Updated on 10th Nov 2020: E-invoicing is mandatory for taxpayers having aggregate turnover above Rs. 100 Cr from 01st Jan 2021 | GST Notification 88/2020 Updates of e-invoicing Notification on 5th Aug 2020: E-invoicing System Changes: Version 1.03 of E-Invoicing API specification is released for testing on 05th Aug 2020 in the sandbox.
Updated on 10th Nov 2020: E-invoicing is mandatory for taxpayers having aggregate turnover above Rs. 100 Cr from 01st Jan 2021 | GST Notification 88/2020
Updates of e-invoicing Notification on 5th Aug 2020: E-invoicing System Changes: Version 1.03 of E-Invoicing API specification is released for testing on 05th Aug 2020 in the sandbox.
The E-invoicing mandate is made applicable to all the companies having more than Rs. 500 Cr. turnover from October 1, 2020 on wards. An invoice will be considered as a valid invoice for companies falling under the mandate only if it has IRN on it. 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. Another important point to note is – QR Code on B2C invoices is deferred till 1st Dec 2020.
With e-invoicing notifications, the Government notifies the e-invoicing system rules, its applicability and date from when the notified rules will be effective. A summary of e-invoicing notifications is as below:
1 October 2020: E-invoicing notification that was released on the day when e-invoicing went live:
30 days of time period allowed to generate IRN for any invoice prepared between 01.10.2020 to 31.10.2020 – GST Notification 73/2020-Central Tax ,dt. 01-10-2020.
30 September 2020: E-invoicing Notifications that were released on September 30:
- Turnover from FY 2017-18 shall 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
- Requirement of Dynamic QR Code on B2C invoices is deferred to 1st December 2020 – GST Notification 71/2020-Central Tax ,dt. 30-09-2020
30 July 2020: Few more e-invoicing notifications were released to mandate e-invoicing from 1st October 2020:
- Revised version of e-invoice schema- Version 1.1, released via e-invoicing Notification 60/2020 Central Tax dated 30 July 2020. For details on changes as per new schema, you can check on our blog E-Invoice LIVE Date: 1st October 2020 – Version 1.1 of E-Invoice Schema Released.
- e-Invoicing Notification 61/2020– Central Tax dated 30th July 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)
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 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.
- 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
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 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
GST Council gave its approval for e-invoicing system implementation in Sept 2019 and with these 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 INR 500 Crore||
|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:
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