Briefing Document & Podcast: E-Invoicing and E-Reporting in India

Last update: December 2, 2025

SUMMARY

Executive Summary:

India has implemented a phased electronic invoicing (e-invoicing) system under the Goods and Services Tax (GST) regime, requiring certain taxpayers to report invoices to a government portal (Invoice Registration Portal – IRP) for validation. This is a “continuous transaction control” system aimed at reducing tax evasion, improving compliance, and streamlining GST return filing. The mandate’s scope is expanding, with turnover thresholds decreasing over time, and future plans include extending e-invoicing to Business-to-Consumer (B2C) transactions and integrating it with e-way bills. Non-compliance leads to penalties, invalid invoices, and potential denial of input tax credit (ITC) for buyers.

Key Themes and Ideas:

E-Invoicing Scope and Implementation:

• Phased Rollout: E-invoicing was launched in October 2020 for businesses with a high turnover and has gradually expanded to include smaller businesses. The turnover threshold has been lowered incrementally over the years. “E-invoicing became mandatory on Oct 1, 2020 for businesses with annual turnover above ₹500 crore…The turnover threshold was subsequently lowered in stages: ₹100 crore from Jan 1, 2021, ₹50 crore from Apr 1, 2021, ₹20 crore from Apr 1, 2022, ₹10 crore from Oct 1, 2022, and ₹5 crore from Aug 1, 2023.”
• Current Status (Late 2025): The current threshold requires all GST-registered businesses with an aggregate annual turnover exceeding ₹5 crore to generate e-invoices.
• Upcoming Changes: From April 1, 2025, taxpayers with a turnover of ₹10 crore or more will not be allowed to report invoices older than 30 days on the IRP. “From April 1, 2025, a new rule kicks in: taxpayers with turnover ≥₹10 crore will no longer be allowed to report invoices older than 30 days on the Invoice Registration Portal (IRP).”
• Future Outlook: Plans are in place to extend e-invoicing to B2C transactions and integrate e-way bills with e-invoices. “The GST Council and government have signaled plans to extend e-invoicing to B2C (business-to-consumer) transactions in coming years.”
• Covered vs. Excluded Transactions: Primarily covers domestic B2B, B2G and export invoices. Excludes B2C transactions, imports, bills of supply, and delivery/job-work challans. “Under the mandate, domestic B2B invoices (business-to-business supplies within India) are the primary focus… B2C transactions (sales to unregistered persons/consumers) are currently exempt from e-invoicing.”
• Exempt Entities: SEZ units, banks/insurers/financial institutions, GTAs, passenger transport service providers, and cinema admission service providers are exempt from e-invoicing, even if their turnover exceeds the threshold.

E-Invoice Generation and Transmission Process:

• JSON Format: Invoices are prepared in JSON format according to the GST INV-01 schema. “The actual invoice is generated by the taxpayer’s own system (ERP or billing software) but must be formatted as a JSON file when reported to the government.”
• Invoice Registration Portal (IRP): The JSON file is uploaded to the IRP for validation.
• IRN and QR Code Generation: The IRP generates a unique 64-character Invoice Reference Number (IRN) and a QR code upon successful validation. “If the data passes validation, the IRP will generate a unique Invoice Reference Number (IRN) – a 64-character hash string – for that invoice. It also generates a QR code containing key invoice particulars…”
• Digital Signature: The IRP digitally signs the invoice data and returns the JSON (with IRN and QR code) to the supplier.
• Data Transmission to GSTN: Invoice details are transmitted to the GSTN backend to auto-populate GST returns and the e-way bill system (if applicable).
• Clearance Model: An invoice becomes legally valid only after IRN generation.
• Reporting Deadline: The expectation is real-time reporting, and invoices cannot be reported after a certain number of days from their date. “Ideally, businesses should generate and report the e-invoice immediately when the invoice is raised…To enforce timeliness, the GSTN has introduced a rule that invoices cannot be reported after a certain number of days from their date.”

Penalties and Consequences of Non-Compliance:

• Invalid Invoice & ITC Denial: Failure to generate an e-invoice results in the invoice being treated as invalid, and the buyer cannot claim input tax credit (ITC). “If a required e-invoice is not generated…that invoice is treated as invalid under GST law. The immediate effect is that the buyer cannot claim input tax credit (ITC) on an invalid invoice…”
• GST Act Penalties: Penalties can be 100% of the tax due on the invoice or ₹10,000, whichever is higher, for failure to issue an e-invoice. Issuing an incorrect e-invoice can attract a penalty of up to ₹25,000 per invoice.
• Goods Detention: Transporting goods without a valid e-invoice (when required) can lead to detention of the goods and conveyance.
• Loss of Input Credit (for Buyers): Buyers may lose input credit if the supplier fails to comply with e-invoicing regulations.

