The GST e-invoicing threshold has not been cut again. It has been ₹5 crore since 1 August 2023. What is changing is scope. E-invoicing is being extended to certain inward supplies, namely specified domestic supplies from unregistered persons and imports of services, where the registered recipient pays GST under reverse charge. GSTN has introduced two new supply types, RCMDOM and RCMIMP, for these recipient-generated self-invoices. The change is reported to take effect from 1 January 2027.
Key Takeaways
- The ₹5 crore threshold is not new in 2026. It has applied since 1 August 2023.
- The 2026 change adds recipient-side invoices for specified RCM transactions to existing outward-supply e-invoicing.
- RCMDOM covers domestic RCM supplies from unregistered persons. RCMIMP covers imports of services.
- The sandbox is live on all six authorised IRPs, but sandbox availability does not mean mandatory production reporting has started.
- The Rule 47A self-invoice period and the IRP 30-day reporting restriction are two separate requirements.
What Is the GST E-Invoice ₹5 Crore Rule?
E-invoicing applies to the notified class of registered persons whose aggregate turnover exceeded ₹5 crore in any preceding financial year from 2017-18 onward, subject to the prescribed exclusions. For these taxpayers, specified documents must be reported to the Invoice Registration Portal (IRP), which generates an Invoice Reference Number (IRN).
"Exceeding ₹5 crore" or "₹5 crore and above"?
The Council recommendation and the GSTN advisory use the phrase "₹5 crore and above". However, the official description of Notification No. 10/2023-Central Tax speaks of aggregate turnover exceeding ₹5 crore, and the October 2026 amendment is reported to leave that wording untouched. A taxpayer whose turnover is exactly ₹5 crore should therefore rely on the operative notification, not headline shorthand.
When Did the ₹5 Crore Threshold Become Effective?
| Event | Detail |
| Earlier threshold | ₹10 crore |
| Reduction to ₹5 crore | With effect from 1 August 2023 |
| 30-day IRP reporting restriction | From 1 April 2025, for taxpayers with AATO of ₹10 crore and above |
| RCM inward supply scope (reported) | From 1 January 2027 |
How Is Turnover Tested: PAN-Wise or GSTIN-Wise?
Eligibility looks at PAN-based aggregate turnover. A business must consider turnover in any preceding financial year from 2017-18 onward, after applying the notified exclusions. Because the test runs across years, a business that crossed the limit in an earlier year may remain covered even if its current-year turnover is lower.
What Changed After the 57th GST Council Meeting?
| Update | What readers need to know |
| Council recommendation (8 Oct 2026) | Extend e-invoicing to specified domestic inward supplies from unregistered persons under RCM, and to imports of services. |
| GSTN advisory (16 Oct 2026) | Introduced the RCMDOM and RCMIMP supply types and confirmed sandbox availability on all six authorised IRPs. |
| Notification No. 04/2026-Central Tax (reported) | Expands covered transactions from 1 January 2027. Verify the Gazette text. |
| Notification No. 05/2026-Central Tax (reported) | Updates the Form GST INV-01 schema reference from Version 1.1 to Version 1.2 from 1 January 2027. Also needs primary-document verification. |
RCMDOM and RCMIMP Explained
Under reverse charge, the recipient, not the supplier, pays the GST. For specified supplies from unregistered suppliers, the recipient already has a self-invoicing obligation. The new development connects those recipient-generated invoices to the IRP so that an IRN can be generated for them.
| Code | Full Form | Intended Use |
| RCMDOM | Reverse Charge Mechanism on Domestic | Recipient-generated self-invoices for specified domestic supplies from unregistered persons, where the registered recipient pays tax under RCM. |
| RCMIMP | Reverse Charge Mechanism on Import of Services | Recipient-generated self-invoices for services imported from suppliers outside India, where the registered recipient pays tax under RCM. |
Which Unregistered-Supplier Purchases Are Covered?
