GST & Indirect Tax

GST e-Invoicing: Current Turnover Threshold and Who Must Comply

CA Nikhil Gupta·July 2026· GST e-Invoicing Rules GST

Reviewed by CA Nikhil Gupta · Last reviewed 17 July 2026

GST e-invoicing started as a large-business requirement and has been progressively pulled down to cover far smaller taxpayers than most businesses assume — checking the current threshold against your actual turnover, not what you remember from a couple of years ago, is worth doing directly.

What e-invoicing actually requires

Under GST e-invoicing, specified taxpayers must report their B2B invoices to a government-notified Invoice Registration Portal (IRP), which validates the invoice and returns a unique Invoice Reference Number (IRN) along with a signed QR code — this IRN and QR code must then appear on the invoice actually issued to the buyer. An invoice that should have been e-invoiced but wasn't processed through the IRP is generally treated as not a valid tax invoice for GST purposes, with downstream consequences for the recipient's input tax credit claim.

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The threshold has been lowered progressively

⚠ The applicable turnover threshold has been reduced multiple times since e-invoicing was first introduced: e-Invoicing began as a requirement for taxpayers with turnover above a relatively high threshold and has been progressively extended to cover taxpayers with much lower turnover over successive notifications. Because of this pattern of repeated threshold reductions, a business that checked its applicability status a year or two ago and concluded e-invoicing didn't apply should re-verify against the current threshold rather than relying on that earlier conclusion — the goalposts have moved more than once, and many businesses have been caught out assuming an old, higher threshold still applies to them.

How the turnover threshold is actually assessed

The threshold is generally assessed based on aggregate turnover in any preceding financial year from the year GST was introduced onward — meaning a business that crossed the threshold in any one of those years generally remains covered by the e-invoicing requirement going forward, even if its turnover subsequently falls below the threshold in a later year. This "once covered, generally stays covered" characteristic catches businesses that assume a temporary dip in turnover exempts them again.

What transactions are covered

e-Invoicing applies to B2B supplies (and certain other specified categories like exports and supplies to SEZ units) — B2C (business-to-consumer) invoices are generally outside the e-invoicing mandate, though B2C transactions have their own separate, related QR code requirements for certain larger taxpayers under a different notification.

Consequences of non-compliance

An invoice required to be e-invoiced but issued without a valid IRN is treated as not a valid invoice, which can jeopardize the recipient's ITC claim on that invoice.
The supplier can face penalty consequences for non-compliance with the e-invoicing mandate.
Movement of goods under an invalid invoice can also create complications for e-way bill generation, since e-way bill and e-invoice data are integrated for covered taxpayers.

Practical steps for a business approaching or near the threshold

A business unsure of its current e-invoicing applicability status should check its aggregate turnover figures against the currently notified threshold specifically (not a remembered older figure), and should set up the IRP integration (through their billing software or a GSP/ASP connector) well before the requirement becomes applicable, given that IRN generation needs to be built into the actual invoicing workflow rather than treated as an afterthought at the point a transaction needs to be issued.

Frequently Asked Questions

Once a business crosses the e-invoicing threshold, can it stop e-invoicing if turnover later falls below it? ▼

Generally no — once a taxpayer's turnover has crossed the applicable threshold in any covered financial year, the e-invoicing requirement typically continues to apply in subsequent years even if turnover later falls below that threshold, so a temporary revenue dip does not automatically restore exemption.

Does e-invoicing apply to a business exclusively selling to consumers (B2C) with no B2B transactions at all? ▼

The core e-invoicing IRN requirement is specifically for B2B supplies — a business with genuinely no B2B transactions would not have any invoices requiring IRN generation under the core e-invoicing mandate, though it should still separately check whether the B2C QR code requirement (a related but distinct compliance) applies to it based on its own threshold.

Can e-invoicing be generated after the invoice date, or must it happen at the time of issue? ▼

e-Invoices are generally expected to be reported to the IRP and the IRN obtained before or at the point the invoice is issued to the recipient — delayed reporting beyond prescribed timelines can itself attract compliance issues, so building IRN generation into the real-time invoicing workflow (rather than as a batch process done later) is the safer practice.

Source and review trail

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Primary category: GST & Indirect Tax
Official starting point: www.gstcouncil.gov.in

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