Electronic Invoice in India: GST, IRP and IRN Guide

Overview

India runs a mandatory centralised tax clearance model. The supplier builds the invoice in its own ERP, sends the structured data to one of the authorised Invoice Registration Portals (IRPs), receives an Invoice Reference Number (IRN), the IRP's digital signature and a QR code — and only then may issue a legally valid invoice to the buyer.

The consequence is unusually severe and worth stating at the top: under Rule 48(5), an invoice issued by a person covered by the mandate in any other way is not an invoice at all. Registration is not a reporting obligation bolted onto invoicing — it is a condition of the document's legal existence.

₹5 crore

the turnover threshold — measured across all GSTINs under one PAN

INV-01 JSON

the mandatory payload — not XML, and not UBL or CII

72 months

retention, counted from the due date of the annual return

Timeline

India lowered the threshold in six steps between 2020 and 2023, then stopped. The recent changes have been to the mechanics rather than the scope.

Already in force

October 2020 — October 2022

The threshold descends

Above ₹500 crore from 1 October 2020, ₹100 crore from 1 January 2021, ₹50 crore from 1 April 2021, ₹20 crore from 1 April 2022 and ₹10 crore from 1 October 2022.

1 December 2020

Dynamic QR Code for B2C

Businesses above ₹500 crore had to include a Dynamic QR Code on B2C invoices — a payment feature, not an IRP clearance code. See B2C.

1 August 2023

The current threshold — above ₹5 crore

Still the operative figure. No officially approved further reduction has been published.

1 April 2025

The 30-day reporting window

For taxpayers with aggregate annual turnover of ₹10 crore and above, the IRP technically blocks registration of an invoice, credit note or debit note more than 30 days after the document date. A document dated 1 April must be registered by 30 April.

The 30-day rule does not mean a business may routinely issue invoices without an IRN and register them later. The legal validity rule still stands: the IRN must be obtained before a valid invoice is issued. Thirty days is the maximum system limit for correction or late submission. For taxpayers above ₹5 crore but below ₹10 crore no equivalent 30-day block is set in the published advisory — but the requirement to obtain the IRN first applies to them too.

Still ahead

No date set

The B2C pilot

In September 2024 the GST Council recommended launching a B2C e-invoicing pilot. The Council's current official page still describes it as a pilot project, and no approved date for a nationwide B2C mandate has been published.

Who is in scope

The threshold is aggregate annual turnover above ₹5 crore, and three features of how it is measured catch companies out:

—It aggregates all GST registrations under one PAN, not the turnover of a single GSTIN

—It looks at any previous financial year from 2017-18 onwards — not just the current year

—It is effectively one-way. Cross the threshold once and a later fall in turnover does not normally take you back out, because the condition remains satisfied by that earlier year

What must be registered

—Tax invoices, GST credit notes and GST debit notes

—Domestic B2B supplies

—Supplies to SEZ, both with and without payment of tax

—Exports, with and without payment of IGST, and deemed exports

What falls outside the IRP mandate

—B2C invoices

—Ordinary financial credit notes that are not Section 34 CGST Act documents

—Bills of supply for non-taxable or wholly exempt transactions

A caution on the threshold. Secondary commentary occasionally circulates a lower figure — ₹1 crore is the one most often seen. We have not been able to confirm any such reduction against an official notification, and the ₹5 crore threshold from 1 August 2023 remains the position we would rely on. Before acting on a lower figure, verify it against a CBIC notification rather than a summary article.

The IRP clearance model

India uses a centralised clearance CTC model with several authorised entry points. Six Invoice Registration Portals are active, but each is an authorised doorway into a single state GST infrastructure — the plurality of IRPs does not make the system decentralised in the Peppol sense.

The sequence

01 The supplier creates the invoice in its ERP, accounting or billing system

02 The data is transformed into the Indian INV-01 schema and sent as JSON to any authorised IRP

03 The IRP validates structure, mandatory fields, GSTINs, code lists and the absence of a duplicate

04 A unique IRN is generated; the IRP signs the structured data and produces the QR code

05 The signed data returns to the supplier and flows into the GST System to pre-fill GSTR-1, and — where the transport data is present — can feed the e-Way Bill

06 The supplier gives the buyer a visual or structured representation carrying the IRN and QR code

What the IRP is not

It is not a delivery network. Its function is tax registration and clearance. Getting the PDF, JSON or any other representation to the buyer is organised by the supplier or its ERP or service provider — the IRP plays no part in it. This surprises people who expect a clearance platform to also route the document, as the Italian SdI does.

