GST e-invoicing: who must issue an e-invoice, and do export invoices need one?

What is GST e-invoicing?

E-invoicing does not mean the government writes your invoices. You still create them in your own billing or accounting software. What changes is that, before you issue one, you report its details in the format of Form GST INV-01 to an Invoice Registration Portal (IRP). The IRP validates it, assigns a unique Invoice Reference Number (IRN), digitally signs it and returns it with a QR code, which you print on the invoice. The legal basis is rule 48(4) of the CGST Rules, and rule 48(5) is what gives it teeth: an invoice that a notified person issues any other way "shall not be treated as an invoice".

Who must issue e-invoices? The current threshold

The class of businesses that must e-invoice is set by Notification No. 13/2020–Central Tax, amended several times. The latest amendment, Notification No. 10/2023–Central Tax of 10 May 2023, cut the aggregate-turnover figure from ₹10 crore to ₹5 crore with effect from 1 August 2023. In October 2026 GSTN still described ₹5 crore as "the current eligibility threshold for e-Invoicing".

The test looks back. GSTN’s advisory on self-enablement explains that if your turnover exceeded ₹5 crore in a financial year, you e-invoice from the start of the next financial year, and the same applies if you crossed the figure in any earlier financial year. Turnover is aggregate turnover under one PAN, so zero-rated exports count.

Do export invoices need an e-invoice?

Yes, if you are above the threshold. NIC’s description of the system says IRNs are generated for invoices, debit notes and credit notes "for B2B and export transactions". The fact that your client abroad has no GSTIN does not take the invoice out of scope. You report the export invoice to the IRP like any other, marking it as an export with or without payment of IGST, and print the QR code on the invoice you send. The endorsement rule 46 requires on export invoices, and your LUT reference, still go on the document; see GST on export of services.

Who is exempt from e-invoicing?

The classes exempted when e-invoicing began, as NIC lists them, are:

• Special Economic Zone units (a supplier selling to an SEZ unit still e-invoices).
• Insurers, banking companies and financial institutions, including NBFCs.
• Goods transport agencies transporting goods by road.
• Suppliers of passenger transportation services.
• Suppliers of admission to cinema screenings in multiplex screens.

The exemptions have been amended since, so check the current text of Notification 13/2020–Central Tax if your business is near one of these categories. GSTN also publishes, each month, a list of GSTINs that have declared an exemption.

What is the 30-day time limit for reporting?

From 1 April 2025, a business with aggregate annual turnover of ₹10 crore or more cannot report an e-invoice to the IRP more than 30 days after its date. GSTN’s example: an invoice dated 1 April 2025 cannot be reported after 30 April 2025, and the IRP blocks it. The limit applies to invoices, credit notes and debit notes. It first applied, under an advisory of September 2023, to businesses with turnover of ₹100 crore or more; as of GSTN’s advisory, there is no such restriction below ₹10 crore.

For an exporter, the practical risk is the invoice raised in your accounting system and forgotten. The IRN has to exist before the invoice is issued, so build the IRP step into the invoicing workflow itself rather than doing it in a batch at month end.

What does the QR code contain, and can an e-invoice be cancelled?

The IRP generates a QR code containing the IRN (a hash) and key particulars of the invoice with its digital signature, so it can be verified offline with GSTN’s verification app or checked on the portal. You can cancel an IRN within the time the system allows, provided no active e-way bill is attached to it; a cancelled invoice number cannot be reused. An e-invoice cannot be amended on the IRP: amendments are made on the GST portal while filing GSTR-1.

How do I start e-invoicing?

1. Check your status: search your GSTIN under "e-Invoice Status of Taxpayer" on an IRP. If you have crossed ₹5 crore but are not enabled, use the self-enablement option on the e-invoice portal.
2. Choose how you will report: the IRP’s web form or offline tool for low volumes, or API integration through your ERP or a GST Suvidha Provider. Six IRPs are authorised; you can use any of them.
3. Map your invoice fields to the INV-01 schema, including HSN or SAC codes (six digits where your turnover is above ₹5 crore) and the export supply type.
4. Test in the sandbox before going live if you integrate by API.
5. Generate the IRN before issuing each invoice, and print the QR code on it.

What changes are coming?

The GST Council’s 57th meeting on 8 October 2026 recommended extending e-invoicing, for businesses with turnover of ₹5 crore or more, to self-invoices raised under reverse charge for supplies from unregistered persons and for import of services. GSTN has added two supply types, RCMDOM and RCMIMP, to the IRP sandboxes and says the production date will be announced. If you pay overseas vendors for software or services, that will mean an IRN on your reverse-charge self-invoices too. More in GST changes for service exporters.