Last reviewed: 6 August 2026. Your FY 2025-26 turnover figure is now effectively final — GSTN’s annual window to amend the Aggregate Annual Turnover (AATO) shown on the portal ran from 1 to 31 July 2026 (GSTN advisory dated 1 July 2026), with officer review through mid-August. That number decides more than composition eligibility: if your AATO crossed ₹5 crore in FY 2025-26, e-invoicing became mandatory for you on 1 April 2026 — and every B2B invoice you have issued since then without an IRN is, strictly speaking, not a valid tax invoice. Many businesses discover this only when a large customer’s accounts team refuses the invoice or an ASMT-10 notice arrives. Here is the complete position for FY 2026-27.
Who must generate e-invoices in FY 2026-27
Under Rule 48(4) of the CGST Rules, e-invoicing applies to every registered person whose aggregate annual turnover exceeded ₹5 crore in any financial year from 2017-18 onwards. Three features of this test catch businesses out:
- It is PAN-level, not GSTIN-level. Turnover of all GSTINs under one PAN is combined. A Maharashtra unit with ₹3.2 crore and a Gujarat unit with ₹2.1 crore together cross the line.
- Any year counts, not just last year. If you crossed ₹5 crore even once — say in FY 2018-19 — the obligation applies today regardless of current turnover.
- It is permanent. There is no exit when turnover subsequently falls below ₹5 crore.
| Your situation | E-invoicing position |
|---|---|
| Crossed ₹5 crore in FY 2023-24 or earlier | Already mandatory (from 1 August 2023 or the relevant later date) |
| Crossed ₹5 crore for the first time during FY 2025-26 | Mandatory from 1 April 2026 — you should be generating IRNs now |
| Will cross ₹5 crore during FY 2026-27 | Mandatory from 1 April 2027 — use this year to get systems ready |
| Never crossed ₹5 crore in any FY since 2017-18 | Not applicable; the IRP will not register invoices of non-notified taxpayers |
Check your enablement status at einvoice.gst.gov.in (Search → e-Invoice Status of Taxpayer). Two cautions: enablement is only a facilitation flag — your legal obligation flows from Rule 48(4), not from whether GSTN has flipped the switch; and if you are covered but not enabled, the portal allows self-enablement. Composition taxpayers are outside e-invoicing altogether.
Why August 2026 is the moment to re-check
Two current developments make this worth fifteen minutes this month. First, the AATO amendment window for FY 2025-26 closed on 31 July 2026 and GSTN has indicated the portal will keep turnover figures updated automatically from filed returns going forward — so the AATO your suppliers, customers and jurisdictional officer see against your GSTIN is now the operative number. Second, with GSTR-3B ITC hard-locking live from July 2026, buyers have become far stricter about documents that do not flow into their GSTR-2B correctly. A missing IRN is exactly the kind of defect that large customers now bounce back within days.
What is covered — and what is not
| IRN required | IRN not required |
|---|---|
| B2B tax invoices to registered persons | B2C invoices to unregistered consumers |
| Credit notes and debit notes for B2B supplies | Bills of supply (exempt/nil-rated supplies) |
| Exports — with or without payment of IGST — and supplies to SEZ | Delivery challans and ISD invoices |
| Deemed exports | Imports and self-invoices for RCM inward supplies from unregistered persons |
| Supplies to registered government entities (B2G) | Documents of taxpayers below the threshold |
Exporters should note: e-invoicing applies to export invoices even though the buyer is outside GST. If you export services under LUT, the IRN requirement sits alongside your LUT and refund workflow.
Entities exempt regardless of turnover
The following are exempt from e-invoicing under Notification 13/2020-Central Tax as amended, whatever their turnover: SEZ units (SEZ developers are not exempt), insurers, banking companies and financial institutions including NBFCs, goods transport agencies carrying goods by road, suppliers of passenger transportation services, suppliers of admission to multiplex cinema screenings, and government departments and local authorities.
How e-invoicing actually works
- You generate the invoice in your accounting or billing software as usual.
- The invoice data is reported to an Invoice Registration Portal (IRP) — through the software’s direct integration, a GSP, or the offline utility.
- The IRP returns a unique Invoice Reference Number (IRN) and a signed QR code within seconds.
- You issue the invoice to your customer carrying that QR code — this is what makes it a valid tax invoice.
- The data auto-populates your GSTR-1 and, where applicable, Part-A of the e-way bill; your buyer sees it flow into GSTR-2B and IMS.
Worked example: crossed in FY 2025-26, discovered in August 2026
A Thane-based components trader had turnover of ₹4.6 crore in FY 2024-25 and ₹5.4 crore in FY 2025-26. E-invoicing applied from 1 April 2026, but the firm continued issuing ordinary invoices. By early August it has issued roughly 300 B2B invoices, averaging ₹1,20,000 plus GST of ₹21,600 each.
- Exposure if ignored: each invoice without an IRN is open to penalty under Section 122 of up to 100% of the tax involved (₹21,600, being higher than ₹10,000) — a theoretical worst case running into crores, quite apart from buyers’ ITC being questioned.