Generating the IRN through the IRPs' core functions is provided to taxpayers free of charge.

B2G

There is no separate nationwide B2G mandate and no government invoice syntax. What decides the treatment is not the public character of the contract but whether the recipient holds a GST registration.

Public body has a GSTINIncluding a registration held solely for GST TDS purposes, it counts as a registered person. A supplier over the threshold must register the invoice at the IRP as a B2B invoice — same INV-01, same IRN

Public body has no GSTINThe transaction is not B2B for the purposes of Rule 48(4), so an IRN is generally not required

Public body as supplierGovernment departments and local authorities are exempt from issuing IRP e-invoices themselves

A particular e-procurement platform or contract may add its own requirements — a PO number, contract reference, department code or a PDF upload. Those are procurement conditions layered on top; they are not a separate national tax regime for the public sector.

B2C and the Dynamic QR Code

There is no full B2C IRP mandate. What exists is a narrower requirement that is frequently confused with clearance: since 1 December 2020, businesses whose aggregate turnover exceeded ₹500 crore in any year from 2017-18 must include a Dynamic QR Code on B2C invoices.

That code exists primarily to enable digital payment. It is not the IRN or clearance QR code issued by an IRP, and generating one confers no clearance of any kind.

The GST Council recommended a B2C e-invoicing pilot in September 2024, and its official page still describes the project as a pilot. No approved date for a nationwide B2C mandate exists.

Formats and PDF

The Indian system is not based on EN 16931 and requires no conformity with the European semantic model. National legislation prescribes none of Peppol BIS Billing, EN 16931 UBL, UN/CEFACT CII, Factur-X or XRechnung.

Mandatory payloadFORM GST INV-01, the Indian e-Invoice Schema, transmitted as structured JSON

Clearance outputThe IRN, the IRP-signed structured data and the QR code

UBL 2.1 and CIINot accepted as a substitute for INV-01 when calling an IRP. A provider may take them as input and convert — but conversion is required, not optional

Note the shape of the requirement rather than just its content: the legally binding technical payload is JSON, not XML. For a European provider whose entire pipeline is XML-first, this is a structural rather than a cosmetic difference.

Where the PDF sits

A PDF is permitted as a visual representation, never as a clearance format. Once the IRN is obtained the supplier may generate a PDF, print the invoice, email it, or supply its own structured file alongside the visualisation. The PDF must correctly show the mandatory particulars including the IRN and QR code.

A self-generated PDF with no previously registered JSON behind it does not satisfy Rule 48(4) for a supplier inside the mandate — and by Rule 48(5) the document is then not an invoice at all.

Identifiers

National identifiers are used throughout; there is no Peppol EAS in the process.

GSTINIdentifies a specific GST registration of the supplier or buyer — the working identifier on every document

PANUsed, among other things, to aggregate turnover across the legal entity for the threshold test

Code listsHSN and SAC codes, state codes, country codes, currency codes and port codes

Transaction typesB2B, SEZWP, SEZWOP, EXPWP and EXPWOP among others — the type drives much of the validation

For exports the foreign buyer needs no Indian GSTIN: the schema uses the export transaction type together with the foreign recipient's details.

Peppol in India

Peppol is not a channel for meeting the Indian GST mandate. Compliance runs through the IRPs, not through Peppol Access Points. Indian commercial providers may participate in Peppol for particular international scenarios, but that is outside the mandatory GST architecture and does not replace IRP registration.

No India Peppol Authority and no official India Peppol country profile are published in the current OpenPeppol catalogues

GSTN is not a Peppol Authority, and an IRP is not a Peppol Access Point

The IRN is not a Peppol Message Level Response or a transport receipt

Access Point certification in another country grants no access to an Indian IRP

There is no mandatory national Peppol EAS. A Peppol participant could in theory use an identifier agreed for a specific cross-border scenario, but it does not replace the GSTIN, is not used by an IRP for routing, does not exempt anyone from registering the INV-01, and has not been established by India as a national EAS scheme.

