Subject: Clarification on Applicability of E-Invoicing and 30-Day Reporting Requirement under GST
This query is : Resolved
28 August 2025
Dear Expert,
I seek your guidance regarding the applicability of e-invoicing and the 30-day reporting requirement under GST based on the following facts:
My aggregate turnover in FY 2023–24 was below 10 crore.
During FY 2024–25, my aggregate turnover exceeded 10 crore only in March 2025.
I did not generate e-invoices for B2B transactions issued in April and May 2024, these e-invoices were generated on 10th August 2025.
The time limit 30-day e-invoicing reporting rule was notified as effective from 1st April 2025.
In this context, I request your guidance on the following:
1. Does the e-invoicing mandate, along with the 30-day reporting rule, apply retrospectively to invoices issued in April and May 2024, even though my turnover was below 10 crore at that time and only crossed the threshold at the end of FY 2024–25?
2. Can I be held liable for non-compliance or delayed compliance in generating e-invoices for the above-mentioned period, considering that the mandate became applicable only after my turnover exceeded the prescribed limit at financial year-end?
3. If e-invoicing and the 30-day limit are applicable in this scenario, what specific penalties or consequences might arise due to the delay in e-invoice generation for April and May 2024?
The GST portal continues to allow generation of IRNs for April–May 2024 invoices in August 2025.
Thank you for your valuable guidance.
I seek your guidance regarding the applicability of e-invoicing and the 30-day reporting requirement under GST based on the following facts:
My aggregate turnover in FY 2023–24 was below 10 crore.
During FY 2024–25, my aggregate turnover exceeded 10 crore only in March 2025.
I did not generate e-invoices for B2B transactions issued in April and May 2024, these e-invoices were generated on 10th August 2025.
The time limit 30-day e-invoicing reporting rule was notified as effective from 1st April 2025.
In this context, I request your guidance on the following:
1. Does the e-invoicing mandate, along with the 30-day reporting rule, apply retrospectively to invoices issued in April and May 2024, even though my turnover was below 10 crore at that time and only crossed the threshold at the end of FY 2024–25?
2. Can I be held liable for non-compliance or delayed compliance in generating e-invoices for the above-mentioned period, considering that the mandate became applicable only after my turnover exceeded the prescribed limit at financial year-end?
3. If e-invoicing and the 30-day limit are applicable in this scenario, what specific penalties or consequences might arise due to the delay in e-invoice generation for April and May 2024?
The GST portal continues to allow generation of IRNs for April–May 2024 invoices in August 2025.
Thank you for your valuable guidance.
16 September 2025
Based on the facts provided, the e-invoicing mandate and the 30-day reporting rule do not apply retrospectively to invoices issued before your turnover exceeded the threshold, and penalties are not applicable for April–May 2024 invoices issued when your turnover had not yet crossed ₹10 crore.
16 September 2025
Applicability of E-Invoicing When Turnover Crosses Limit
The e-invoicing requirement under GST becomes applicable only from the beginning of the financial year following the year in which the aggregate turnover exceeds the notified threshold (for example, ₹10 crore).
Since your turnover exceeded ₹10 crore only in March 2025 (i.e., late in FY 2024–25), the e-invoicing mandate would apply from FY 2025–26 (i.e., from 1 April 2025) and not to invoices issued in FY 2024–25.
The 30-day e-invoice reporting rule, effective from 1 April 2025, also applies prospectively and not to prior-period invoices.
The e-invoicing requirement under GST becomes applicable only from the beginning of the financial year following the year in which the aggregate turnover exceeds the notified threshold (for example, ₹10 crore).
Since your turnover exceeded ₹10 crore only in March 2025 (i.e., late in FY 2024–25), the e-invoicing mandate would apply from FY 2025–26 (i.e., from 1 April 2025) and not to invoices issued in FY 2024–25.
The 30-day e-invoice reporting rule, effective from 1 April 2025, also applies prospectively and not to prior-period invoices.
16 September 2025
Liability for Non-compliance or Delayed Compliance
For B2B invoices issued in April and May 2024 (when your turnover was still below ₹10 crore), neither e-invoice generation nor the 30-day rule applied, and late submission in August 2025 is not non-compliance for those invoices.
The GST portal allowing IRN generation for these invoices is aligned with the current practice and confirms the non-applicability of e-invoicing rules for the period concerned.
Liability for non-compliance arises only if e-invoicing was applicable at the time of invoice issue (i.e., after the turnover threshold was crossed and from the next financial year onward).
For B2B invoices issued in April and May 2024 (when your turnover was still below ₹10 crore), neither e-invoice generation nor the 30-day rule applied, and late submission in August 2025 is not non-compliance for those invoices.
The GST portal allowing IRN generation for these invoices is aligned with the current practice and confirms the non-applicability of e-invoicing rules for the period concerned.
Liability for non-compliance arises only if e-invoicing was applicable at the time of invoice issue (i.e., after the turnover threshold was crossed and from the next financial year onward).
16 September 2025
Penalties and Consequences
If e-invoicing and the 30-day reporting rule had applied and were not followed, GST law prescribes a penalty of 100% of tax due or ₹10,000 per invoice (whichever is higher), possible non-allowance of input tax credit, and invoice rejection by the IRP.
In your scenario, these consequences do not arise for April–May 2024 invoices because the mandate was not in force for your entity at that time.
If e-invoicing and the 30-day reporting rule had applied and were not followed, GST law prescribes a penalty of 100% of tax due or ₹10,000 per invoice (whichever is higher), possible non-allowance of input tax credit, and invoice rejection by the IRP.
In your scenario, these consequences do not arise for April–May 2024 invoices because the mandate was not in force for your entity at that time.
16 September 2025
No retrospective liability: The e-invoicing mandate and 30-day rule do not apply to B2B invoices for April–May 2024 since your turnover threshold was not crossed in the preceding financial year and only crossed late in FY 2024–25.
Mandate triggers from next FY: E-invoicing and the 30-day limit are applicable from the next financial year (2025–26) after the year in which the threshold is crossed, i.e., from 1 April 2025 onward in your case.
Penalties aren’t applicable for FY 2024–25 invoices: There is no exposure to GST penalties or other adverse consequences for delay in e-invoice generation for April–May 2024.
For full compliance, ensure all B2B invoices from 1 April 2025 onward are e-invoiced within 30 days of issuance. For prior periods, no historical penalties or retrospective compliance are required based on your facts.
Mandate triggers from next FY: E-invoicing and the 30-day limit are applicable from the next financial year (2025–26) after the year in which the threshold is crossed, i.e., from 1 April 2025 onward in your case.
Penalties aren’t applicable for FY 2024–25 invoices: There is no exposure to GST penalties or other adverse consequences for delay in e-invoice generation for April–May 2024.
For full compliance, ensure all B2B invoices from 1 April 2025 onward are e-invoiced within 30 days of issuance. For prior periods, no historical penalties or retrospective compliance are required based on your facts.
21 September 2025
Good luck....
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