In India, reverse-charge tax liability does not by itself decide who reports an e-invoice. When a notified, registered supplier makes a covered supply under section 9(3) of the CGST Act, that supplier prepares the invoice in its accounting system and reports it to an Invoice Registration Portal (IRP) for an Invoice Reference Number (IRN) and signed QR code. The customer may pay the GST under reverse charge, but the customer does not become the e-invoice reporter.
A different rule applies when a registered person receives a relevant supply from an unregistered supplier. Section 31(3)(f) requires the registered recipient to issue a self-invoice; the IRP FAQ says e-invoicing does not arise for that receipt. The self-invoice and an IRP-generated e-invoice are therefore separate obligations.
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The rule in one view
This article addresses Indian GST. Other VAT or GST systems can assign reverse-charge invoicing duties differently.
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Reverse charge changes the person liable to discharge GST, not automatically the person who creates the supplier’s tax invoice or reports it. The customer’s accounting entry for reverse-charge tax, payment through the GST return and input-tax-credit conditions are separate from the supplier’s IRP submission.
Two reverse-charge situations that must not be confused
| Question | Notified registered supplier making a section 9(3) supply | Registered recipient buying from an unregistered supplier |
|---|---|---|
| Who is the supplier? | A registered person whose class and transaction are covered by the current e-invoice mandate. | An unregistered person on the date the goods or services are received. |
| Who bears reverse-charge tax? | Generally, the recipient under the applicable section 9(3) notification. | The registered recipient when the statutory reverse-charge conditions apply; section 31(3)(f) also covers liability under section 9(4). |
| Who issues the ordinary invoice? | The registered supplier issues its tax invoice. | The registered recipient issues a self-invoice under section 31(3)(f). |
| Who reports an e-invoice to the IRP? | The notified supplier reports the invoice and obtains the IRN and signed QR code. | No IRP e-invoice arises for the receipt from the unregistered supplier, according to the IRP FAQ. |
| What should the recipient receive? | The supplier’s invoice carrying the IRN and signed QR code when e-invoicing applies. | The recipient’s statutory self-invoice, not an IRP-generated e-invoice for the unregistered supplier’s receipt. |
This comparison follows the official reverse-charge answer in the Invoice Registration Portal FAQ and the invoice-issuance rule in the Central Goods and Services Tax Act, 2017.
Case 1: A notified registered supplier makes the reverse-charge supply
The supplier still reports the invoice
If the supplier is registered, falls within the currently notified e-invoice class and makes a transaction covered by the mandate, it must first prepare its normal tax invoice. It then reports that invoice to an IRP. The IRP validates the data, generates an IRN and returns a digitally signed QR code. The supplier gives the resulting invoice to the recipient.
The IRP FAQ answers the reverse-charge question directly: “If the invoice issued by notified person is in respect of supplies made by him but attracting reverse charge under Section 9(3), e-invoicing is applicable.” The wording is important: the supplier is the “notified person,” and the invoice is for a supply made by that supplier. The fact that the recipient pays the tax does not transfer the supplier’s reporting role.
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What the recipient must do
The recipient should record the supplier’s invoice and account for the reverse-charge liability under the applicable GST rules. It should not attempt to generate an IRP e-invoice in place of the supplier. Recipients and transporters cannot generate the supplier’s e-invoice under the IRP mandate guidance.
Illustrative example
A registered service provider that is in the notified e-invoice class supplies a service listed for reverse charge under section 9(3) to another registered business. The service provider creates the invoice, reports it to the IRP and sends the IRN-bearing invoice with the signed QR code. The customer pays the GST under reverse charge. The customer’s payment obligation does not make it the e-invoice reporter.
Case 2: The registered recipient receives a supply from an unregistered supplier
Self-invoice duty under section 31(3)(f)
Section 31(3)(f) of the CGST Act requires a registered person who is liable to pay tax under section 9(3) or section 9(4), and who receives a supply from an unregistered supplier, to issue an invoice for that supply. This is commonly called a self-invoice because the recipient creates the document for the inward supply.