Export, import and SEZ

Exports

Exports are inside the e-invoice scope, even though the foreign buyer is not a registered person in India. The schema distinguishes export with payment of IGST from export without payment — for instance under a Letter of Undertaking — and captures goods versus services, currency, country of destination, port code where required, and ship-to and place-of-supply data. The Indian supplier obtains the IRN first, and may then send the foreign buyer a PDF, its own XML or EDI file, or any other agreed format. The overseas recipient never connects to an IRP.

Imports

A foreign supplier without Indian GST registration generates no IRN. E-invoicing does not apply to import Bills of Entry, nor to the invoices a recipient raises in connection with imported services under reverse charge. For input tax credit on imports, the Bill of Entry or an equivalent customs document is the admissible basis.

SEZ — three different answers

—A supply to an SEZ unit or SEZ developer is inside the supplier's mandate

—An SEZ unit acting as supplier is exempt from issuing IRP e-invoices

—An SEZ developer acting as supplier does not automatically inherit the SEZ unit's exemption

ViDA

ViDA does not extend to the Indian GST system and sets no deadline for Indian companies as such. An Indian export to the EU is not an intra-EU supply, so ViDA alone does not draw an Indian supplier into the intra-EU digital reporting requirements from 1 July 2030. Parallel obligations can arise where an Indian group holds an EU VAT registration or permanent establishment, supplies between two European VAT subjects, invoices through a European legal entity, or participates in a member state's domestic e-invoicing system — but those are the obligations of the European taxpayer, not an extension of the Indian IRP mandate.

IRP, GSP and ASP

India has no role that maps directly onto a Peppol Access Point. Three categories have to be kept apart, and the differences decide what a foreign provider can and cannot do.

IRP operator

A state-authorised invoice registration portal. Foreign Peppol AP certification is irrelevant — the operator must be specifically selected and authorised by GSTN. A taxpayer may register and submit through any active authorised IRP.

GST Suvidha Provider

A nationally accredited integration provider with a formal relationship and API connection to GSTN. This is the role with real accreditation requirements.

ASP / ERP provider

Builds the INV-01 JSON, converts from ERP or foreign formats, talks to an authorised IRP or GSP, returns the IRN and QR code, produces the PDF and organises delivery. No Peppol-style licence exists for this role — but an authorised channel must be used.

What GSP accreditation requires

—A company incorporated in India under the Companies Act, or a suitable Indian partnership or LLP

—A GST Registration Certificate and a PAN

—Financial and technical criteria, and a demonstration in the GST sandbox

—Building and submitting the e-invoice JSON, handling the IRN and errors, verifying the signature and QR code

—Own or contracted infrastructure of sufficient capacity, a privacy policy and security measures

—A contract with GSTN and a dedicated connection once selected

—Backend infrastructure used for GSP work must be located in India

What this means for a European provider

A foreign Peppol Access Point cannot serve Indian clients on the strength of its Peppol certificate — the certificate confers no access to GSTN or an IRP. Nor can a foreign company become a GSP directly: the published criteria require an Indian registered entity or a suitable Indian partnership or LLP, GST registration and a PAN.

The workable route is partnership: the foreign ERP or Peppol provider builds or converts the data, and registration is performed through an authorised Indian IRP or GSP. No local official electronic mailbox is required — there is no Indian equivalent of the Slovak e-schránka — and no separate representative requirement applies to an ordinary foreign software vendor.

One thing that is not a mailbox: the taxpayer's own IRP registration involves verifying its GST-registered details, mobile number and email by OTP. That is an ordinary taxpayer account, not a state electronic delivery box.

Archiving

GST invoices and the prescribed records must be retained for 72 months — six years — counted from the due date of filing the annual return for the financial year concerned, not from the invoice date. Getting the start point wrong is the common error; it can add most of a year to the real obligation.

