On 13th Dec 2019, Government notified the e-invoicing rules, its applicability and date from when the notified rules will be effective. In all there were 5 notifications and a summary of notifications is as below
- Getting Invoice Reference Number (IRN)from Government prescribed portal will be mandatory for the notified class of registered person from 1st April 2020
- All the IRN generation portals will be managed and maintained by GSTN, the IT arm of Government, which is currently maintaining the GST Common Portal
- Registered persons with aggregate turnover above INR 100 crore to obtain IRN for all invoices issued to registered persons
- Registered persons with aggregate turnover above IRN 500 crore should include QR code for all invoices issued to unregistered persons
- Invoices issued by the notified persons as stated above which are not complying with the conditions stated above will not be considered as invoices
GST Council gave its approval for e-invoicing implementation in Sept 2019 and with these notifications, necessary changes in the GST Act and rules have been formalized. The e-invoicing mandate does necessitate making updates to the internal systems and educating the teams and as well as supply chain, so that the business can continue as usual. Here is a quick high-level impact on the businesses and their IT systems and processes
|Transaction Type||Applicable to||Requirement||Timelines||Impact|
|B2B Invoices||Registered Person with turnover above INR 100 Crore||
|B2C Invoices||Registered Person with turnover above INR 500 Crore||Invoice output or print to have QR code||
While the e-invoicing rules are applicable to certain set of companies and also for certain type of transactions, we recommend while making any changes to existing systems and while defining the standard practices for invoice generation and printing, a holistic and futuristic approach to be taken. Flexibility and provision to cover all transaction types and all document types, if considered in the IT systems now, adapting to future changes in the e-invoice mandate if any, will be quick and hassle-free.
Government is getting the IRP system up for testing and in parallel is holding workshops for various stakeholders across the country. The API specifications are expected to be released during 3rd or 4th week of Dec 2019. IRN generation through API is most likely to be via GSPs. We’ll keep you posted about the latest developments.
IRIS is one of the established ASP-GSP solution provider for GST compliance as well as Eway Bill Generation. For e-invoicing, our approach will be make transition and integration with minimal changes in the data requirements.
Links to all notifications
- Notification 68/2019 : Generating Invoice reference number as per the conditions and format prescribed
- Notification 69/2019 : Specifies the common portal links for generating the IRN
- Notification 70/2019 : Applicability of e-invoice rules for B2B invoice for registered persons with aggregate turnover above INR 100 crore from 1st April 2020
- Notification 71 /2019 : Inclusion of provision in the CGST Act regarding QR code generation vide earlier no 31/2019 dated 28th June 2019
- Notification 72/2019 : Generation of QR code for B2C invoices by registered persons with aggregate turnover above INR 500 crore from 1st April 2020