As of today, India requires businesses with an aggregate annual turnover exceeding INR 50M (~ âŹ470K) in any financial year since 2017-2018 to comply with mandatory e-invoicing.
Under the mandate, invoices issued for B2B & B2G transactions, as well as exports and other specified transactions, must be reported to an authorised Invoice Registration Portal (IRP) to obtain an Invoice Reference Number (IRN) and a signed QR code.
Further to GSTN Advisory No. 678 [âïž] of October 16, 2026, Indian authorities published Notification No. 04/2026-Central Tax [âïž] on October 26, 2026, formally expanding the scope of the existing e-invoicing requirements.
New transactions in scope
The adopted extension covers two new categories of transactions for businesses already subject to the existing e-invoicing mandate, and introduces two new supply categories that must be specified when reporting invoice data to the IRP for these transactions:
- Domestic purchases from unregistered suppliers: Where a registered business receives goods or services from an unregistered supplier and is liable to pay GST under the Reverse Charge Mechanism (RCM), it must issue a self-invoice and report it through the IRP. The new supply category RCMDOM will have to be used for these transactions.
- Imports of services: Businesses receiving services from suppliers located outside India, where GST is payable by the Indian recipient under the Reverse Charge Mechanism (RCM), will also be required to issue self-invoices and report them through the e-invoicing system.The new supply category RCMIMP will have to be used for these transactions.
As of today, businesses receiving goods or services covered by the relevant RCM provisions are already required to issue recipient-generated self-invoices under the GST framework. However, these self-invoices are not currently required to be reported through the e-invoicing system or to obtain an IRN.
Implementation timeline
Those new requirements will become effective on January 1, 2027. This leaves businesses with only two months to adapt their processes and systems ahead of the implementation date.
The extension applies only to taxpayers already subject to the existing e-invoicing mandate. It does not extend the obligation to businesses previously outside its scope, and existing exclusions under the GST e-invoicing framework also remain applicable.