- The practical remedy: because the 30-day IRP time limit currently applies only to taxpayers with AATO of ₹10 crore or more, a ₹5-6 crore taxpayer can still report those April-July invoices to the IRP now. Generate IRNs for the backlog, reissue current documents correctly, and document the correction before any notice arrives. Penalty exposure for the interim period reduces sharply once the record is regularised voluntarily.
The lesson: the cost of the fix in August is a few days of disciplined data work; the cost of waiting for a notice is measured in penalties and strained customer relationships.
The 30-day rule for ₹10 crore+ taxpayers
Since 1 April 2025, taxpayers with AATO of ₹10 crore or more must report invoices, credit notes and debit notes to the IRP within 30 days of the document date. The portal rejects anything older — there is no appeal to the IRP, and a rejected document means no IRN, no valid invoice and no clean ITC flow for your buyer. If you are in this bracket, month-end batch reporting is no longer a viable habit; align IRN generation with dispatch.
Checklist for businesses that have just crossed ₹5 crore
- Confirm your PAN-level AATO for every year since 2017-18 — not just the latest year.
- Check enablement at einvoice.gst.gov.in; self-enable if required.
- Activate e-invoicing in your accounting software (Tally, Zoho, Busy and the major cloud platforms all support IRP integration) and test on a sandbox invoice.
- Map who in the billing team owns IRN generation — same-day, not month-end.
- Reissue or regularise any post-applicability B2B invoices issued without IRN.
- Tell your regular buyers the format is changing, so their accounts teams expect QR-coded invoices.
- Align your e-way bill process — Part-A now auto-populates from the IRN data.
- Diarise the ₹10 crore threshold: crossing it brings the 30-day reporting limit and, at ₹500 crore, dynamic QR for B2C.
Common mistakes we see
- Testing turnover GSTIN-wise. Branches under one PAN are aggregated; two mid-size state registrations together can cross ₹5 crore.
- Assuming a dip below ₹5 crore ends the obligation. It does not — the test is any year since 2017-18.
- Skipping IRNs on exports because the customer "is not in GST". Export invoices squarely require e-invoicing.
- Cancelling an IRN after 24 hours by editing the invoice in software only. Post-window corrections need a credit note, not a quiet edit — the IRP record does not change.
- Waiting for GSTN to enable you. The obligation is self-executing; non-enablement is not a defence.
Frequently asked questions
What is the e-invoice turnover limit for FY 2026-27?
The threshold remains ₹5 crore. E-invoicing is mandatory for every registered person whose aggregate annual turnover (PAN-level, all GSTINs combined) exceeded ₹5 crore in any financial year from 2017-18 onwards (Notification 10/2023-Central Tax, effective 1 August 2023). No change has been notified for FY 2026-27.
I crossed ₹5 crore for the first time during FY 2025-26. From when does e-invoicing apply to me?
From 1 April 2026. The test looks at any preceding financial year, so a first-time crossing during FY 2025-26 makes e-invoicing mandatory from the start of the next financial year. Likewise, a first-time crossing during FY 2026-27 triggers the obligation from 1 April 2027.
Is e-invoicing required for B2C sales?
No. E-invoicing covers B2B tax invoices, credit notes and debit notes, exports, SEZ supplies and deemed exports. B2C invoices do not need an IRN; the separate dynamic QR code requirement for B2C applies only to taxpayers with turnover above ₹500 crore.
What happens if I issue B2B invoices without an IRN even though I am covered?
Under Rule 48(5) of the CGST Rules, an invoice issued without an IRN by a notified taxpayer is not treated as a valid invoice. Penalty under Section 122 can be ₹10,000 or 100% of the tax due, whichever is higher, per invoice, and your buyer’s input tax credit on that document can be questioned. In practice, buyer pressure usually arrives before the department’s notice does.
Does the 30-day reporting time limit apply to me?
Currently only if your AATO is ₹10 crore or more. Since 1 April 2025, such taxpayers must report invoices, credit notes and debit notes to the IRP within 30 days of the document date; the portal rejects later submissions. Taxpayers between ₹5 crore and ₹10 crore have no hard time limit yet, but reporting at the time of issue is the only safe practice.
My turnover has fallen below ₹5 crore this year. Can I stop generating e-invoices?
No. Once your turnover has exceeded the threshold in any financial year from 2017-18 onwards, e-invoicing remains applicable permanently, even if turnover later falls below ₹5 crore.
We help businesses in Thane, Mumbai and across India confirm e-invoice applicability, set up IRP integration in their accounting software, regularise missed IRNs and build a monthly GST process that holds up in scrutiny.
GST Registration & Return Filing GST IMS & ITC Process Setup Talk to usThis article is a general summary of e-invoicing provisions under Rule 48(4)/48(5) of the CGST Rules and related notifications as on 6 August 2026, for education only. It is not professional advice; positions in specific cases depend on facts. Verify current thresholds and portal advisories or consult a professional before acting.