Impact on GST Return Filing:

• Auto-Population of Returns: E-invoicing data is used to auto-populate GST return forms, specifically the supplier’s GSTR-1 and the buyer’s GSTR-2A/2B. “E-invoicing data is leveraged to auto-populate GST return forms …The supplier’s GSTR-1 (sales statement) is automatically populated with e-invoice details…The buyer’s GSTR-2A/2B (purchase/ITC statement) is populated with invoices issued to them by e-invoicing suppliers.”
• Pre-Filled Summary Returns: While GSTR-3B is not fully pre-filled, the system suggests entries based on GSTR-1 and 2B data.
• Future Developments: The government is actively working on more advanced pre-filled return functionality.

Archiving and Record Retention:

• Taxpayers must retain copies of e-invoices and related records for at least 6 years from the end of the financial year to which they pertain (effectively 7 years in practice). Some sources recommend 8 years after the end of the fiscal year.
• Electronic invoices should be preserved in their digital form (JSON with IRN). The onus is on businesses to securely store the e-invoice data.

Glossary of Key Terms (From Provided Source):

• B2B (Business-to-Business): Transactions between two registered businesses.
• B2C (Business-to-Consumer): Transactions between a registered business and an unregistered consumer.
• B2G (Business-to-Government): Transactions between a registered business and a government entity.
• CBIC (Central Board of Indirect Taxes and Customs): The governing body responsible for formulating policy concerning indirect taxes in India.
• CGST (Central Goods and Services Tax): A tax levied on the intra-state supply of goods and services by the Central Government.
• E-invoice: An invoice prepared in a standardized digital format and authenticated electronically by the Invoice Registration Portal (IRP).
• E-reporting: Reporting of transactions (e.g., B2C) through regular GST return filing, rather than a separate real-time system.
• ERP (Enterprise Resource Planning): A suite of integrated applications that a company can use to collect, store, manage and interpret data from many business activities.
• GST (Goods and Services Tax): An indirect tax levied on the supply of goods and services.
• GSTIN (Goods and Services Tax Identification Number): A unique 15-digit identification number assigned to every registered taxpayer under GST.
• GSTN (Goods and Services Tax Network): The IT backbone of the GST system in India, responsible for managing the GST portal and related infrastructure.
• GSTR-1: A monthly or quarterly return that summarizes all outward supplies (sales) made by a registered taxpayer.
• GSTR-2A/2B: A purchase statement that shows the invoices issued to a buyer by e-invoicing suppliers.
• GSTR-3B: A monthly summary of output tax and input credit to determine net tax payable under GST.
• HSN Code (Harmonized System Nomenclature): A standardized system of names and numbers for classifying traded products developed and maintained by the World Customs Organization (WCO).
• IGST (Integrated Goods and Services Tax): A tax levied on the inter-state supply of goods and services.
• IRP (Invoice Registration Portal): A government-authorized portal for validating and registering e-invoices, generating the IRN and QR code.
• IRN (Invoice Reference Number): A unique 64-character hash string generated by the IRP for each validated e-invoice.
• ITC (Input Tax Credit): The credit a business receives for the GST paid on purchases of goods or services that are used in the course or furtherance of their business.
• JSON (JavaScript Object Notation): A lightweight data-interchange format that is easy for humans to read and write and easy for machines to parse and generate.
• NBFC (Non-Banking Financial Company): A financial institution that provides banking services without holding a banking license.
• OIDAR (Online Information Database Access and Retrieval Services): Services delivered through the internet with minimal human intervention, such as online advertising, cloud services, and digital content.
• PAN (Permanent Account Number): A ten-digit alphanumeric identifier issued to all taxpayers in India.
• QR Code (Quick Response Code): A type of matrix barcode that contains encoded information, such as the IRN and invoice details.
• SGST (State Goods and Services Tax): A tax levied on the intra-state supply of goods and services by the State Government.
• SEZ (Special Economic Zone): A geographical region that has economic laws that are more liberal than a country’s typical economic laws.
• Turnover Threshold: The minimum annual revenue a business must exceed to be required to comply with the e-invoicing mandate.

Key Takeaways:

• E-invoicing in India is a progressively expanding mandate, requiring real-time invoice reporting for many businesses.
• Compliance is critical to avoid penalties and ensure the validity of invoices for claiming input tax credit.
• The system is evolving towards greater automation in GST return filing, leveraging e-invoicing data to pre-populate returns.
• Businesses must adapt their systems and processes to comply with the e-invoicing requirements, including generating JSON files, uploading them to the IRP, and archiving e-invoices for several years.

This briefing document provides a comprehensive overview of e-invoicing and e-reporting in India based on the provided sources. Remember to consult official sources for the most up-to-date information.

