Regulatory updates - India

The glossary describes what is e.g. an e-invoicing, the Invoice Registration Portal (IRP), the Invoice Reference Number (IRN), the difference between Debit and Credit Note and the e-invoice QR code. The list is broader and explains also the technical matters e.g. JSON format and API connection for e-invoice reporting via IRP.

The guide further explains the details of the e-invoicing processes, as well as what taxpayers are in and out of scope and the document types that must be reported.

The published materials do not introduce any changes to the current system. Instead, they serve as an educational source aimed to help businesses better understand their obligations by getting insights into how the E-Invoicing system operates.

Additionally, earlier on 27 November 2024 the GSTN published an Advisory No. 553 document on the authorized B2B e-invoice verification apps, to ensure that taxpayers have up-to date details regarding the approved apps. These mobile apps will allow buyers to verify the authenticity of an issued invoice, by scanning the respective QR code. This will simplify the invoice verification process, making it convenient for the buyers to verify their documents.

On 5 November 2024, the Goods and Services Tax Authority (GSTN) in India announced that taxable persons with annual aggregate turnover (AATO) INR 10 crores and above (ca. EUR 110 000) will have a 30-day window to report e-invoices as of 1 April 2025.

The IRP portal passes validations that prevent taxpayers from reporting electronic invoices surpassing 30 days. For instance, an invoice with a date equivalent to 1 April 2025 will not be allowed to be reported after 30 April 2025.

The GSTN clarifies in the announcement that this new requirement applies to all document types: invoices, credit notes, and debit notes.

The Goods and Services Tax Network (GSTN) will introduce a new Invoice Management System (IMS) on the GST portal starting 1 October 2024. This system will help make Input Tax Credit (ITC) claims easier by allowing taxpayers to accept, reject, or keep invoices pending for later review. Both regular taxpayers and those using the Quarterly Return Monthly Payment (QRMP) scheme will benefit from this feature.

The main benefits of the IMS include making it easier to fix invoice mistakes between suppliers and buyers, as well as ensuring more explicit ITC claims. If an invoice is accepted, it will automatically appear in the taxpayer's GSTR-2B and GSTR-3B forms. The rejected records will appear under the "ITC Rejected" section of the respective GSTR-2B, which will not auto-populate in FORM GSTR 3B.

Other features include automatic acceptance of invoices if no action is taken and options for correcting invoices and credit notes. This system will make GST compliance more efficient, but businesses will need to carefully check their invoices to ensure correct ITC claims.

On 9 September 2024, at the GST Council’s 54^th meeting, it was recommended to roll out a B2C e-invoicing pilot in the country.

The Council’s recommendation is based on the positive results of the previous B2B e-invoicing implementation. An additional benefit raised by the council is the opportunity this will provide to the end customer, who should be able to verify the invoice reporting in the GST return.

The pilot will be implemented in selected states and sectors on a voluntary basis.

On 21 February 2024, the Goods and Services Tax Network (GSTN) issued a notice, rolling out an upgraded e-invoice master information portal. This initiative marks one year from:

• Successful introduction of five new IRP portals;
• E-invoice master information portal; and
• E-invoice QR Code Verifier application.

Main new features in the portal

• Automatic e-invoice exemption list: Monthly publication of GSTINs with e-invoice exemptions;
• PAN-based search: Instantly check e-invoice enablement status using PAN or GSTIN;
• Improved accessibility compliance and UI/UX: Adherence to GIGW guidelines for enhanced accessibility features;
• Daily IRN count statistics: Stay informed with daily IRN generation count statistics;
• Dedicated section on mobile app: Find information and support for the e-invoice QR Code Verifier app.

Furthermore, the GSTN has introduced an internal e-invoice comprehensive health dashboard for heightened ecosystem monitoring.

Other key highlights

• Expansion of IRP portals: Seamless reporting through the operation of six IRP portals;
• E-invoicing reporting accessibility: All eligible taxpayers can report e-invoices through any of the six IRP portals, online, via APIs, or through a mobile app, all free of cost;
• Hourly auto-population of e-invoices: Ongoing efforts to enable hourly auto-population of e-invoices in GSTR-1 via NIC-IRP;
• E-invoice download: Buyers and sellers can access e-invoice download for the past six months;
• E-invoice QR code verifier app: Verify e-invoices and search IRN functionality available for online verification.

The list of enhancements continues to expand, and an upgraded version of the e-invoice verifier app, equipped with new features, is set to be launched soon.

On 3 October 2023, the Goods and Services Tax Network (GSTN) in India published its advisory on downloading of invoices in JSON format from the GST portal.

From now on, taxpayers in India are able to both manually view and download JSON e-invoices, as well as automatically fetch these through GST Suvidha Provider or an Authorized Intermediary.

There are two important aspects of the new functionality:

•  The GST Portal combines e-invoices reported across all six IRPs;
• Invoices are available only for up to 6 months from the date of IRN generation.

On 13 September 2023, the Goods and Services Tax Authority (GSTN) in India announced that taxpayers will have a 30-day window to report e-invoices from 1 November 2023 onwards. This new regulation applies to taxable persons with annual aggregate turnover (AATO) greater than INR 100 crores (ca. EUR 11 million).

The IRP portal passes validations that prevent taxpayers from reporting electronic invoices surpassing 30 days. For instance, an invoice with a date equivalent to 1 November 2023 will not be allowed to be reported after 30 November 2023.

The GSTN also clarifies in the announcement that all document types will be in the scope of this new requirement: invoices, credit notes, and debit notes.

Currently, the Goods and Services Tax (GST) is taking steps to implement e-invoices, which will eventually lead to the dispensing of the e-way bill system. Taxpayers with turnovers above INR 1.5 crores (ca. EUR 168 000) will be mandated to use e-invoicing as part of the initiative. Moreover, the new requirement will probably affect taxable persons mentioned from next year onward.

Since the government began implementing e-invoicing a few years ago, the scope has grown gradually. The proposed change to lower the turnover threshold to INR 1.5 crores would bring more businesses under the ambit of e-invoicing. However, a formal announcement has not yet been made by the government.

According to the Notification, as of 1 August 2023, all businesses with turnovers exceeding INR 5 crores (ca. EUR 560 000) must integrate their systems and clear invoices via the IRP platform before sharing invoices with customers.

Notification No. 10/2023 is available here.

The Goods and Services Tax Network of India announced its advisory on imposing a timeline for invoice reports through the IRP Portal.

The advisory covers an imposition of a time limit on old invoices reporting within the e-invoice IRP portals for taxpayers with Annual Aggregate Turn Over (AATO) more or equal to INR 100 crores (ca. EUR 11 million).

The report of invoices issued in seven days or more will not be allowed on the reporting date for taxpayers.

This limitation applies to all document types (including credit/debit notes) for which IRN is to be generated.

The 7-day timeline requirement is proposed to take effect from 1 May 2023.