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Yes, in limited circumstances you can sell goods online without GST registration and issue a normal commercial invoice. Notification 34/2023-Central Tax (effective 1 October 2023) allows an eligible small goods seller to use a qualifying electronic-commerce operator (ECO) without mandatory registration when the seller stays within the applicable section 22 turnover threshold, makes only intra-State supplies, uses an ECO in only one State or Union territory, completes portal declarations and obtains an enrolment number before supplying. The document sent to the buyer is an invoice or bill, not a GST tax invoice: it should show the sale details and total amount, but no GST rate or GST amount. The exemption is conditional, so adding inter-State shipping, crossing the threshold or changing the selling model can make registration necessary.
What does “without GST registration” mean for an online seller?
An unregistered seller can document a sale with an ordinary commercial invoice, but cannot issue a GST tax invoice or collect GST as a separately stated tax. Section 31 places the tax-invoice obligation on a registered person supplying taxable goods, and Rule 46 lists the GSTIN and other particulars required on that registered-person document. Your invoice therefore proves the commercial transaction; it does not create input-tax-credit (ITC) entitlement for the buyer.
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The 2023 exemption is not a blanket online-business exemption. It is aimed at eligible persons supplying goods through an ECO while remaining within the relevant registration threshold and meeting every condition in Notification 34/2023-Central Tax.
Who can use the online-goods exemption?
You may use the route only when all conditions below are satisfied before the order is supplied. Missing one condition can remove the protection.
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- Turnover: aggregate turnover remains below the current section 22 registration threshold applicable to your State or Union territory. Thresholds and special-category treatment can change, so verify the current position before relying on an old figure.
- Goods only: the notification concerns supplies of goods through an ECO. Services, mixed models and products subject to separate restrictions need a separate analysis.
- No inter-State goods supplies: you must not ship goods from one State or Union territory to a customer in another under this exemption.
- One State/UT ECO footprint: you may not use an ECO for supplies in more than one State or Union territory under the enrolment.
- PAN and address declaration: declare your PAN, business address and intended State/UT on the common portal and complete validation.
- Enrolment number: obtain the number generated on the common portal before making any supply through the ECO.
- Marketplace acceptance: the chosen ECO must support its current onboarding process for unregistered goods sellers. The notification does not force every platform to accept them.
The GST Council’s meeting record describes the waiver and related procedure for unregistered goods suppliers and composition taxpayers using ECOs. A government year-end release characterises the reform as enabling intra-State goods sales through ECOs for small taxpayers; it does not remove the conditions above.
How do I check eligibility before accepting an order?
Run this check for the business as a whole, not just for one product or one marketplace order.
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1Scan for outdated or missing drivers - takes under a minute2Clear out junk files and repair common Windows errors3Fix the driver behind crashes, sound loss and screen glitches- Calculate aggregate turnover. Include the supplies that count toward the GST registration test and compare the total with the current State/UT threshold. Do not assume that a threshold quoted for service suppliers or another State applies to your goods business.
- Map delivery locations. Confirm that the seller’s State and every customer delivery address are in the same State/UT. A customer’s billing address, warehouse location and dispatch point can create different tax questions; investigate any mismatch before shipping.
- Count ECO locations. Check whether your intended account, fulfilment arrangement or additional storefront would amount to using an ECO in a second State/UT.
- Check product and platform rules. Ask the ECO whether it accepts an unregistered seller, what documents it requires and how it handles returns, settlements and tax-collected-at-source (TCS) reporting.
- Record the decision. Keep a dated eligibility worksheet showing turnover, State/UT, platform and the checks performed. Re-run it whenever the business expands.
How do I obtain the enrolment number?
Complete the common-portal process before your first marketplace supply. Notification 34/2023 requires the PAN, business address and intended State/UT to be declared, successful validation and an enrolment number; it also says no supply may be made through the ECO before that number is granted.
- Prepare the PAN and the business address that will be used for the online-goods activity.
- On the common portal, submit the declaration for the State/UT in which you will make the intra-State supplies.
- Complete the portal’s identity and data validation steps and save the acknowledgement.
- Wait for the enrolment number. Give it to the ECO during onboarding or update the seller profile as the platform instructs.
- Do not accept or dispatch an ECO order until the number is available and the platform confirms that the account is enabled under its current procedure.