INDEPTH ANALYSIS

• Phased Timeline of Implementation:
  – Initial Launch (2020): E-invoicing became mandatory on Oct 1, 2020 for businesses with annual turnover above ₹500 crore, covering large B2B and B2G transactions.
  – Gradual Expansion: The turnover threshold was subsequently lowered in stages: ₹100 crore from Jan 1, 2021, ₹50 crore from Apr 1, 2021, ₹20 crore from Apr 1, 2022, ₹10 crore from Oct 1, 2022, and ₹5 crore from Aug 1, 2023. At each phase, more mid-sized and small businesses fell in scope. Since April 2023, even taxpayers below the threshold have had voluntary access to the e-invoicing system (to encourage early adoption).
  – Current Status (2025): As of late 2025, all GST-registered businesses with turnover above ₹5 crore must generate e-invoices for eligible transactions. Those below ₹5 crore remain exempt (unless they opt in voluntarily).
  – Upcoming Changes: From April 1, 2025, a new rule kicks in: taxpayers with turnover ≥₹10 crore will no longer be allowed to report invoices older than 30 days on the Invoice Registration Portal (IRP). (A similar 30-day upload deadline already applies to taxpayers ≥₹100 crore since Nov 2023.) In practice, this means large businesses must upload each invoice to the IRP within 30 days of its issue date or the system will reject it, invalidating the invoice for GST purposes.
  – Future Outlook: The GST Council and government have signaled plans to extend e-invoicing to B2C (business-to-consumer) transactions in coming years. A voluntary B2C e-invoicing pilot is expected in select sectors and states by 2024–25, with a full rollout targeted by 2026–2027. This would mark a significant expansion of scope beyond the current B2B/B2G focus. Additionally, authorities intend to integrate e-way bills (the goods transport documents) with e-invoices for B2B and export transactions by 2026, creating a unified reporting system and further reducing tax evasion. [einvoice6.gst.gov.in] [einvoice6.gst.gov.in], [cleartax.in] [fiscal-req…ements.com] [cleartax.in] [economicti…atimes.com], [economicti…atimes.com] [economicti…atimes.com] [vatupdate.com], [vatupdate.com] [vatupdate.com], [fiscal-req…ements.com]

• Scope of Transactions – What’s Covered vs. Excluded:
  Covered: Under the mandate, domestic B2B invoices (business-to-business supplies within India) are the primary focus. This includes B2G invoices (supplies to government entities) and export invoices (zero-rated supplies to overseas recipients) issued by in-scope taxpayers. Related documents like credit notes and debit notes for these transactions also require e-invoicing. Even certain special cases such as deemed exports and supplies to SEZ developers fall under e-invoicing when the supplier is obliged to use it. In essence, any invoice that a GST-registered business above the threshold issues to another registered entity (or for export) must be e-invoiced. [einvoice6.gst.gov.in]
  Not Covered: B2C transactions (sales to unregistered persons/consumers) are currently exempt from e-invoicing. Instead, such sales are reported through aggregate values in GST returns (see “E-Reporting” below). Imports of goods into India are also outside the e-invoicing regime, since the supplier in that case is foreign and not on the GST system – import GST is handled via customs documentation, not the IRP. Similarly, certain document types are excluded: bills of supply (used for GST-exempt goods/services) and delivery challans/job-work challans do not require reporting to the IRP. In summary, any transaction where the supplier is not a GST-registered taxpayer in India or the document is not a tax invoice lies outside the e-invoice mandate. (Notably, online imports of services by consumers – e.g. foreign digital services supplied to Indian individuals under OIDAR – are effectively B2C imports and thus not e-invoiced. Those foreign providers have a special GST registration and continue to file returns without real-time invoice reporting.) [einvoice6.gst.gov.in]

• Scope of Taxable Persons – Who Must Comply:
  The e-invoice mandate is determined primarily by a turnover threshold on the supplier’s aggregate annual turnover (PAN-based, across India). All GST-registered businesses exceeding the threshold (₹5 Cr at present) are in scope, regardless of whether they are Indian-owned or foreign-owned, and irrespective of their constitution (company, partnership, etc.). This means even a foreign company registered in India for GST (as an import-export unit or OIDAR provider) would be subject to e-invoicing if it crosses the turnover limit, unless falling under an exempt category. [cleartax.in], [einvoice6.gst.gov.in]
  Exempt Entities: The government carved out specific categories of registered persons who are exempt from e-invoicing, even if their turnover is high. According to Rule 48(4) CGST Rules and associated notifications, the following are not required to generate e-invoices:
  – SEZ units: Businesses operating as units in Special Economic Zones are exempt (however, SEZ developers are not exempt).
  – Banks, insurers, and financial institutions (including NBFCs): These regulated entities have their own invoicing norms and are exempt.
  – Goods transport agencies (GTAs): Exempt due to special consignment note invoicing rules.
  – Passenger transport service providers: e.g. airlines or stage carriage bus services issuing tickets.
  – Cinema admissions: Suppliers providing services by way of admission to cinema films (who issue tickets).
  These sectors were given blanket exemptions likely because their invoices/tickets have unique formats or because invoice data is already captured through other means. All other persons – including government departments and public sector units when acting as suppliers – must follow e-invoice rules if above the turnover cut-off (though government entities as buyers simply receive e-invoices from their vendors; they don’t issue GST invoices unless registered for GST as suppliers themselves). Importantly, if a taxpayer is below the turnover threshold, they are out of scope even if they make B2B supplies; they continue using standard invoicing without IRP reporting until they cross the limit. Once the threshold is exceeded in any financial year (from 2017-18 onward), e-invoicing becomes compulsory from the next period onward. Thereafter it remains applicable in subsequent years even if turnover falls, as long as notifications don’t change (the threshold is examined on the highest turnover in any past year). [einvoice6.gst.gov.in] [cleartax.in]