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Why this is not an IRP e-invoice
The IRP FAQ distinguishes this situation from a notified registered supplier’s invoice and states that e-invoicing does not arise for supplies received from an unregistered supplier. The recipient’s self-invoice remains a GST document required by section 31(3)(f), but it is not an invoice reported by an unregistered supplier to the IRP.
Do not describe every reverse-charge purchase as “recipient-generated e-invoicing.” That phrase collapses two different systems: a self-invoice required by the CGST Act and an IRN-bearing e-invoice generated through the IRP.
How to determine whether the supplier is in the e-invoice mandate
Start with notified status and turnover history
The IRP mandate page says applicability is based on aggregate annual turnover in any preceding financial year from financial year 2017–18 onward, along with taxpayer type and the applicable notifications. It records a threshold of ₹5 crore or more effective 1 August 2023, under Notification 10/2023 dated 10 May 2023. Treat ₹5 crore as the stated threshold in that mandate material, not as a complete substitute for checking the current notification and exclusions.
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Check the transaction category
The IRP FAQ identifies business-to-business supplies and exports among covered categories, while listing exclusions that include business-to-consumer supplies, imports, exempt supplies and specified classes of entities. The exact notification and facts control. Check whether the reverse-charge transaction is within the covered document and supply types rather than assuming that reverse charge itself creates or removes e-invoice liability.
Use this decision sequence
- Identify the parties. Record the supplier’s GST registration status on the supply date and the recipient’s registration status.
- Classify the reverse-charge basis. Decide whether the outward supply is a notified section 9(3) supply, or whether the recipient is dealing with an unregistered supplier under the statutory section 9(3) or 9(4) conditions.
- Check the supplier’s mandate status. Review aggregate annual turnover in any preceding financial year from FY 2017–18 onward, taxpayer type and the current exemption list.
- Check the document and supply. Confirm that the transaction is not an excluded B2C, import, exempt or specified-entity case, and verify any current notification applicable to the facts.
- Assign the document duty. For a notified registered supplier, the supplier reports the invoice to the IRP. For the qualifying unregistered-supplier receipt, the registered recipient issues the section 31(3)(f) self-invoice and does not seek an IRP e-invoice for that receipt.
What the ordinary reverse-charge invoice must contain
E-invoicing does not replace the underlying tax-invoice requirements. The supplier must prepare an invoice with the particulars required by the applicable GST rules before reporting it. CBIC’s Tax Invoice, Credit and Debit Notes material, including Rule 46, covers the required fields.
- Supplier name, address and GSTIN.
- Recipient name, address and GSTIN where applicable.
- A consecutive invoice serial number and the invoice date.
- Description and value of the goods or services, with the relevant quantities or service details.
- Taxable value, tax rate and tax amount, along with the applicable tax heads.
- The required reverse-charge indication on the invoice.
- Other particulars required by the GST Rules for the document and transaction.
After IRP reporting, the invoice also carries the IRN and the signed QR code returned by the portal. The IRN and QR code evidence the portal registration; they do not change who is liable to pay reverse-charge tax.
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Supplier reporting workflow when e-invoicing applies
- Create the invoice in the accounting or ERP system. Enter the supplier, recipient, supply, tax and reverse-charge details required by the GST Rules.
- Confirm scope before submission. Check that the supplier is in the notified class and that the transaction is not excluded. Do not rely only on an “enabled” status shown by the portal.
- Transmit the invoice data to an IRP. The supplier or its authorised system sends the prepared invoice data to the portal designated for IRP registration.
- Receive and store the IRN and signed QR code. The IRP returns the registration result. Preserve the returned data with the original invoice and accounting record.
- Issue the registered invoice to the recipient. Send the IRN-bearing invoice so the recipient can record the reverse-charge purchase and meet its own tax and documentation duties.
