The e-invoice limit under GST is ₹5 crore in aggregate turnover. If your business crossed that figure in any single financial year from 2017-18 onward, you must generate every B2B invoice and export invoice through the government’s Invoice Registration Portal (IRP) before issuing it to the buyer. The threshold was set by Notification No. 10/2023-Central Tax and has applied since August 1, 2023.1Central Board of Indirect Taxes and Customs. E-Invoice Notifications
The ₹5 Crore Rule and Why It Sticks
Rule 48(4) of the CGST Rules empowers the government to notify which taxpayers must issue e-invoices.2Central Board of Indirect Taxes and Customs. Rule 48 – Manner of Issuing Invoice The current notification pulls in every registered person whose aggregate turnover exceeded ₹5 crore in any financial year starting from 2017-18. That threshold has held steady into 2026.3Central Goods and Service Tax Jaipur. Trade Notice No 01/2024 – Action in Respect of Non-Issuance of E-Invoices
Here is the part businesses miss most often. Once you have crossed ₹5 crore in any one year since GST began, the obligation stays with you. A later year with lower turnover does not lift it. The test looks backward across every completed year from 2017-18, so a company that touched ₹6 crore in 2019-20 and has run at ₹3 crore ever since is still inside the mandate today.
Turnover here means revenue, not profit. A business operating at a loss can easily cross the threshold, so profitability is beside the point.
How to Calculate Aggregate Turnover
Section 2(6) of the CGST Act defines aggregate turnover as the combined value of all taxable supplies, exempt supplies, exports, and interstate supplies of persons sharing the same Permanent Account Number (PAN), computed on an all-India basis.4Central Board of Indirect Taxes and Customs. CGST Act Section 2 – Definitions It excludes central tax, state tax, union territory tax, integrated tax, and cess, and also excludes the value of inward supplies on which you pay tax under reverse charge.
The PAN-level aggregation is where multi-location businesses get caught. Three branches in three states, each holding its own GSTIN, are added together. If their combined turnover crosses ₹5 crore, every branch must comply with e-invoicing even though no single branch may have crossed the line on its own.3Central Goods and Service Tax Jaipur. Trade Notice No 01/2024 – Action in Respect of Non-Issuance of E-Invoices
Before you conclude you are outside the mandate, pull the aggregate turnover figure for every financial year back to 2017-18 across all GSTINs under your PAN. One qualifying year is enough.
Which Transactions Are Covered
E-invoicing applies to two categories of outward supplies: B2B transactions between two GST-registered entities, and exports of goods or services.3Central Goods and Service Tax Jaipur. Trade Notice No 01/2024 – Action in Respect of Non-Issuance of E-Invoices Supplies to government entities that hold GST registration count as B2B and require e-invoicing.
Credit notes and debit notes issued under Section 34 of the CGST Act also have to be reported through the IRP. This is a common gap: businesses generate e-invoices for their sales but skip the credit notes, and the mismatch shows up at return filing.
Business-to-consumer transactions, where the buyer is not GST-registered, do not require e-invoicing. If you sell to both, your billing system needs to route only the B2B and export invoices through the IRP while handling B2C separately.
Businesses Exempt Regardless of Turnover
Notification No. 13/2020-Central Tax, as amended, exempts certain registered persons from e-invoicing no matter how large they are.5Central Board of Indirect Taxes and Customs. Notification No 13/2020 – Central Tax The exempted categories are:
- Banks, non-banking financial companies, and insurance companies
- Special Economic Zone units
- Goods transport agencies
- Passenger transportation services
- Suppliers of services through an e-commerce operator where the operator collects tax under Section 52
A bank running turnover in the thousands of crores still uses its own documentation standards rather than routing invoices through the IRP.
Reporting Deadlines
Generating the e-invoice is not something you can defer indefinitely. Taxpayers with an annual aggregate turnover of ₹10 crore or more must report their invoices and credit-debit notes on the IRP within 30 days of the invoice date. The 30-day window has applied to businesses above ₹100 crore since November 2023, and was extended to the ₹10 crore-and-above bracket from April 1, 2025.
Businesses between ₹5 crore and ₹10 crore are not currently bound by the 30-day validation rule, though that may change. Even without a hard deadline in that band, delay creates practical trouble. Your GSTR-1 will not auto-populate correctly, and your buyer’s GSTR-2B will show a gap where your invoice should be.
An e-invoice can be cancelled on the IRP within 24 hours of generation. After that, cancellation has to be handled manually on the GST portal before the GSTR-1 for that period is filed.
What Non-Compliance Costs You
An invoice issued without a valid Invoice Reference Number is not an invoice under GST law. Rule 48(5) is blunt: any invoice issued by a person covered under Rule 48(4) in any manner other than the prescribed manner simply does not count as an invoice.2Central Board of Indirect Taxes and Customs. Rule 48 – Manner of Issuing Invoice
Section 122 of the CGST Act sets the direct penalty. A taxable person who supplies goods or services without issuing a proper invoice faces a penalty of ₹10,000 or the amount of tax evaded, whichever is higher.6Central Board of Indirect Taxes and Customs. CGST Act Section 122 – Penalty for Certain Offences Section 122(3)(e) adds a separate penalty of up to ₹25,000 for failing to issue an invoice in accordance with the Act or its rules.
The bigger hit lands on the buyer. Without a valid IRN, the invoice never auto-populates into your GSTR-1 and never appears in the buyer’s GSTR-2B. Section 16 of the CGST Act requires possession of a valid tax invoice for input tax credit, so the buyer cannot claim ITC on the purchase. Buyers who catch this typically refuse delivery, withhold payment, or both. The commercial fallout of denying customers their ITC generally hurts more than the government-imposed fine.
If You’ve Just Crossed the Threshold
Start the setup work before the obligation actually bites. Your accounting or ERP software has to connect to the IRP through APIs, and that integration takes time to configure and test. Compatibility issues tend to surface only when the first live invoice is generated under real conditions.
Sort your transactions by type. Only B2B supplies and exports route through the IRP, but your workflow has to handle B2C alongside them without confusion. Walk your accounting team through IRN generation, the 24-hour cancellation window, and the review of auto-populated GSTR-1 data before filing.7Goods and Services Tax Network. Advisory on Auto-Population of E-Invoice Details Into GSTR-1
Then audit your history. Add up turnover across all GSTINs under your PAN for every year from 2017-18 forward. The most common compliance failure is not deliberate: it is a business that never realized its combined turnover crossed ₹5 crore in an earlier year and has been issuing non-compliant invoices since. By the time a notice arrives, the accumulated exposure can be substantial.