• E-Invoice Contents and Format (Data Requirements):
  India uses a standardized invoice schema (Form GST INV-01) for e-invoicing. The actual invoice is generated by the taxpayer’s own system (ERP or billing software) but must be formatted as a JSON file when reported to the government. This ensures a uniform structure with mandatory fields and validation rules. Key data points required in an e-invoice JSON include:
  – Supplier details: GSTIN (GST identification number) of the supplier, legal name, address, PAN, and contact details.
  – Recipient (Buyer) details: GSTIN of the buyer (if B2B/B2G), legal name, billing address and place of supply state code. (For exports, recipient might be marked as an export with country code.)
  – Invoice particulars: A unique invoice number (assigned by supplier) and date of issue. The system will check that this invoice number has not been used before (to prevent duplicates).
  – Line item details: Description of goods or services, quantity, unit price, total value per line, and the HSN code (Harmonized System Nomenclature) for each item. HSN codes must be reported at least at 4-digit level for smaller taxpayers, or 6-digit level for those with turnover above ₹5 Cr, to classify the goods/services.
  – Tax amounts: The GST breakdown for each item or invoice total – SGST, CGST (for intra-state supplies) or IGST (for inter-state or exports), and any cess, calculated as per the applied tax rate. The schema includes fields for taxable value and tax amounts for each rate slab.
  – Order/reference details: Optional fields for linking to any purchase order, sales order, or other reference number, if applicable.
  – Additional information: e.g. whether reverse charge is applicable, discount amounts, freight or other charges, etc., as needed.
  – Master codes: The system uses standard codes for certain fields (like country codes, unit of measure codes) which must be used if those fields are populated.
  Essentially, the data provided must meet the government-notified schema requirements in full. If any mandatory field is missing or the format is incorrect, the IRP will reject the invoice. For example, an invoice without a valid GSTIN for the buyer (where required) or with an invalid date format would fail validation. (The official schema defines about 140 fields, of which ~50 are mandatory. This schema is published by the GSTN and aligns with the information needed for GST returns.) [fiscal-req…ements.com], [basware.com] [fiscal-req…ements.com], [gstn.org.in] [vatupdate.com] [cleartax.in]

• E-Invoice Generation & Transmission Process:
  Technical Format: As noted, invoices are uploaded in JSON format via designated channels. Large businesses typically integrate their ERP systems with the government’s APIs to automate this. Others may use offline tools or excel utilities provided by the GST Network, or even manually enter invoice data on the e-invoice portal to generate the JSON and IRN. The process is as follows:
  1. Preparation: The supplier finalizes the invoice in their own system and prepares a JSON file conforming to the e-invoice schema. This can be done via API integration (direct machine-to-machine communication) or by using a government-provided interface to convert invoice data into JSON.
  2. Upload to IRP: The JSON invoice data is transmitted to an Invoice Registration Portal (IRP) – a government-authorized portal. (There are multiple IRPs now – including NIC-operated and private GSTN-authorized portals – but a taxpayer can use any of them; they all connect to the central system.) The IRP performs basic validations on the data (e.g., checks that GSTINs are valid and active, invoice hasn’t been reported before, mandatory fields present). [gstn.org.in] [fiscal-req…ements.com]
  3. IRN Generation: If the data passes validation, the IRP will generate a unique Invoice Reference Number (IRN) – a 64-character hash string – for that invoice. It also generates a QR code containing key invoice particulars (such as supplier and buyer GSTINs, invoice number/date, invoice total, and the IRN itself) in encoded form. The IRP then digitally signs the invoice data, effectively certifying it. [fiscal-req…ements.com] [vatupdate.com], [fiscal-req…ements.com]
  4. Return of validated invoice: The IRP returns the digitally signed JSON back to the supplier, now augmented with the IRN and QR code (and an IRP timestamp). This response is the “e-invoice”. The supplier’s system can automatically read this and even generate a human-readable PDF of the invoice including the QR code. For legal purposes, the combination of supplier’s invoice data + IRP’s signature/QR constitutes a valid e-invoice. The supplier must provide this IRN/QR code-bearing invoice to the buyer (electronically or as a printed copy) as it is the buyer’s evidence for claiming input tax credit. [basware.com] [fiscal-req…ements.com]
  5. Data sent to GST and E-Way systems: Simultaneously, the IRP forwards the invoice details to the GSTN’s backend. The invoice data is transmitted to the GST portal to automatically populate the supplier’s GSTR-1 return (sales statement) and the buyer’s GSTR-2B (purchase/ITC statement). If the invoice involves a goods movement that requires an e-way bill, the IRP can also forward relevant details to the e-way bill system (NIC) – so that the supplier only needs to add vehicle/transport info to generate the e-way bill. (In the future, e-invoice and e-way bill may be fully merged for one-stop reporting.)
     Importantly, this is a clearance model – meaning an invoice becomes legally valid only after it’s registered and an IRN is obtained. The IRP is not merely a post-facto reporting tool; it’s integral to invoice issuance. [expertinsi…tsnews.com] [fiscal-req…ements.com]