Keep a copy of the declaration, validation result and enrolment communication with your sales records. If your address, State/UT or selling arrangement changes, check whether a new declaration or GST registration is required.
What should an invoice without GST registration contain?
Use a clear commercial invoice or bill for every order. The following fields give the buyer and your records enough information to identify, price and settle the transaction without presenting it as a tax invoice.
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- Seller’s legal or trading name and business address.
- Buyer’s name and delivery address; add a billing address when it differs.
- A unique, consecutive invoice or order number and the issue date.
- Plain-language product description, quantity and unit price.
- Item-level discounts, shipping or other charges, where applicable.
- The final amount paid or due, currency and payment status.
- Payment method or settlement reference, if useful for reconciliation.
- Return, cancellation and refund terms that apply to the order.
Label the document “Invoice” or “Bill.” Do not print “GST tax invoice,” a GSTIN that you do not hold, a GST rate, or a GST amount collected from the customer. Do not add wording that suggests the buyer can claim ITC from the document.
Example layout
INVOICE / BILL
Seller: [business name]
Address: [business address]
Invoice no.: [unique consecutive number] Date: [DD-MM-YYYY]
Buyer: [customer name]
Delivery address: [full address]
Item Qty Unit price Discount Line total
[Product description] 1 INR 000.00 INR 00.00 INR 000.00
Shipping: INR 00.00
Total paid / due: INR 000.00
Payment status: Paid / Due
Payment reference: [reference]
Returns: [your applicable terms]This is a practical format, not a government-mandated template. An ECO may impose additional fields or a particular file format, so follow its current seller instructions as long as they do not turn the document into a false GST tax invoice.
Should I charge GST on the invoice?
No. If you are not GST-registered, do not show GST as a separately collected amount or apply a GST rate to the line items. Quote the commercial price and any delivery or other charges, then show the total payable. A buyer who needs an ITC-eligible tax invoice must purchase from a registered supplier that can issue one; your commercial bill cannot substitute for it.
Do not describe a marketplace deduction as GST charged to the customer. The platform may collect TCS from the operator’s settlement under the GST law, but that accounting entry does not change your unregistered seller invoice.
How does marketplace TCS affect my records?
When an ECO collects consideration, it collects TCS on the net value of taxable supplies. The GST Council Law Committee FAQ states a notified structure of 0.5% CGST plus 0.5% SGST/UTGST for intra-State supplies, or 1% IGST, and says the ECO must be registered for this purpose.
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Your settlement may therefore be lower than the invoice total after TCS, platform fees, refunds or other adjustments. Reconcile the settlement report to the underlying orders rather than reducing the customer’s invoice by the TCS amount.
- Match each order number to the commercial invoice and payment received.
- Separate product returns, cancellations and refunds from completed supplies.
- Record TCS entries exactly as shown in the ECO report; do not relabel them as GST charged by you.
- Retain the marketplace reports with bank statements and shipping evidence so turnover can be checked independently.
Is selling through my own website different from using a marketplace?
Yes. A direct website or social-channel sale may avoid an ECO’s onboarding and settlement process, while a marketplace adds platform rules, possible TCS reporting and enrolment checks. Neither route automatically permits inter-State goods sales without registration.
| Issue | Own website or social channel | Marketplace / ECO |
|---|---|---|
| Geography under the exemption | Must still remain within the permitted intra-State model; verify whether the activity falls within Notification 34/2023. | Notification 34/2023 specifically addresses qualifying goods supplied through an ECO and prohibits inter-State supplies. |
| Onboarding | You control checkout, invoice numbering and customer records. | The ECO may require enrolment details, identity checks and a platform-specific invoice format. |
| Customer consideration | Usually collected directly by your payment provider; document the settlement. | The ECO may collect consideration and issue settlement reports. |
| TCS | No ECO TCS entry merely because the sale is online; confirm the payment arrangement separately. | Reconcile the ECO’s TCS deductions and reports to orders and returns. |
| Returns | You set the policy and must retain courier and refund evidence. | The ECO’s return workflow can change the settlement and the order history. |
| Registration trigger | Crossing the applicable threshold, making inter-State supplies or another statutory trigger can require registration. | The same triggers apply, plus loss of any notification condition or inability to maintain enrolment. |
The exemption is not a general approval for every social-commerce or digital business model. Confirm that the exact activity is a supply of goods and that the platform arrangement fits the notification.