- Correct errors through the permitted process. If invoice data is wrong or a submission fails, follow the IRP and GST correction or cancellation rules that apply to the document. Do not silently replace an already registered invoice without checking the applicable procedure.
Worked scenarios
Scenario A: Notified supplier, section 9(3) service
A registered supplier that meets the current mandate criteria provides a notified reverse-charge service to a registered customer. The supplier issues the tax invoice, reports it to the IRP and supplies the IRN-bearing document. The customer pays the reverse-charge GST. There is one supplier-reported e-invoice for the outward supply; the customer does not generate a second IRP e-invoice.
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Scenario B: Registered recipient, unregistered supplier
A registered business receives a supply from a supplier that is unregistered on the date of receipt, and the business is liable under the applicable section 9(3) or 9(4) rule. The recipient issues the statutory self-invoice under section 31(3)(f). Because the supplier is unregistered, the IRP FAQ says e-invoicing does not arise for that receipt. The recipient should retain the self-invoice and supporting records required for its GST accounting.
Scenario C: Portal access but no legal mandate
A taxpayer discovers that its GST profile can access an IRP. That technical access does not, by itself, prove that every invoice must be reported. The taxpayer must still apply the turnover, taxpayer-type, transaction-scope and exception tests in the current mandate. If the facts place the taxpayer outside the legal requirement, portal availability alone should not be treated as the deciding rule.
Common mistakes and how to avoid them
- “The customer pays, so the customer must e-invoice.” This confuses tax liability with portal reporting. For a notified registered supplier’s section 9(3) supply, the supplier reports the invoice.
- “Reverse charge means no e-invoice.” The IRP FAQ expressly says e-invoicing applies to an invoice issued by a notified person for that person’s section 9(3) supply.
- “A self-invoice is the same as an IRN invoice.” A recipient’s section 31(3)(f) self-invoice for an unregistered supplier’s receipt is a different statutory document, and the FAQ says IRP e-invoicing does not arise for that receipt.
- “The ₹5 crore number answers every case.” The threshold is part of the mandate history and applies with taxpayer-type, notification and exception tests. Review the current rules for the relevant period.
- “Portal enablement proves liability.” The FAQ warns that enablement is only a technical state and is not conclusive proof of legal applicability.
- “The invoice can omit the reverse-charge indicator.” Rule 46 particulars include a reverse-charge indication where applicable. Check the current GST Rules and ensure the underlying invoice is complete before IRP submission.
Practical compliance checklist
- Confirm the country and legal framework: this rule set is Indian GST.
- Identify whether the supplier is registered on the relevant date.
- For a registered supplier, check aggregate annual turnover in any preceding financial year from FY 2017–18 onward and the current notified class; the IRP mandate page records ₹5 crore or more effective 1 August 2023.
- Classify the reverse-charge provision and verify that the supply is actually covered.
- Check B2B, export, B2C, import, exempt-supply and specified-entity exceptions against the current notification.
- If the notified registered supplier is making the section 9(3) supply, have that supplier report the invoice and obtain the IRN and signed QR code.
- If the registered recipient receives the relevant supply from an unregistered supplier, issue the section 31(3)(f) self-invoice; do not seek an IRP e-invoice for that receipt.
- Ensure the invoice contains Rule 46 particulars, including the reverse-charge indicator where required.
- Keep the invoice, IRN, signed QR code, self-invoice where applicable and supporting registration records together.
Official references
For the mandate threshold, supplier-only reporting rule and exemption framework, consult the Invoice Registration Portal’s GST e-invoice mandate guidance.
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For the specific reverse-charge e-invoice answer, portal-enablement caution and unregistered-supplier treatment, consult the IRP FAQ powered by IRIS IRP.
For the recipient’s self-invoice duty under section 31(3)(f), read the CBIC Central Goods and Services Tax Act, 2017. For invoice particulars, use CBIC’s Tax Invoice, Credit and Debit Notes rules. CBIC also provides a Sectoral FAQ on Reverse Charge Mechanism for general reverse-charge questions.
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