• Deadline for Reporting Invoices (Timing Requirements):
  Under GST law, a taxpayer is supposed to issue a valid tax invoice within prescribed timelines (e.g. within 30 days of service completion for services). With e-invoicing, an additional compliance layer is that the invoice must be reported to the IRP essentially at the time of issuance. In practice, this often means real-time or same-day upload of the invoice data to obtain the IRN and include it on the printed invoice given to the buyer. Initially, there was no strict cut-off and invoices could be back-reported, but recent rules have tightened this:
  – Real-Time Expectation: Ideally, businesses should generate and report the e-invoice immediately when the invoice is raised (the IRN generation is instantaneous, usually a few seconds). This ensures the invoice carries the IRN/QR from the start. In fact, an invoice without an IRN (if one was required) is deemed invalid from issuance – it’s as if the invoice was never issued. So issuing an unreported invoice is non-compliance in itself. [cleartax.in], [cleartax.in]
  – 30-Day Reporting Window: To enforce timeliness, the GSTN has introduced a rule that invoices cannot be reported after a certain number of days from their date. Currently, for large taxpayers (turnover ≥ ₹100 Cr), any invoice dated more than 30 days ago will be blocked by the IRP (effective since Nov 1, 2023). From April 1, 2025, this 30-day rule extends to all taxpayers with ≥₹10 Cr turnover. For example, an invoice dated April 1, 2025 must be uploaded by April 30, 2025; after that, the IRP will reject it. Failing to report within this window means no IRN can ever be generated for that invoice. The invoice then cannot be used to claim input tax credit by the buyer and is not a valid record for tax purposes. (The supplier would have to cancel that invoice and issue a fresh one or manually account for the tax in returns with penalties.) [economicti…atimes.com], [economicti…atimes.com] [economicti…atimes.com]
  – No Current “Grace Period” for small taxpayers: As of now, businesses under ₹10 Cr turnover (who only joined e-invoicing recently at ₹5+ Cr) are not yet subject to an automated 30-day cutoff on the portal. However, since the law already makes unreported invoices invalid, even small taxpayers are expected to comply in real-time. There is discussion of possibly shortening the allowed reporting window further (initially a 7-day limit was considered in 2023 for ₹100Cr taxpayers, but it was deferred in favor of 30 days). The trend indicates increasingly strict real-time compliance. [economicti…atimes.com], [economicti…atimes.com] [cleartax.in]
  In summary, e-invoices should be reported as close to the time of invoice generation as possible (ideally instantly). The maximum delay allowed for larger companies will be 30 days, and the direction is toward similar discipline for all. Businesses need to incorporate IRP submission into their invoicing workflow to avoid any delay beyond the permissible window. [economicti…atimes.com], [economicti…atimes.com]

