatory for taxpayers having aggregate turnover above Rs. 100 Cr from 01st Jan 2021 | GST Notification 88/2020-Central Tax, dt.10-11-2020
2nd November 2020: E-Invoicing enabled on Sandbox environment for companies having turnover Rs 100 Cr and above.
1 October 2020: E-invoicing went LIVE for companies with Rs. 500 CR and above turnover. However, CBIC released another notification which gave some leverage to companies having teething issues. As per the notification, 30 days of time period was allowed to generate IRN for any invoice prepared between 01.10.2020 to 31.10.2020. A one time relaxation for companies is provided until 31st October 2020. IRN still has to be issued but can be done within 30 days of invoice generation – GST Notification 73/2020-Central Tax ,dt. 01-10-2020.
30 September 2020: E-invoicing Notifications that were released on September 30:
- Certain class of persons were allowed to be exempted from issuance of E-Invoice and QR code shall be embedded with IRN which can be reproduced for verification instead of physical copies – GST Notification 72/2020-Central Tax ,dt. 30-09-2020
- Requirement of Dynamic QR Code on B2C invoices is deferred to 1st December 2020 – GST Notification 71/2020-Central Tax ,dt. 30-09-2020
- Turnover from FY 2017-18 to be considered for determining applicability of E-Invoicing and e-invoice shall be generated for export transactions as well – GST Notification 70/2020-Central Tax ,dt. 30-09-2020
5th Aug 2020: Version 1.03 of E-Invoicing API specification released for testing on the sandbox.
30 July 2020: Few more e-invoicing notifications were released to mandate e-invoicing from 1st October 2020:
- E-Invoicing applicability enhanced to entities having turnover above Rs. 500 Crores (Earlier it was Rs. 100 Crores). E-Invoice shall not be applicable to Special Economic Zone (SEZ)- e-Invoicing Notification 61/2020-Central Tax dt. 30-07-2020
- Revised version of e-invoice schema- Version 1.1, released via e-invoicing Notification 60/2020-Central Tax, dt. 30-07-2020. For details on changes as per new schema, you can check our blog E-Invoice Schema and E-Invoice Framework – Complete Guide.
23 July 2020: Taxpayers with a turnover of Rs. 500 cr & above in the FY 2019-20 are mandated to generate e-invoice from October 2020. Login to the e-invoice portal enabled.
23rd March 2020: The e-invoicing system was pushed to 1st Oct 2020 in the 39th GST Council Meeting on 16th March 2020.
- E-Invoicing Notification 14/2020-Central Tax dated 23rd April 2020 extended the requirement to generate dynamic QR Code for B2C transactions for companies with turnover above Rs 500 CR
- e-invoicing notification 13/2020-Central Tax dated 23rd April pushed the e-invoicing requirement for companies with turnover of Rs 100 CR above to 1st October 2020.
7th January 2020: E-Invoice APIs released
01st January 2020: CBIC prescribed schema for e-invoices under GST as per GST Notification 02/2020-Central Tax, dt. 01-01-2020. CGST Rules were updated to notify the e-invoice fields in the form GST INV-01. Also the E-Invoice API specification and guidance were released by the NIC- National Informatics Centre who has developed the first IRP system,
13th December 2019:
While the first 13-member officers’ committee, comprising central and state tax officials as well as the GST Network Chief Executive was set up to look into the feasibility of introducing e-invoicing system in India to streamline generation of invoices and easing compliance burden in May 2019. The e-invoicing mandate came in December 2019 via below GST Notifications:
Links to all notifications
- Notification 68/2019 : Generating Invoice reference number as per the conditions and format prescribed
- Notification 69/2019 : Specifies the common portal links for generating the IRN
- Notification 70/2019 : Applicability of e-invoice rules for B2B invoice for registered persons with aggregate turnover above INR 100 crore from 1st April 2020
- Notification 71 /2019 : Inclusion of provision in the CGST Act regarding QR code generation vide earlier Notification no 31/2019 dated 28th June 2019
- Notification 72/2019 : Generation of QR code for B2C invoices by registered persons with aggregate turnover above INR 500 crore from 1st April 2020
- Getting Invoice Reference Number (IRN)from Government prescribed portal will be mandatory for the notified class of registered person from 1st April 2020
- All the IRN generation portals will be managed and maintained by GSTN, the IT arm of Government, which is currently maintaining the GST Common Portal
- Registered persons with aggregate turnover above INR 100 crore to obtain IRN for all invoices issued to registered persons
- Registered persons with aggregate turnover above IRN 500 crore should include QR code for all invoices issued to unregistered persons
- Invoices issued by the notified persons as stated above which are not complying with the conditions stated above will not be considered as invoices
28th June 2019: As per the CGST Act 2017 fourth amendment released via GST Notification 31/2019-Central Tax, dt. 28-06-2019, Rule 46 was amended to add the following proviso after the fifth proviso ,with effect from a date to be notified later, namely:-
“Provided also that the Government may, by notification, on the recommendations of the Council, and subject to such conditions and restrictions as mentioned therein, specify that the tax invoice shall have Quick Response (QR) code.”.
In the said rules, in rule 49, after the third proviso, with effect from a date to be notified later, the following proviso was also inserted, namely:-
“Provided also that the Government may, by notification, on the recommendations of the Council, and subject to such conditions and restrictions as mentioned therein, specify that the bill of supply shall have Quick Response (QR) code.”.
GST Council gave its approval for e-invoicing system implementation in Sept 2019 and with the above mentioned e-invoicing notifications, necessary changes in the GST Act and rules have been formalized. The e-invoicing mandate does necessitate making updates to the internal systems and educating the teams and as well as supply chain so that the business can continue as usual. Here is a quick high-level impact on the businesses and their IT systems and processes:
|Transaction Type||Applicable to||Requirement||Timelines||Impact|
|B2B Invoices||Registered Person with turnover above Rs. 50 Cr||
|B2C Invoices||Registered Person with turnover above INR 500 Crore||Invoice output or print to have QR code||
While the e-invoicing system rules are applicable to a certain set of companies and also for a certain type of transactions, we recommend while making any changes to existing systems and while defining the standard practices for invoice generation and printing, a holistic and futuristic approach to be taken. Flexibility and provision to cover all transaction types and all document types, if considered in the IT systems now, adapting to future changes in the e-invoice mandate if any, will be quick and hassle-free.
You may read about the E-Invoicing Specifications and E-Invoicing Schema related updates here:
IRIS is one of the established ASP-GSP solution providers for GST compliance as well as Eway Bill Generation. For e-invoicing under GST, our approach is to make transition and integration with minimal changes in the data requirements.
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