Current e-invoicing threshold under Notification 10/2023-Central Tax, who must generate IRN, the 30-day reporting rule for higher-turnover taxpayers, and a practical compliance checklist.

By Kanoons Editorial Team · 14 min read · Last verified 2026-10-06

What e-invoicing is (and is not)

E-invoicing under GST is not a government billing software. Your ERP or billing tool still creates the invoice. Before you issue it to the recipient, the invoice payload is reported to an authorised IRP. The IRP validates GSTIN and core fields, returns an IRN, and the supplier embeds the IRN / QR on the invoice copy shared with the buyer.

Legal anchor: Rule 48(4) of the CGST Rules, 2017, read with the class of registered persons notified under that rule (currently via Notification No. 13/2020-Central Tax as amended, including by Notification 10/2023-Central Tax).

Current threshold — verified position (October 2026)

Primary listing: GST Council — Notification 10/2023-Central Tax (“Seeks to implement e-invoicing for the taxpayers having aggregate turnover exceeding Rs. 5 Cr from 01st August 2023”). IRP explainer pages on einvoice*.gst.gov.in still describe the same ₹5 crore step as the latest notified reduction in their threshold history tables.

Regulatory watch: marketing copy and third-party blogs sometimes announce a further cut (for example to ₹2 crore). Until a Central Tax notification appears on CBIC / GST Council and the IRP FAQ is updated, do not redesign compliance calendars around unverified thresholds. Re-check einvoice.gst.gov.in and CBIC notifications each quarter.

Who is covered

You are in scope if:

• You are a registered person under GST; and
• Your aggregate turnover under section 2(6) exceeded ₹5 crore in any financial year from FY 2017-18 onwards; and
• You are not within a class specifically exempted from Rule 48(4) by notification (certain categories historically excluded — verify the current exemption list on CBIC before assuming you are out).

Because aggregate turnover is PAN-based, a quiet second GSTIN can still be pulled in when the group total crosses the line. Current-year turnover below ₹5 crore does not switch e-invoicing off once a prior year already crossed the notified limit.

Documents and supplies that typically require IRN

In practice, businesses enabled for e-invoicing must generate IRN for:

• Tax invoices issued to registered persons (B2B)
• Credit notes and debit notes linked to those supplies
• Export / SEZ-related invoices where the portal and schema require IRN reporting

Ordinary B2C tax invoices are outside the Rule 48(4) e-invoice mandate (a separate Dynamic QR-code regime applies to certain high-turnover B2C suppliers under other notifications — do not confuse the two).

Circular clarifications (for example Circular No. 198/10/2023-GST) treat Government departments / local authorities / PSUs registered solely for TDS under section 51 as registered persons for e-invoice purposes — so B2G supplies to those GSTINs still need IRN when you are otherwise liable.

Thirty-day reporting window (AATO ₹10 crore+)

GSTN’s e-invoice portal advisory (widely republished on IRP sites, including einvoice6.gst.gov.in) states that from 1 April 2025, taxpayers with AATO of ₹10 crore and above must report e-invoices within 30 days of the invoice / credit note / debit note date. Late reporting can be blocked by the IRP with an error that the document cannot be processed because the time window was exceeded.

Operational implication: month-end bulk uploads are no longer safe for ₹10 crore+ taxpayers. Build IRN generation into the invoice-issue workflow, not a fortnightly backlog.

Compliance checklist

• Confirm whether any FY from 2017-18 already crossed ₹5 crore AATO (GSTR-3B / GSTR-9 history, not “this year’s run rate”).
• Check e-invoice enablement status on the GST portal / IRP; if auto-enablement did not fire, complete enablement manually.
• Map mandatory schema fields in ERP (GSTIN, HSN/SAC, tax break-up, document type, place of supply).
• Segregate B2B/export documents from B2C so IRN is not skipped on the wrong population.
• For AATO ₹10 crore+, enforce the 30-day IRP clock.
• Train AP teams at customers: they should refuse non-IRN B2B invoices where e-invoice applies — this protects their ITC as well as your receivable cycle.
• Keep cancellation / credit-note discipline aligned with IRP rules (IRN cancellation windows are short; beyond that, use credit notes).

Mid-article CTA: if your billing stack is not IRP-ready, start with E-invoicing Setup and keep monthly outward supply reporting aligned via GST Return Filing.

How e-invoicing connects to GSTR-1 and ITC

Reported e-invoices flow into the recipient’s invoice views and support ITC matching. Buyers reconcile purchases against GSTR-2B (see GSTR-2B Guide). Supplier-side gaps — wrong GSTIN, late IRN, or a document that never reached the IRP — show up as buyer ITC friction even when the physical invoice looked fine.

For broader ITC mechanics, see Input tax credit basics.

Common failure modes

• Assuming the threshold is “this FY only” instead of any FY from 2017-18.
• Treating e-invoicing as GSTIN-local when aggregate turnover is PAN-level.
• Generating IRN after courier dispatch, then discovering schema errors.
• ₹10 crore+ taxpayers batching a month of invoices after day 30.
• Confusing homepage “threshold lowered” notices with an unpublished notification — always prefer CBIC / GST Council PDF text.

Primary sources

• GST Council — Notification 10/2023-Central Tax
• CBIC GST portal
• GST portal
• e-Invoice FAQs / IRP
• Rule 48(4), CGST Rules, 2017 (taxinformation.cbic.gov.in / CBIC)

Disclaimer

This guide is for general informational purposes only and is not legal, financial or tax advice. Kanoons Law and Tax Consultants Private Limited is a consultancy platform and is not a law firm or accounting firm. No professional relationship is created by reading this page. Confirm the latest CBIC / GSTN position for your facts, and consult an independently qualified professional before acting. See our Disclaimer.