When India switched on e-invoicing in October 2020, it reached only the country's largest businesses, those with turnover above ₹500 crore. Five notifications later, the line has fallen a hundredfold, to ₹5 crore. The e-invoice has quietly become the normal invoice for a great many of the businesses a CA firm audits.
Along the way the system picked up a deadline of its own, one that most businesses find out about only when the portal refuses an invoice.
The law in two sentences
Rule 48(4) of the CGST Rules says that notified classes of registered persons must prepare their invoices by uploading them to the Invoice Registration Portal and obtaining an Invoice Reference Number. Rule 48(5) says what happens if they don't: an invoice issued any other way "shall not be treated as an invoice".
A hundredfold fall, in five steps
Each step amended Notification No. 13/2020-Central Tax:
- ₹500 crore, from 1 October 2020
- ₹100 crore, from 1 January 2021
- ₹50 crore, from 1 April 2021
- ₹20 crore, from 1 April 2022
- ₹10 crore, from 1 October 2022
- ₹5 crore, from 1 August 2023, under Notification No. 10/2023-Central Tax
We found no later notification changing the ₹5 crore line.
The two traps in the test
- Any year, not this year. The test is aggregate turnover exceeding ₹5 crore "in any preceding financial year from 2017-18 onwards". A business that crossed ₹5 crore once, in 2019-20, and has shrunk since, is still in.
- The whole PAN, not one GSTIN. Aggregate turnover under section 2(6) of the CGST Act is computed across every registration under the same PAN, all over India. Three small branches can add up to one e-invoicing business.
It applies to supplies to registered persons and to exports. Invoices to consumers remain outside it.
Who is left out
Notification No. 13/2020 excludes:
- a government department and a local authority;
- a Special Economic Zone unit. The exclusion names units, not developers;
- insurers, banks, financial institutions and NBFCs;
- goods transport agencies;
- passenger transport services;
- multiplex cinema admissions.
An excluded business above the threshold has to print a declaration on its invoices, under rule 46(s), saying it is not required to e-invoice.
The 30-day rule
This is the deadline that catches people. Under a GSTN advisory of 5 November 2024, from 1 April 2025 a taxpayer with annual aggregate turnover of ₹10 crore or more cannot report an invoice, credit note or debit note on the IRP more than 30 days after its date. The advisory's own example is an invoice dated 1 April 2025, which cannot be reported after 30 April 2025. The portal simply refuses it.
The limit started in 2023 at ₹100 crore and was widened to ₹10 crore. It is a portal validation, not a rule of law, but in practice the effect is the same. An invoice the IRP won't accept can't get an IRN, and under rule 48(5) it isn't an invoice.
A late e-invoice is not a late filing. It is, in law, no invoice at all, and the buyer's credit rests on it.
What rides on it
- The buyer's input tax credit. Section 16(2) requires the buyer to hold a tax invoice, and the supplier to report it in GSTR-1. An e-invoice reported on the IRP flows into the supplier's GSTR-1 automatically, but only if it is reported before that GSTR-1 is filed.
- The e-way bill. The QR code with the IRN can be shown in place of the physical invoice, under rule 138A(2), and the portal lets an e-way bill be generated from the IRN.
- Penalty. Section 122(1)(i) penalises supplying goods or services without issuing an invoice, or issuing an incorrect one. The Act and the Rules don't spell out how it applies to a missing e-invoice, but rule 48(5) is the obvious bridge.
Check your position
Must you e-invoice, and by when must it reach the IRP?
E-invoicing applies to your B2B invoices and exports
Turnover above ₹5 crore in some year since 2017-18 brings you in, even if this year's is lower. An invoice issued without an IRN is not treated as an invoice under rule 48(5).
With AATO below ₹10 crore, no 30-day reporting limit applies as of now.
CGST Rules, rules 46 and 48; Notification No. 13/2020-Central Tax as amended up to No. 10/2023-Central Tax; GSTN advisory of 5 November 2024 on the 30-day limit. Nothing you type leaves this page.
Also changed
- Multi-factor authentication became mandatory for the e-invoice and e-way bill portals in stages: for turnover above ₹20 crore from 1 January 2025, above ₹5 crore from 1 February 2025, and for everyone from 1 April 2025.
- B2C e-invoicing was recommended by the GST Council in September 2024 as a voluntary pilot in selected sectors and states. It isn't a general obligation.
Where this comes from
The law is rules 46, 48, 54 and 138A of the CGST Rules and sections 2(6), 16 and 122 of the CGST Act. The thresholds are Notification No. 13/2020-Central Tax and its amending notifications, the last being No. 10/2023-Central Tax. The 30-day limit and the authentication schedule come from GSTN advisories of 5 November 2024 and 17 December 2024. As at 19 September 2026, we found no later change to the threshold, so check the latest notifications before relying on it.
Questions this answers
What is the e-invoicing threshold limit in India?
Aggregate turnover exceeding ₹5 crore in any financial year from 2017-18 onwards, from 1 August 2023, under Notification No. 10/2023-Central Tax.
Is e-invoicing turnover counted per GSTIN?
No. Aggregate turnover under section 2(6) of the CGST Act is computed across all registrations under the same PAN, on an all-India basis.
What is the 30-day rule for e-invoices?
From 1 April 2025, taxpayers with AATO of ₹10 crore or more cannot report an invoice, credit note or debit note on the IRP more than 30 days after its date, under a GSTN advisory of 5 November 2024.
Who is exempt from e-invoicing?
Government departments, local authorities, SEZ units, insurers, banks, financial institutions and NBFCs, goods transport agencies, passenger transport services and multiplex cinema admissions.
What happens if an e-invoice is not generated?
Under rule 48(5) of the CGST Rules, an invoice issued without following rule 48(4) is not treated as an invoice, which affects the buyer's input tax credit.