E-Invoice Rules for Businesses Above Rs 5 Crore Turnover

E-invoicing has been mandatory for businesses whose aggregate turnover crossed Rs 5 crore in any financial year since 1 August 2023 (Notification 10/2023-Central Tax). If your business crossed the Rs 5 crore mark in FY 2025-26 for the first time, you must generate e-invoices for all B2B supplies through the Invoice Registration Portal (IRP).

This is not a future compliance requirement. It is effective now. Here is what you need to do.

What Changed

Threshold

The threshold was cut from Rs 10 crore to Rs 5 crore with effect from 1 August 2023 (Notification 10/2023-Central Tax). It has not changed since. Any business whose turnover grows past Rs 5 crore in a year comes under e-invoicing from then on.

30-Day Reporting Limit

From 1 April 2025, businesses with AATO of Rs 10 crore or more cannot report an invoice, credit note or debit note on the IRP more than 30 days after its date (GSTN advisory, 5 November 2024). The IRP rejects such documents, so no IRN can be generated. Businesses with AATO below Rs 10 crore are not under this limit for now.

Who Is Affected

You must comply with e-invoicing if:

• Your AATO exceeded Rs 5 crore in any financial year from FY 2017-18 onwards (the threshold is based on the highest turnover achieved, not just the most recent year)
• You are a registered taxpayer under GST (not under composition scheme)
• You issue B2B invoices, B2B credit notes, or B2B debit notes

You are exempt from e-invoicing if:

• You are under the composition scheme
• You are a banking company or financial institution
• You are an insurance company or NBFC
• You are a Special Economic Zone (SEZ) unit
• You are a government department or local authority

Step-by-Step Setup for Newly Eligible Businesses

Step 1: Verify Your AATO

Log in to the GST portal and check your aggregate turnover for FY 2025-26 and prior years. AATO includes turnover across all GSTINs under the same PAN. If any single year exceeds Rs 5 crore, e-invoicing applies.

Step 2: Register on the Invoice Registration Portal

Visit the IRP portal (einvoice1.gst.gov.in). Registration is automatic for GSTINs that meet the threshold. Log in with your GST credentials to verify your registration status.

If registration is not active, submit a registration request through the portal. Approval is typically within 24 to 48 hours.

Step 3: Generate API Credentials

For automated e-invoice generation, you need API credentials from IRP:

1. Log in to the IRP portal
2. Navigate to API Registration
3. Generate your Client ID and Client Secret
4. Note your authentication endpoint URL

These credentials are used by your billing software to communicate with IRP.

Step 4: Integrate with Your Billing Software

Most popular accounting and ERP software packages support e-invoicing integration. Contact your software provider to:

• Enable the e-invoicing module
• Enter your IRP API credentials
• Configure automatic IRN (Invoice Reference Number) generation
• Set up QR code printing on invoices

If your software does not support e-invoicing, you can use the IRP portal's bulk upload feature or the NIC e-invoice tool as an interim solution.

Step 5: Test with Sandbox Environment

Before going live, test your integration using the IRP sandbox (einvoice1.gst.gov.in sandbox mode):

• Generate test invoices
• Verify IRN generation
• Check QR code accuracy
• Confirm cancel and amend workflows

Step 6: Go Live

Once testing is complete:

• Switch from sandbox to production mode
• Generate e-invoices for all B2B supplies from your go-live date
• Report every invoice on the IRP on the day it is issued

The 30-Day Reporting Limit

This is the compliance trap that will catch many businesses with AATO of Rs 10 crore or more:

• An invoice, credit note or debit note must be reported on the IRP within 30 days of its date
• After 30 days the IRP rejects it, so no IRN is generated
• Under Rule 48(5), an invoice that needed an IRN but has none is not a valid tax invoice, so your buyer cannot rely on it for input tax credit

Example

You issue an invoice dated April 5, 2026. If you try to report it on the IRP on May 10, 2026 (35 days later), the IRP rejects it. Without an IRN the document is not a valid tax invoice, and your buyer will ask you to sort it out, which creates its own complications.

