Who Must Issue GST E-Invoices in India (2026)?

Quick Answer: Any GST-registered supplier whose aggregate turnover exceeded ₹5 crore in any preceding financial year from 2017-18 onwards must issue e-invoices for supplies to registered persons and for exports. The main exclusion is the class of registration: SEZ units, banks, insurers, goods transport agencies and a few other classes are exempt whatever their turnover.

The obligation is fixed by a class of person, not by a transaction. Notification No. 13/2020-Central Tax, as amended by Notification No. 10/2023-Central Tax, names that class: registered persons whose aggregate turnover exceeds five crore rupees in any preceding financial year from 2017-18 onwards. The class has stood at that level since 1 August 2023. Once a business enters it, the obligation does not lapse when turnover falls back below the line.

Two changes the GST Council recommended on 8 October 2026 are not yet notified and do not alter the rows above.

Which Businesses Fall Inside the E-Invoicing Class?

A GST-registered supplier falls inside the class, and must issue e-invoices, once its aggregate turnover has exceeded ₹5 crore in any preceding financial year from 2017-18 onwards. The test runs on the Permanent Account Number. It aggregates turnover across every GST registration number (GSTIN) held under that PAN and across all of India.

Which supplies are covered?

Rule 48(4) of the Central Goods and Services Tax Rules 2017 sets out the mechanism and leaves the scope to the notification. Notification No. 13/2020-Central Tax, as amended by Notification No. 70/2020-Central Tax, confines the obligation to supplies of goods or services to a registered person and to exports. Business-to-consumer supplies sit outside it.

Reverse charge needs care. Where a supplier in the notified class issues the invoice for its own supply and the recipient discharges the tax under section 9(3), the invoice is reported. Where that supplier instead receives a supply from an unregistered person under section 9(4), or imports a service, no e-invoice arises. The GST Council, at its 57th meeting on 8 October 2026, recommended extending e-invoicing to both of those cases at ₹5 crore and above, which is a wider test than the mandate's own "exceeds". That is a recommendation, and it binds nobody until it is notified.

What Is the E-Invoicing Turnover Limit?

The e-invoicing limit is aggregate turnover exceeding ₹5 crore, and the distinction matters. A business at exactly ₹5 crore is outside the class. A business at ₹5.01 crore is inside it. E-invoicing applicability therefore turns on two questions: whether that figure was ever crossed, and whether the registration sits in an exempt class.

The figure has not changed since 1 August 2023. Each change to the class was made by a Central Tax notification of the Central Board of Indirect Taxes and Customs (CBIC), and the e-invoicing mandate published on a government-authorised e-invoice portal records them in order.

How is aggregate turnover measured?

Aggregate turnover is the section 2(6) figure: PAN-level, all-India, and not the turnover of the registration raising the invoice. The portal uses a computed figure it calls aggregate annual turnover for the 30-day reporting window, so the two labels attach to two different tests. A legal entity running both a domestic unit and an SEZ unit therefore tests the combined figure. Where the PAN-level turnover crosses the line, the domestic unit is covered even if its own turnover sits well below ₹5 crore.

Which Documents Must Be Reported to the IRP?

Rule 48(4) requires the notified person to upload the prescribed particulars in FORM GST INV-01 to the Common Goods and Services Tax Electronic Portal, in practice an Invoice Registration Portal (IRP), and obtain an Invoice Reference Number (IRN). The table below sets out which documents are reported and which are not.

An Input Service Distributor invoice distributes credit rather than evidencing an outward supply, so it appears on neither list. Supplies to an SEZ unit are reported in the ordinary way. The SEZ exemption is about who issues, not who receives.

Who Is Exempt From E-Invoicing?

The exemption attaches to the registered person, not to the supply. A registration in an exempt class reports no document to the IRP, even on a transaction that would otherwise be covered. Because section 25(4) treats each registration as a distinct person, the exemption does not travel to the other registrations under the same PAN.

Notification No. 13/2020-Central Tax carves out the classes of registered person described in rule 54(2), (3), (4) and (4A) of the CGST Rules. Notification No. 23/2021-Central Tax dated 1 June 2021 later added a government department and a local authority, and Notification No. 61/2020-Central Tax, the same instrument that set the ₹500 crore step, is what excluded SEZ units. The portal's own exemption list also names Input Service Distributors and persons registered under rule 14; those sit outside the mandate because of what they issue, not under the rule 54 carve-out.

