Background:
Under Rule 48(4) of the CGST Rules, 2017, a notified class of registered persons is required to generate e-invoices, i.e., report specified documents on the Invoice Registration Portal (IRP) and obtain an Invoice Reference Number (IRN). The class of persons was notified vide Notification No. 13/2020-Central Tax dated 21.03.2020, and the threshold has progressively been reduced; since 01.08.2023 (Notification No. 10/2023-Central Tax), e-invoicing applies to registered persons whose aggregate turnover in any preceding financial year from 2017-18 onwards exceeds ₹5 crore.
However, the scope of e-invoicing was confined to supplies of goods or services made to a registered person (B2B) and supplies for exports. Documents issued by the recipient itself – i.e., the self-invoice required under Section 31(3)(f) of the CGST Act for inward supplies from unregistered persons on which tax is payable under reverse charge, and the self-invoice for import of services – remained outside the e-invoicing framework. As a result, reverse charge liability and the corresponding input tax credit were reported in returns without any system-level validation, leading to mismatches, difficulty in verification by the Department and avoidable notices on RCM liability.
The 57th GST Council, in its meeting held on 08.10.2026, recommended (para 18(4) of the Press Release) extending e-invoicing to domestic supplies received from an unregistered person where the tax is payable under reverse charge mechanism, as well as to the import of services, for taxpayers having aggregate annual turnover of ₹5 crore and above. The intent is to bring the RCM leg of transactions on the IRP so that liability and ITC on such supplies can be auto-populated and reconciled.
What the Notification provides:
Now, the CBIC vide Notification No. 04/2026-Central Tax dated 26.10.2026 (G.S.R. 918(E)), issued under Rule 48(4) of the CGST Rules on the recommendations of the GST Council, has amended Notification No. 13/2020-Central Tax dated 21.03.2020. In the first paragraph of the said notification, the words “in respect of supply of goods or services or both to a registered person or for exports” have been substituted, so that e-invoicing shall now apply in respect of:
- supply of goods or services or both to a registered person (B2B supplies);
- supply of goods or services or both for exports;
- supply of goods or services or both received from an unregistered person where the tax is payable on reverse charge basis by the recipient of such goods or services or both; and
- import of services.
Consequently, every registered person covered by Notification No. 13/2020-Central Tax (aggregate turnover exceeding ₹5 crore in any preceding financial year from 2017-18 onwards) will be required to generate an IRN for the self-invoice issued under Section 31(3)(f) of the CGST Act in respect of (a) inward supplies received from unregistered suppliers liable to RCM (for example, legal services from advocates, renting of commercial property by unregistered landlords, security services, sponsorship, and the newly notified categories of waste and scrap), and (b) import of services, including services received from overseas group entities.
In tandem, Notification No. 05/2026-Central Tax dated 26.10.2026 has amended FORM GST INV-01 (the e-invoice schema) to Version 1.2 and has introduced two new supply-type codes – “RCMDOM” (domestic supply from unregistered person under RCM) and “RCMIMP” (import of services) – with effect from the same date.
Effective date:
The amendment comes into force on 1st January, 2027. Self-invoices for RCM inward supplies and import of services pertaining to the period from 01.01.2027 onwards will have to be reported on the IRP by the notified class of taxpayers. Businesses should map their RCM vendor masters, update ERP/accounting systems for the new document types and schema fields, and align the self-invoice generation timelines (Rule 47A requires the self-invoice to be issued within 30 days of receipt of the supply) with IRN generation.
The Notification can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2026/10/CBIC-NN-04-of-2026–-Central-Tax.pdf