• Penalties and Consequences for Non-Compliance:
  Compliance with e-invoicing is enforced by both legal penalties and business consequences:
  1. Invalid Invoice & ITC Denial: If a required e-invoice is not generated (i.e. the supplier issues a regular invoice without routing it through the IRP), that invoice is treated as invalid under GST law. Legally, this is considered as failure to issue an invoice in the prescribed manner (a violation of GST rules). The immediate effect is that the buyer cannot claim input tax credit (ITC) on an invalid invoice, since a valid tax invoice with IRN is a prerequisite for ITC. This can disrupt business: buyers may refuse to accept or pay an invoice lacking a valid IRN/QR, and transporters may not carry goods without a proper e-invoice document. Additionally, details of such an invoice won’t populate the GST returns (GSTR-1/2B), creating mismatches. In essence, non-compliance undermines the transaction’s legitimacy in the GST system. [cleartax.in], [cleartax.in] [cleartax.in]
  2. GST Act Penalties: The GST law prescribes penalties for not adhering to invoicing rules. For failure to issue an invoice or issuing an invoice not conforming to requirements, the penalty can be 100% of the tax due on that invoice or ₹10,000, whichever is higher, per instance. This means if tax of ₹8,000 was on that supply, penalty is ₹10,000 (minimum); if tax was ₹50,000, penalty can be ₹50,000. This is a general penalty under Section 122 of CGST Act, applied here for non-generation of e-invoice. Separately, if an e-invoice is issued but with incorrect particulars (misreported data), a penalty up to ₹25,000 may apply for each such invoice. [cleartax.in]
  3. Goods Detention: Carrying goods by road without a valid e-invoice (when one was required) is akin to moving goods without proper documents. GST officers at check-posts or during transit checks may treat this as a contravention triggering detention of the conveyance and goods under Section 129 of the CGST Act. Since the e-invoice (with QR code) is often needed alongside the e-way bill, not having one can lead to the same penalties as transporting without documentation – typically a hefty fine equal to the tax or more. This adds a practical deterrent: logistics can be disrupted and goods seized for non-compliance. [cleartax.in]
  4. Loss of Input Credit (for Buyers): From the buyer’s perspective, if their seller does not comply with e-invoicing, the buyer stands to lose input credit on that purchase. A new rule effective in 2025 explicitly ties ITC eligibility to the seller uploading the invoice within 30 days. Thus, non-compliance by the supplier directly hits the customer, which pressures businesses to only deal with compliant vendors. This indirect consequence can lead to loss of business for non-compliant suppliers. [economicti…atimes.com], [economicti…atimes.com]
  Beyond these, repeated non-compliance can invite departmental audits or scrutiny. Since e-invoicing data is used for analytics, not reporting invoices might flag a taxpayer for investigation. In summary, failing to e-invoice when required is a serious offense: it not only incurs monetary penalties (minimum ₹10k per invoice and potential fines during transit), but also nullifies the tax invoice itself, harming both seller and buyer (no credit, potential cancellation of supply). Tax authorities have urged strict adherence, highlighting that an invoice without an IRN is “not a valid document” for GST. Businesses are therefore implementing system checks to ensure every invoice triggers IRN generation to avoid these outcomes. [cleartax.in], [cleartax.in]

• Format and Transmission of Data to Authorities (E-Invoicing & E-Reporting):
  E-Invoicing Format: India’s e-invoice format is built for direct system-to-system communication. Data is transmitted in JSON format via API to the IRP. The IRP returns a digitally signed JSON (with IRN and QR). Human-readable invoices (PDF/print) are generated by the business from that data. The content of the JSON adheres to the GST INV-01 schema (as described above), which is essentially a machine-readable representation of a tax invoice. There is no use of formats like PDF or XML for submission – the government chose JSON for its lightweight and widely compatible nature. The transmission is typically over secure internet connection (HTTPS), and each invoice request/response is a separate API call. For high-volume upload, taxpayers can use batch tools or GST Suvidha Providers’ solutions to push many invoices in one go. The end result is that the tax authorities receive granular invoice data in real time, in a standardized form that can be fed into their databases. [fiscal-req…ements.com]
  E-Reporting (Other Transactions): For transactions currently not covered by e-invoicing (e.g. B2C or imports), the “e-reporting” is accomplished via the regular GST return filing process rather than a separate real-time system. For instance, a business’s B2C sales are reported in summary in the GSTR-1 return (usually by listing total value of B2C supplies state-wise, or invoice-wise for large retail invoices above ₹2.5 lakh to unregistered buyers). These returns are filed monthly or quarterly (by the 10th of the next month for GSTR-1 for most) – so the data reaches the authorities on a periodic basis, not immediately at invoice issuance. Imports of goods are reported through Bill of Entry filings on the customs ICEGATE system, and the GST paid at import reflects in the importer’s GST returns automatically. In other words, there isn’t a separate IRP-like portal for B2C or cross-border invoices yet; the reporting is indirect and through existing return channels.
  However, as noted, India plans to extend the e-invoice system itself to B2C in the future, effectively bringing those into the real-time reporting net. If and when “e-reporting” for B2C is implemented, it will likely use the same IRP infrastructure and JSON schema, perhaps with some modifications (for example, not requiring a buyer GSTIN, but still requiring an IRN for each retail invoice above a certain amount). The timeline and method for this are still under discussion (a voluntary pilot is expected first). For now, the obligation for non-e-invoiced transactions is to report them in the monthly returns by the due date – e.g., sales to consumers in October must be reported by the 10th or 11th of November in GSTR-1. This is less immediate than e-invoicing but is the interim “e-reporting” mechanism. There is no separate file or format akin to the e-invoice JSON for these transactions; they are aggregated in the return forms. [vatupdate.com], [fiscal-req…ements.com] [vatupdate.com]
  Transmission to Tax Authorities: In the e-invoicing scenario, once an invoice is registered, the data is automatically transmitted to the GST authorities’ database and becomes available to tax officers. The IRP itself is run by authorized providers under the oversight of GSTN (Goods and Services Tax Network), and after initial 24-hour storage for processing, the IRP does not retain the data long-term. Instead, the data goes to the central GST system (and the state tax systems via GSTN) in real-time. This is how the government builds a transaction-level dataset for audits and return cross-verification. For e-reported data via returns (B2C, etc.), the transmission is simply the filing of the return on the GST portal, which the tax authorities then have access to. [fiscal-req…ements.com]
  Reporting Timeline: The question of “X days after invoice issuance” is applicable where a country allows some lag in reporting. In India’s e-invoice model, the requirement is effectively immediate clearance (with the new 30-day absolute limit for large companies as a backstop). So officially, invoices must be reported before or at the time of issuance – India does not allow a long delay by design. By comparison, if we consider future e-reporting for B2C, the government might allow a brief grace (e.g. a few days) for batch reporting of those invoices, but currently there’s no such separate system mandated. Many businesses in practice do batch their e-invoice uploads (for instance, uploading all day’s invoices at night), but as long as it’s within the allowed window, it’s compliant. In short, for mandated invoices, the data goes to authorities almost instantly, and for non-mandated, it goes by the next return filing. [economicti…atimes.com] [basware.com]