• Special Economic Zone units
• An insurer, a banking company or a financial institution, including a non-banking financial company
• A goods transport agency supplying transport of goods by road
• A supplier of passenger transportation service
• A supplier of services by way of admission to the exhibition of cinematograph films in multiplex screens
• A government department and a local authority

Are SEZ developers exempt?

No. Notification No. 61/2020-Central Tax exempts SEZ units only. An SEZ developer that meets the turnover class must issue e-invoices in the same way as any other covered supplier. A unit in a Free Trade and Warehousing Zone, being a category of Special Economic Zone, takes the unit exemption.

What Happens If an E-Invoice Is Not Issued?

Rule 48(5) is the operative consequence. An invoice issued by a notified person in any manner other than the manner specified in rule 48(4) shall not be treated as an invoice at all. The document is not merely defective; in law it is not an invoice.

Section 122(1)(i) of the CGST Act 2017 then supplies the penalty. Supplying goods or services without issue of an invoice, or issuing an incorrect or false invoice, attracts ₹10,000 or an amount equivalent to the tax evaded, whichever is higher. An equivalent penalty arises under the corresponding State or Union territory Act. The figure is a floor rather than a ceiling, because it is measured against the tax at stake.

What is the 30-day time limit for reporting an e-invoice?

A separate time limit governs reporting. The GSTN advisory of 5 November 2024 is published on the e-invoice portal. Under it, a taxpayer with aggregate annual turnover of ₹10 crore or more must report an invoice, credit note or debit note within 30 days of the document date. That restriction took effect on 1 April 2025. After the window closes the portal refuses to generate an invoice reference number.

The mandate begins above ₹5 crore. The 30-day reporting window begins at ₹10 crore or more.

How Do You Evidence E-Invoicing Compliance Across Entities?

Applicability is decided once per PAN, but the evidence sits per GSTIN, per document and per month. A group holding several registrations has to show which entities fall inside the class, which documents were reported, and when each was reported. Positions move, and not only statutory ones: the reporting window stepped down from ₹100 crore to ₹10 crore.

What Does the Compliance Record Need to Hold?

A compliance management system holds that record: the obligation, the assigned owner, the due date and the filed evidence, with an audit trail against each entry. LexComply maintains it across multiple entities and keeps the underlying instruments in a searchable legal library.

The platform does not report invoices to the IRP and does not issue any document. Reporting remains with the supplier and its invoicing system. Where applicability itself is contested, advisory support can work the test through before the first document is raised. If you need to establish which registrations fall inside the class, we can walk through the test with you. Get in touch to start that review.

Common Mistakes to Avoid

• Reading the threshold as "₹5 crore or more". Notification No. 10/2023-Central Tax reads on aggregate turnover that exceeds five crore rupees. A business sitting exactly at ₹5 crore falls outside the class; one at ₹5.01 crore falls inside it.
• Testing only the current financial year. The class is fixed by any preceding financial year from 2017-18 onwards. One year above the line keeps the obligation alive after turnover falls back.
• Quoting ₹25,000 as the penalty for an incorrect invoice. Section 125 is a residual penalty that "may extend to" ₹25,000 and applies only where no penalty is separately provided. An incorrect invoice is section 122(1)(i), which carries ₹10,000 or the tax evaded, whichever is higher. The GST Council, at its 57th meeting on 8 October 2026, recommended reducing that section 125 maximum to ₹10,000, which awaits notification and is not yet law.
• Treating the exemption as transaction-based, and extending it to SEZ developers. Notification No. 13/2020-Central Tax exempts classes of person, and Notification No. 61/2020-Central Tax reaches SEZ units alone. A developer above the threshold must comply.
• Treating the dynamic QR code as e-invoicing. The dynamic QR code requirement on business-to-consumer invoices applies above ₹500 crore under Notification No. 14/2020-Central Tax. It has no bearing on rule 48(4).

Legal Disclaimer

This article is general information on the position under the Central Goods and Services Tax Act 2017 and the rules and notifications made under it, as at 10 October 2026, and it is not legal or tax advice. Statutory positions change by notification, so verify the current instrument and take professional advice on your own facts before acting.