How to Avoid This

• Upload invoices to IRP on the same day they are issued
• Set up automated e-invoice generation so invoices are uploaded in real time
• Monitor your IRP dashboard weekly for any pending or failed uploads
• Train your billing team on the 30-day reporting limit

Common Compliance Traps

1. Forgetting Credit Notes

E-invoicing applies to credit notes and debit notes too, not just invoices. Every B2B credit note must be uploaded to IRP with its own IRN.

2. Branch-Level Compliance

The Rs 5 crore threshold applies at the PAN level (aggregate across all GSTINs). But e-invoicing compliance is required at each GSTIN/branch level. If your business has multiple branches, each branch must generate e-invoices.

Branch-level compliance also means branch-level books; our guide on tracking income, expenses and ITC across multiple GSTINs explains how to keep each registration reconciled.

3. Incorrect HSN Codes

IRP validates HSN codes on invoices. If you use an invalid HSN code, the IRP rejects the invoice.

4. Not Cancelling Within 24 Hours

If you need to cancel an e-invoice, it must be done within 24 hours on the IRP portal. After 24 hours, you cannot cancel on IRP. You must issue a credit note instead.

5. Missing Mandatory Fields

IRP requires specific fields: supplier GSTIN, buyer GSTIN, invoice number, date, HSN code, taxable value, tax amounts, and place of supply. Missing any field causes rejection.

Impact on Your Buyers

Your buyers are directly affected by your e-invoicing compliance:

Non-compliance does not just affect you. It affects your entire supply chain.

Penalties for Non-Compliance

• Issuing a regular invoice instead of an e-invoice: under Rule 48(5) it is not a valid invoice, so the supply is treated as made without a proper invoice. Section 122(1) of the CGST Act provides a penalty of Rs 10,000 or the tax involved, whichever is higher
• Other procedural lapses with no specific penalty: up to Rs 25,000 under Section 125 of the CGST Act
• Repeated non-compliance may trigger GST audit or investigation

Let Tax Garden Handle Your E-Invoicing

Setting up e-invoicing for the first time involves IRP registration, software integration, team training, and ongoing monitoring. Tax Garden's Compliance Standard plan covers end-to-end e-invoicing setup and monthly compliance management.

Frequently Asked Questions

Since when has e-invoicing been mandatory for businesses above Rs 5 crore?

The Rs 5 crore threshold has applied since 1 August 2023 under Notification 10/2023-Central Tax. A GST-registered business must issue e-invoices for B2B supplies if its aggregate turnover exceeded Rs 5 crore in any financial year from 2017-18 onwards. Turnover is counted across all GSTINs under the same PAN.

Can I stop e-invoicing if my turnover falls below Rs 5 crore?

No. The test is whether turnover crossed Rs 5 crore in any preceding financial year since 2017-18, not only the latest year. Once you cross the limit, e-invoicing continues to apply even if turnover falls in later years. Keep generating IRNs for every B2B invoice, credit note and debit note.

Is there a time limit for reporting invoices on the IRP?

Businesses with aggregate turnover of Rs 10 crore or more cannot report an invoice, credit note or debit note on the IRP more than 30 days after its date, a rule in force since 1 April 2025. The IRP simply rejects late documents. Businesses below Rs 10 crore are not yet under this limit, but reporting on the day of issue avoids trouble.

Do I need an e-invoice for exports and B2C sales?

Exports, including supplies to SEZ units, are treated like B2B supplies and need an e-invoice with an IRN. Sales to unregistered consumers (B2C) do not need an IRN, although businesses with turnover above Rs 500 crore must print a dynamic QR code on B2C invoices.

What happens if I issue a B2B invoice without an IRN?

An invoice that should have been an e-invoice but has no IRN is not treated as a valid tax invoice under Rule 48(5). Your buyer's input tax credit on it is at risk and you can face penalty proceedings under the CGST Act. Generate the IRN before the goods move or the invoice is sent.

Can an e-invoice be edited after the IRN is generated?

No. An IRN can only be cancelled in full within 24 hours of generation, and partial cancellation or editing is not allowed on the IRP. After 24 hours, correct the transaction by issuing a credit note or debit note with its own IRN, or amend the details in GSTR-1.