• Archiving and Record Retention Requirements:
  Taxpayers must retain copies of e-invoices and related records for a lengthy period to comply with GST law and auditing needs. Indian GST law (Section 36 of CGST Act) generally requires keeping accounts and records for 6 years from the end of the financial year to which they pertain. In effect, due to annual return timelines, this can be up to about 7 years in practice (e.g., records for FY 2020-21 must be kept until at least late 2027). However, some sources recommend an even longer retention for e-invoices – eight years after the end of the fiscal year of issue – as a best practice, likely to cover any extended litigation scenarios or as required by other business laws. For instance, one compliance advisory explicitly states “invoices must be stored for 8 years” after the year of issuance. [english.dh…online.com] [basware.com] [basware.com], [basware.com]
  Format of Archival: Electronic invoices should be preserved in their digital form (JSON with IRN) because that contains the digital signature and QR code from the IRP. It’s common to also keep human-readable copies (PDFs) for convenience, but the legal evidence of authenticity is the IRN and the digitally signed payload. The government’s systems do not serve as an archive for taxpayers – the IRP only retains data for 24 hours and the GST portal shows only summaries. So the onus is on businesses to securely store the e-invoice data.
  Storage Location: The regulations allow electronic records to be stored on servers outside India, provided they are accessible to authorities on demand. This means a company can use cloud storage or overseas data centers, but must be able to produce or fetch any invoice record during a GST audit or investigation. Many businesses use compliance solutions or their ERPs to maintain an e-invoice repository. It’s advisable to have backups given the long retention period. If invoices are stored electronically, businesses should also ensure the integrity and security of the data (no tampering, and proper indexing). When asked by a tax officer, the business might need to regenerate a print of the e-invoice or provide the JSON and QR code for verification. [basware.com], [basware.com]
  In addition to invoices, the audit trail or acknowledgment of IRN generation may be kept as proof. While not mandated, maintaining a log of IRN details can help. In summary, e-invoices must be kept for at least 6-8 years and be available for scrutiny. This archiving requirement aligns with general GST record-keeping rules and is crucial since e-invoices form the basis of tax credits and liabilities over time. Non-availability of records beyond the retention period can be a compliance breach, so companies are careful to store these digitally signed invoices for the long term. [basware.com], [english.dh…online.com]