The signed e-invoice JSON and the QR code form part of the mandatory records for the full window — not merely the PDF that was sent to the buyer

The IRN links the archived document to the GST system — keep it retrievable, because it is how a document is identified in any subsequent query

The IRP does not hold a permanent copy on the taxpayer's behalf — the archive is the business's own responsibility

Where a business operates several GSTINs under one PAN, the archive should be organised so records can be produced per registration, since that is how they will be asked for.

Penalties

The most serious consequence is not a fine. Under Rule 48(5) an invoice issued otherwise than through the IRP by a person covered by Rule 48(4) is not an invoice — a problem of legal validity, not a file defect.

What follows from that

—No valid GST tax invoice can be issued for the transaction

—The buyer may refuse or delay payment

—Mismatches appear between GSTR-1 and the buyer's GSTR-2B, putting the buyer's input tax credit at risk

—Goods in transit can fail inspection

—The document has to be cancelled, corrected or reissued

The statutory fines

Section 122(1)(i)Covers supply without an invoice, or with an incorrect or false invoice. The penalty may be ₹10,000 or an amount equivalent to the tax involved — whichever is higher

Section 122(3)(e)Up to ₹25,000 for failing to issue an invoice in accordance with the Act or Rules, or failing to account for an invoice in the books

Section 125The general residual penalty of up to ₹25,000, which may apply to a breach of the B2C Dynamic QR Code requirement where no other sanction is prescribed

Which provision and which amount apply depends on the facts — whether tax was lost, whether there was intent, how many documents are involved and the position the authority takes. The often-repeated formula "a flat ₹10,000 per invoice" is not an accurate statement of the law.

Input Tax Credit

India speaks of Input Tax Credit (ITC) under GST rather than VAT deduction, and Section 16 sets out cumulative conditions: a tax invoice, debit note or other prescribed document; the supplier having reported the document; receipt of the goods or services; the tax actually being paid to the government; and the recipient filing its own return.

Where the supplier is required to use e-invoicing, a document without an IRN is not an invoice at all under Rule 48(5). The buyer therefore faces a substantial risk of ITC being denied until the supplier issues a correct document and the data appears in the GST system. The supplier's compliance failure lands on the buyer's balance sheet — which is why Indian buyers verify IRNs rather than trusting them.

But the e-invoice is not the only basis

—An ordinary tax invoice from a supplier who is not inside the e-invoice mandate

—A debit note

—A self-invoice in the reverse-charge cases the law provides for

—A Bill of Entry for imports

—An Input Service Distributor invoice or credit note

For a supplier inside Rule 48(4), a valid e-invoice with an IRN is the necessary tax document for that B2B transaction. But GST recognises other lawful documents on which ITC can be claimed.

How we help

India cannot be served from a European Access Point alone. Where a European platform contributes is upstream of the IRP and on the European side of the trade:

Conversion from ERP, UBL, CII or Peppol data into the INV-01 JSON schema

GSTIN and code-list validation — HSN, SAC, state, country, currency and port codes

Submission through an authorised IRP or GSP partner, with IRN, signature and QR-code handling

Correct handling of the export transaction types and the 30-day reporting window

Delivery of the cleared invoice to the buyer — the part the IRP does not do

The European format the EU counterparty needs for an Indian export

Connection by API, SFTP and CSV, with ERP and IDoc source data

Frequently asked questions

Is e-invoicing mandatory in India?

Yes, above a threshold. It applies to suppliers whose aggregate annual turnover exceeded ₹5 crore in any financial year from 2017-18 onwards, in force since 1 August 2023, and covers B2B invoices, credit and debit notes, SEZ supplies, exports and deemed exports. B2C is outside it. Because the test looks back to any earlier year and aggregates all GSTINs under one PAN, crossing the threshold once keeps you inside it even if turnover later falls.

Can I use my European Peppol Access Point in India?

Not to meet the mandate. Peppol is not a compliance channel in India: there is no India Peppol Authority, GSTN is not one, an IRP is not an Access Point, and AP certification elsewhere grants no access to an Indian IRP. Nor can a foreign company become a GSP directly — the published criteria require an Indian registered entity or suitable partnership or LLP, GST registration, a PAN, and GSP backend infrastructure located in India. The workable model is to build or convert the data and register through an authorised Indian IRP or GSP.

What happens if I issue an invoice without an IRN?

