GST e-Invoicing: Current Turnover Threshold and Who Must Comply
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.
The threshold has been lowered progressively
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.