• Pre-Filled GST Returns (Using E-Invoice Data):
  India’s GST system is evolving towards greater automation in return filing, but as of 2025 fully pre-filled tax returns are not yet a reality for most taxpayers. There is no official “pre-filled VAT return” provided to taxpayers that they can simply confirm, the way some countries have started doing. However, e-invoicing has significantly enabled auto-population of return data: the details of each e-invoice flow into the GSTN systems and help prefill parts of the GST returns:
  – Auto-Population of Sales (GSTR-1): When a supplier generates an e-invoice, the invoice particulars (buyer GSTIN, invoice number, date, taxable value, tax amount, etc.) are automatically recorded in that supplier’s GSTR-1 draft on the GST portal. The taxpayer can view these auto-drafted entries and need not re-enter the B2B invoice details while filing the return. This reduces manual work and transcription errors. Essentially, the e-invoices form the basis of the outward supplies return, making GSTR-1 preparation largely automated for e-invoiced transactions. [expertinsi…tsnews.com]
  – Auto-Population of Purchases (GSTR-2B/GSTR-2A): Correspondingly, the same e-invoice data is mirrored to the buyer’s side. A buyer can see the invoices issued to them by e-invoicing suppliers in their GSTR-2A/2B (purchase statements) in near real-time. This lets buyers know how much input tax credit (ITC) is available from those purchases. So in a sense, the purchase side of the return is pre-filled from the supplier’s e-invoices. Buyers no longer have to collect physical invoices and manually enter details for claiming credit; the system automatically reflects it provided the seller complied. This has improved tax credit matching and reduced discrepancies.
  – Pre-Filled Summary Returns: The ultimate tax form to be filed is GSTR-3B (a monthly summary of output tax and input credit to determine net tax payable). Currently, GSTR-3B is not fully pre-filled, but the GST system does make suggested entries based on GSTR-1 and 2B data. For example, it may pre-fill the outward taxable turnover and tax amounts (from GSTR-1/e-invoices) and input credit (from GSTR-2B). Taxpayers still have to review, adjust (if any amendments or non-invoice items), and submit the GSTR-3B. So we cannot say the return is auto-filed, but much of the information comes in automatically.
  – Future Developments: The government is actively working on more advanced pre-filled return functionality. Recent news (late 2025) indicates a major GST system overhaul aiming for fully automated, pre-filled returns using e-invoice and other data. The idea is that data from e-invoices, e-way bills, TDS, imports, etc., will be integrated to present a draft return to the taxpayer each period, which the taxpayer would simply confirm or correct. This would mirror the approach of some countries where the tax authority provides the preliminary return. While not in effect yet, this is on the roadmap – pilots and internal testing have been mentioned. So, we can expect in coming years that much of the GST filing process will be streamlined thanks to mandatory e-invoicing, reducing manual intervention. [expertinsi…tsnews.com], [expertinsi…tsnews.com] [expertinsi…tsnews.com]
  Bottom line: Currently, India does not have pre-filled GST returns that the taxpayer can accept without input, but e-invoicing data is heavily leveraged to auto-fill return forms. Taxpayers benefit from this integration through easier compliance (less data entry) and the tax department benefits via improved accuracy and the possibility of advanced analytics (for example, automated discrepancy checks between reported sales and purchases across taxpayers). There is no pre-filled “VAT refund/return” mailed by the government yet, but the trajectory is towards that level of automation. For now, one still must file GSTR-1 and GSTR-3B, albeit with much assistance from the system populating e-invoice info. Notably, if a taxpayer fails to e-invoice, those transactions won’t appear in the pre-populated data, which again highlights how non-compliance puts one outside the system and at risk of penalties and credit denial. [expertinsi…tsnews.com]

• Regulatory and Official References:
  The legal basis for e-invoicing in India comes from the Central Goods and Services Tax (CGST) Rules, 2017, specifically Rule 48(4) which empowers the government to notify classes of taxpayers who must issue e-invoices for specified documents. The mandates have been given effect through a series of notifications issued by the Central Board of Indirect Taxes and Customs (CBIC). For example, Notification 68/2019 and 70/2019 first introduced the concept in late 2019, and subsequent notifications (e.g., 13/2020, 88/2020, 5/2021, 1/2022, 17/2022, 10/2023) updated the turnover thresholds and dates for each phase. These government notifications and circulars can be found on the official CBIC and GST Council websites. Additionally, the GSTN and NIC maintain official portals: the GST e-invoice portal (einvoice.gst.gov.in) provides tools, schema definitions, FAQs, and resources for taxpayers. The GSTN has published a comprehensive “e-Invoicing Handbook” and numerous advisories – for instance, the November 2024 advisory announcing the 30-day rule for IRN generation. There are also dedicated sites (like the IRP websites and developer portals) providing the API specs and integration guidelines. For further reference, one can consult the official GST legislation (CGST Act and Rules – Rule 48) and the notifications mentioned (available on CBIC’s website), as well as press releases from the GST Council. Government FAQs and user manuals are a useful resource to understand practical aspects – for example, the GSTN’s FAQ clarifies which transactions are covered or exempt and the procedure to generate e-invoices. All these confirm the points above and reflect the most recent requirements as of 2025. In summary, India’s e-invoicing system is well-documented through official channels, and taxpayers and observers can refer to those for the authoritative wording of the rules and any new updates. [einvoice6.gst.gov.in] [economicti…atimes.com], [economicti…atimes.com] [gstn.org.in] [einvoice6.gst.gov.in], [einvoice6.gst.gov.in]

• See also
  • E-Invoicing/Real Time Reporting – What can you find on VATupdate.com
  • Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
  • Country Profiles on E-Invoicing, E-Reporting, E-Transport, SAF-T Mandates, and ViDA Initiatives

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