If you are inside the mandate, Rule 48(5) means the document is not an invoice. That is a validity problem, not a formatting one: no valid GST tax invoice exists for the transaction, the buyer may refuse or delay payment, GSTR-1 and GSTR-2B will not match, the buyer's input tax credit is at risk, goods in transit can fail inspection, and the document must be cancelled, corrected or reissued. Penalties under Sections 122(1)(i) and 122(3)(e) may also apply.

What format do I have to send?

FORM GST INV-01 — the Indian e-Invoice Schema — as structured JSON, not XML. India does not use EN 16931 and prescribes none of Peppol BIS Billing, EN 16931 UBL, UN/CEFACT CII, Factur-X or XRechnung; UBL 2.1 and CII are not accepted as a substitute for INV-01 when calling an IRP. Your platform may take those formats as input, but conversion is mandatory rather than optional.

Can I still send a PDF to the buyer?

Yes, after clearance. Once the IRN is obtained you can generate a PDF, print it, email it or supply your own structured file alongside the visualisation — provided the PDF correctly shows the mandatory particulars including the IRN and QR code. What does not work is a self-generated PDF with no registered JSON behind it. Note also that the IRP is not a delivery network: getting the document to the buyer is your job, not the portal's.

What is the 30-day rule?

Since 1 April 2025, taxpayers with aggregate annual turnover of ₹10 crore and above cannot register an invoice, credit note or debit note at an IRP more than 30 days after the document date — a document dated 1 April must be registered by 30 April. It is a system limit for correction or late submission, not permission to invoice first and register later: the IRN must still be obtained before a valid invoice is issued. No equivalent block is set for taxpayers between ₹5 and ₹10 crore, but the same validity rule binds them.

Do invoices to government bodies need an IRN?

It depends on whether the recipient holds a GSTIN — including one held only for GST TDS. If it does, the transaction is B2B and a supplier over the threshold must register it at the IRP using the same INV-01 and IRN; there is no separate government syntax. If the public recipient has no GSTIN, an IRN is generally not required. Government departments and local authorities acting as suppliers are themselves exempt from issuing IRP e-invoices.

How long must records be kept?

72 months from the due date of filing the annual return for the financial year — not from the invoice date, which is the usual mistake. The signed e-invoice JSON and QR code are part of the mandatory records for the full window, so archiving only the PDF is insufficient. The IRP holds no permanent copy on your behalf, and where several GSTINs sit under one PAN the archive should be organised so records can be produced per registration.

Summary

India is a clearance country with an unusually sharp edge. Suppliers above ₹5 crore must register invoices, credit notes and debit notes at an authorised IRP, receive an IRN, signature and QR code, and only then issue a valid document — because under Rule 48(5) anything issued another way is not an invoice at all. Exports and SEZ supplies are in scope; B2C is not, beyond the Dynamic QR Code for the largest businesses.

Technically it is JSON, not XML. FORM GST INV-01 is the only accepted payload, EN 16931 plays no part, and Peppol has no role in the mandate at all — no Peppol Authority, no national EAS, no route from an Access Point certificate to an IRP.

For a European provider, India is a partnership market rather than a direct one. A foreign company cannot be a GSP — the criteria require an Indian entity and Indian-hosted backend — but it can build and convert the data, and register through an authorised IRP or GSP. What no one else does for you is delivering the cleared invoice to the buyer, and holding the signed JSON for 72 months.

Electronic invoice in India

Overview

Timeline

The threshold descends

Dynamic QR Code for B2C

The current threshold — above ₹5 crore

The 30-day reporting window

The B2C pilot

Who is in scope

What must be registered

What falls outside the IRP mandate

The IRP clearance model

The sequence

B2G

B2C and the Dynamic QR Code

Formats and PDF

Where the PDF sits

Identifiers

Peppol in India

Export, import and SEZ

Exports

Imports

SEZ — three different answers

IRP, GSP and ASP

IRP operator

GST Suvidha Provider

ASP / ERP provider

What GSP accreditation requires

What this means for a European provider

Archiving

Penalties

What follows from that

The statutory fines

Input Tax Credit

But the e-invoice is not the only basis

How we help

Frequently asked questions

Summary

Resources

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