Clarification on Voluntary E-Invoicing

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Our company’s turnover is below ₹5 crore, so we are not covered under mandatory e-invoicing.

However, one of our customers requires IRN-based invoices, so we are planning voluntary enabling of our GSTIN for e-invoicing on the Invoice Registration Portal.

Kindly clarify:

  1. After voluntary enabling of e-invoicing, are we required to generate IRN for all B2B invoices?

  2. Or can we generate IRN only for selected invoices/customers and issue normal GST invoices for others?

Kindly confirm the correct position.

Regards,

Replies (5)
Quick Summary
After voluntary e-invoicing enablement, IRN should ideally be generated for all B2B invoices. Selective IRN use may risk invoice validity and ITC issues for customers, though GSTR-1 reporting still reflects in 2A/2B.

After voluntary enablement, you should generate IRNs for all B2B invoices to ensure they remain legally valid; selective generation is not recommended as it may lead to ITC denials for your other customers.

 

Thanks for your reply sir,

Sir for other small customers i'll file GSTR1 manually. Won't these invoices reflect in their GSTR2A?

 

Under Rule 48(4) of CGST Rules, the requirement is framed GSTIN-level, not invoice-level. Once your GSTIN is enabled, you are effectively behaving like a “notified person”. A B2B invoice without IRN (when your system is enabled and capable) can be questioned as non-compliant with Rule 48(4) intent. If you opt in voluntarily, be ready to fully transition your B2B invoicing to IRN-based e-invoicing. If your requirement is only for one customer, consider whether you can handle that via a workaround (like a separate GSTIN, if feasible) rather than partial adoption.

Suggested response for Thread 2 (voluntary e-invoicing): Yes, any GST-registered taxpayer can voluntarily generate e-invoices even if their turnover is below Rs.5 crore. The benefit is practical: your buyers receive your invoice data in their GSTR-2B automatically, making it easier for them to reconcile and claim ITC without chasing you for reconciliation.
Some large corporate buyers now prefer suppliers who provide e-invoices for this reason. You can register on the IRP (einvoice1.gst.gov.in) and start generating IRNs voluntarily at any time.

Once you voluntarily enable e-invoicing on the IRP, the portal treats all your B2B invoices as IRP-covered, and customers may face ITC denial if they receive invoices without a valid IRN. Selective IRN generation after voluntary enablement is not recommended for this reason. There is no self-service way to disable voluntary enrolment on the portal currently. If you are below the Rs 5 crore AATO threshold and do not have a specific customer requirement for IRN-stamped invoices, the safest approach is to not enable e-invoicing voluntarily. Details on who must comply and what happens at different turnover levels in this [e-invoicing guide for businesses crossing Rs 5 crore](https://taxgarden.in/blog/e-invoice-mandatory-5-crore-businesses-2026).

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