What is the safest order-to-invoice workflow?
Use one controlled sequence so an order is never shipped before eligibility and enrolment are checked.
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- At checkout: block delivery addresses outside the permitted State/UT or route them for a registration review.
- At order confirmation: assign a consecutive invoice number and capture the buyer and delivery details.
- At dispatch: issue the invoice or bill showing the goods, prices, discounts, shipping and total; do not show GST.
- At settlement: match the payment, platform fees, TCS, refunds and bank credit to that invoice.
- At month-end: update aggregate turnover and review State/UT, product, ECO and enrolment conditions.
- At expansion: pause the new activity and obtain professional advice before adding inter-State shipping, another State/UT, a second ECO footprint or a new business line.
When must I stop using this method and register?
Stop relying on the exemption and obtain advice when a condition is no longer true. The clearest triggers are crossing the applicable turnover threshold, making an inter-State supply of goods, using an ECO in a second State/UT, supplying before enrolment, or failing the portal validation and enrolment requirements.
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Registration can also become necessary because of another provision of the GST law or a change in the nature of your supplies. The 2023 notification does not override product-specific restrictions, later amendments or rules that apply to a different business model. Treat a planned expansion as a tax-status change, not merely a website setting.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What records should I keep?
Maintain an order file that lets you reconstruct each sale and test the exemption conditions. Keep the commercial invoice, order confirmation, payment or settlement record, dispatch and delivery proof, return or refund evidence, and marketplace reports including TCS entries. Preserve the portal declaration, validation acknowledgement and enrolment number as well.
Use consistent invoice numbering and do not reuse a number after cancellation; link a refund or replacement to the original order. Store the State/UT and delivery address captured at checkout, because those fields support the intra-State test. Retain records for the period required by applicable law and the ECO’s terms, and keep backups that can be exported if the platform account is closed.
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- Calling the document a tax invoice: rename it “Invoice” or “Bill” and remove GST fields when you are unregistered.
- Adding GST to make the price look formal: quote a tax-inclusive commercial price only in the ordinary pricing sense; never represent a GST collection you are not authorised to make.
- Shipping across a State border: block or review the order before dispatch; an inter-State goods supply conflicts with the notification condition.
- Skipping enrolment: an ECO order made before the enrolment number is granted is not protected by the procedure.
- Assuming every marketplace accepts unregistered sellers: obtain written onboarding requirements from the specific ECO.
- Ignoring TCS reconciliation: keep the customer invoice at its sale value and record the ECO deduction separately.
- Using an old turnover limit: check the current State/UT threshold and later amendments before each major expansion.
How should I handle a customer who asks for a GSTIN?
Tell the customer accurately that the business is not GST-registered and therefore issues a commercial invoice rather than a GST tax invoice. Do not borrow another entity’s GSTIN or alter the invoice to satisfy a procurement form. If the customer requires ITC, offer a registered-supplier route or explain that the purchase will not generate an ITC-eligible tax invoice.
Frequently Asked Questions
Can an unregistered seller issue an e-invoice or GST e-invoice number?
No. The process described here produces a commercial invoice or bill, not a GST e-invoice. GST e-invoicing requirements attach to registered taxpayers covered by the applicable rules, so an unregistered seller should not create a document that imitates that system.
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What if a buyer enters a different State as the delivery address by mistake?
Pause dispatch and correct the order record before shipment. If the goods would move across a State or Union-territory border, treat it as a potential inter-State supply and obtain tax advice rather than relying on the unregistered-seller exemption.
Can I sell both goods and services under the same enrolment?
The 2023 waiver is framed for eligible goods supplied through an ECO. Adding services or a mixed supply can change the registration analysis, so review the whole business before advertising the additional offering.
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Does marketplace TCS mean the customer paid GST?
No. TCS is an amount the ECO collects and reports under the GST framework; it is not GST that you have added to the buyer’s commercial invoice. Reconcile the deduction in your settlement records instead of listing it as customer tax.
Can I keep using the exemption after opening a second marketplace account?
Not automatically. The notification condition concerns use of an ECO in more than one State or Union territory, so a second account or fulfilment arrangement may require a fresh analysis even if the products and turnover are unchanged.
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