Only domestic supplies from unregistered persons on which the registered recipient is legally liable to pay GST under reverse charge. Review your purchase ledger to separate these from ordinary purchases from unregistered suppliers, which do not all attract RCM.
How Are Imports of Services Affected?
Services received from a supplier outside India, where the recipient pays tax under RCM, fall under RCMIMP. The category covers imports of services only. Imports of goods are not part of it.
What Does This Change Not Mean?
- It does not bring every purchase from an unregistered supplier under RCM.
- It does not require every business to start issuing recipient-side e-invoices.
- It does not extend the import of services category to imports of goods.
- Sandbox availability does not, by itself, mean that mandatory production reporting has begun.
Also Read - GST Return Filing Changes From April 2027: New Rules for ITC and Tax Liability
The Reported 1 January 2027 Effective Date
Notification No. 04/2026-Central Tax is reported to expand the covered transactions from 1 January 2027, and Notification No. 05/2026-Central Tax is reported to move the INV-01 schema to Version 1.2 from the same date. Both are consistently reported in secondary sources but should be checked against the Gazette before they are treated as final. Businesses that rely on ERP or GSP software should start schema and workflow testing well before the date.
Two Different 30-Day Requirements: Do Not Mix Them Up
| Requirement | Starting point | Key distinction |
| Self-invoice issuance under Rule 47A | Receipt of goods or services | The prescribed self-invoice must be issued within 30 days for covered transactions. |
| IRP reporting restriction | Invoice or document date | Applies to taxpayers with AATO of ₹10 crore and above, and blocks reporting beyond the permitted window. |
These two periods arise from different provisions and serve different purposes. They are not a single "30-day e-invoicing rule for all ₹5 crore businesses", and they do not automatically combine into a 60-day compliance window. Invoice issuance, IRN generation and tax payment must be tracked separately. How the reporting validation will apply to the new RCM supply types should be confirmed once final operational guidance is released.
Exclusions and Operational Points to Check
- The notified exclusions from the e-invoicing class, which affect whether you are covered at all.
- Final IRP validation rules for RCMDOM and RCMIMP documents.
- Return-mapping guidance, including how these self-invoices will flow into GSTR-1 and GSTR-3B reporting.
- Your ERP or GSP provider's readiness for the new supply types and the Version 1.2 schema.
Also Read - GST New Rules: Major Relief on Notices, Penalties and Appeals
FAQs
Has the GST e-invoicing threshold been reduced again in 2026?
No. The threshold has been ₹5 crore since 1 August 2023. The 2026 development concerns the scope of transactions covered, not a new turnover limit.
What is RCMDOM in GST e-invoicing?
RCMDOM stands for Reverse Charge Mechanism on Domestic supplies. It is the supply type for recipient-generated self-invoices on specified domestic supplies from unregistered persons, where the registered recipient pays GST under reverse charge.
What is RCMIMP in GST e-invoicing?
RCMIMP stands for Reverse Charge Mechanism on Import of Services. It is used for recipient-generated self-invoices on imported services where the registered recipient pays GST under reverse charge.
Is e-invoicing mandatory for all reverse charge purchases?
No. It applies only to the specified categories and only to businesses within the notified e-invoicing class. Not every purchase from an unregistered supplier attracts reverse charge.
Are imports of goods covered by the new e-invoicing scope?
No. The new category covers imports of services only.
Is the ₹5 crore limit tested PAN-wise or GSTIN-wise?
It is tested on a PAN basis, considering aggregate turnover in any preceding financial year from 2017-18 onward, subject to the notified exclusions.
Does the 30-day IRP reporting restriction apply to all businesses above ₹5 crore?
No. From 1 April 2025 it applies to taxpayers with aggregate annual turnover of ₹10 crore and above. It is separate from the ₹5 crore applicability threshold.
When will e-invoicing for RCM inward supplies begin?
It is reported to begin from 1 January 2027. The sandbox is already available on all six authorised IRPs, but businesses should confirm the date against the Gazette text.
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