Many headlines say that e-invoicing is now mandatory for reverse charge (RCM) invoices. The change is real, but it is narrower than that. A notification dated 26 October 2026 extends e-invoicing to the self-invoices that a business raises for certain reverse charge purchases, starting from 1 January 2027. This note explains who is affected, what is covered and what to do before the date.

Key points at a glance

Background: how e-invoicing works today

Under rule 48(4) of the CGST Rules, a registered person whose turnover is above the notified limit must prepare invoices for supplies to registered persons (B2B) and for exports by uploading the invoice details to the Invoice Registration Portal and getting an Invoice Reference Number (IRN) and a QR code. Notification No. 13/2020-Central Tax lists the categories that are exempt. Rule 48(5) says an invoice issued in any other manner by a person to whom rule 48(4) applies is not treated as an invoice.

The consequences of not following the e-invoicing procedure are already well known. The recipient is not eligible to claim input tax credit (ITC) if an e-invoice was required but not generated by the supplier, and the supplier faces penalty provisions under section 122. The tax invoice must also state whether tax is payable on reverse charge.

What changes from 1 January 2027

Until now, e-invoicing mainly covered a business’s outward supplies. When you buy from an unregistered supplier and pay GST under reverse charge, you issue the invoice to yourself (a self-invoice). When you import a service and pay GST under reverse charge, you also account for it through a self-invoice. From 1 January 2027, if you are an e-invoicing taxpayer, these two kinds of self-invoice must be reported on the Invoice Registration Portal so that an IRN is generated.

GSTN has also introduced a self-invoice facility on the portal, with separate document categories for domestic RCM purchases from unregistered persons and for import of services, so you can generate the IRN for these documents.

Who is affected and who is not

Why it matters: ITC and compliance

Reports on the notification say a self-invoice that is not reported on the portal may not be treated as a valid invoice, which could put the ITC on that reverse charge purchase at risk. The reverse charge tax itself remains payable whether or not an IRN is generated. Because exact consequences depend on the notification wording and later clarifications, treat the safe approach as generating the IRN on time for every covered self-invoice.

What to do before 1 January 2027

How Brightfin can help

If you are not sure whether you fall under e-invoicing or how to handle reverse charge self-invoices, we can review your purchases and set up a simple process. See our GST return filing and GST advisory services, or message us on WhatsApp.

Sources

This article is for general information only and is not legal or tax advice. Rules, thresholds and effective dates can change, so check the current notification or speak to a professional before you act.

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