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E-Invoice Applicability Checker.

The ₹5 crore test runs on ANY financial year since 2017-18 — not just the latest one. Check the threshold, the entity exemptions, your effective start date, and the 30-day IRN reporting window.

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The #1 misconception

The test is any financial year from 2017-18 onwards — not the current year. If your turnover crossed ₹5 crore in even one past FY and later fell, e-invoicing still applies and never switches off. Answer the turnover question below with your highest-ever AATO.

Your profile

Highest aggregate annual turnover (AATO, PAN-level) in ANY FY since 2017-18

Entity-category exemptions — do any apply?

SEZ unit?

Special Economic Zone UNIT (developers are NOT exempt)

Insurer / bank / financial institution?

Including NBFCs

Goods Transport Agency?

Transporting goods by road, issuing consignment notes

Passenger transport service?

Supplying passenger transportation services

Multiplex cinema admission?

Admission to exhibition of films in multiplex screens

Government department / local authority?

Departments and local authorities registered under GST

Where this fits

In an audit, e-invoice gaps surface in reconciliation.

Missed IRNs show up as invoices that exist in books but not on the IRP — and as buyers' ITC disputes. CORAA's GST checks compare books, e-invoice data and returns so the gap is caught before the notice arrives.

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How e-invoice applicability is determined

E-invoicing under Rule 48(4) of the CGST Rules requires notified taxpayers to report B2B invoices, exports and credit/debit notes to an Invoice Registration Portal (IRP) and obtain an Invoice Reference Number (IRN) with a signed QR code. Without an IRN, the document is not a valid tax invoice for a notified person (Rule 48(5)).

The threshold test: aggregate annual turnover exceeding ₹5 crore in ANY financial year from 2017-18 onwards. This is the single most misunderstood part of the rule — the test is not the current year's turnover. The mandate phased in from ₹500 crore (1 October 2020) down through ₹100 crore (1 January 2021), ₹50 crore (1 April 2021), ₹20 crore (1 April 2022), ₹10 crore (1 October 2022), and finally ₹5 crore from 1 August 2023 (Notification 10/2023-Central Tax, dated 10 May 2023, amending Notification 13/2020-Central Tax). Once your highest-ever AATO crosses the line, the obligation begins and never lapses even if turnover later falls.

Certain entity categories are excluded regardless of turnover: SEZ units (Notification 61/2020-CT — but not SEZ developers), insurers, banking companies and financial institutions including NBFCs, Goods Transport Agencies, suppliers of passenger transportation services, and multiplex cinema admission (all per Notification 13/2020-CT), plus government departments and local authorities (Notification 23/2021-CT).

Scope: e-invoicing covers B2B taxable supplies, supplies to SEZ (with or without payment), exports and deemed exports, and credit/debit notes against them. B2C invoices are outside e-invoicing (they carry a separate dynamic-QR requirement for AATO > ₹500 crore). Separately, taxpayers with AATO ≥ ₹10 crore must report documents to the IRP within 30 days of the document date from 1 April 2025 — the portal hard-rejects older documents.

Worked example — the any-year trap

A trader had turnover of ₹6.2 crore in FY 2018-19. Business shrank; turnover has been ₹3–4 crore every year since. In FY 2025-26 the accountant assumes e-invoicing does not apply because current turnover is under ₹5 crore.

Inputs

AATO FY 2018-19₹6.2 crore (highest ever)

AATO FY 2024-25₹3.8 crore

Entity categoryRegular trader — no exemption

Output

Threshold test₹6.2 Cr > ₹5 Cr in a past FY — test met

VerdictE-invoicing MANDATORY from 1 August 2023

Consequence of skippingInvoices without IRN are not valid tax invoices; buyer ITC at risk; penalty exposure under Sec 122

The ₹5 crore test looks at every FY from 2017-18 onwards. Crossing it once — even seven years ago — permanently brings the taxpayer into e-invoicing from the applicable phase date (here 1 August 2023, when the ₹5 crore phase took effect). Current-year turnover is irrelevant.

Common mistakes

Testing only the current year's turnover

The Rule 48(4) notification applies to taxpayers whose AATO exceeded the limit in ANY FY from 2017-18 onwards. A business that crossed ₹5 crore once in 2018-19 and shrank since is still covered — permanently. This is the most common e-invoice compliance failure.

Treating SEZ developers as exempt like SEZ units

Notification 61/2020-CT excludes SEZ UNITS only. SEZ developers with AATO over ₹5 crore must generate IRNs. Also, supplies TO an SEZ by a regular taxpayer are squarely within e-invoicing scope — the exemption belongs to the SEZ unit as supplier, not to its vendors.

Computing AATO GSTIN-wise

AATO is aggregate turnover on the PAN — all GSTINs, all states, including exempt supplies and exports (Section 2(6)). Two branches of ₹3 crore each = ₹6 crore AATO. One registration cannot stay out of e-invoicing while the other is in.

Missing the 30-day IRN window at ₹10 crore AATO

From 1 April 2025 the IRPs reject documents older than 30 days for taxpayers with AATO ≥ ₹10 crore (earlier ≥ ₹100 crore, per the 13 September 2023 advisory). A backlog of unreported invoices found in month 2 cannot be regularised — the IRN simply cannot be generated, leaving invalid invoices and blocked buyer ITC.

Assuming B2C or RCM self-invoices need IRNs

B2C supplies are outside e-invoicing (dynamic QR is a separate requirement for > ₹500 crore AATO). Similarly, self-invoices raised by a recipient for RCM inward supplies from unregistered persons are not reported to the IRP. Over-generating is wasted effort; the scope is B2B, SEZ, exports and their credit/debit notes.

Frequently asked questions

What is the e-invoice turnover limit now?+

₹5 crore aggregate annual turnover, effective 1 August 2023 (Notification 10/2023-Central Tax dated 10 May 2023). The test is whether AATO exceeded ₹5 crore in ANY financial year from 2017-18 onwards — not just the latest year.

Is e-invoicing applicable if my turnover crossed ₹5 crore in an earlier year but is lower now?+

Yes. Once AATO exceeds ₹5 crore in any FY from 2017-18 onwards, e-invoicing applies from the relevant effective date and never switches off — even if turnover later falls below the limit.

Who is exempt from e-invoicing regardless of turnover?+

SEZ units (not developers), insurers, banking companies and financial institutions including NBFCs, Goods Transport Agencies, passenger transport service suppliers, multiplex film admission services (Notification 13/2020-CT), and government departments and local authorities (Notification 23/2021-CT).

Does e-invoicing apply to B2C invoices?+

No. E-invoicing covers B2B supplies, supplies to SEZ, exports, deemed exports, and credit/debit notes against them. B2C invoices do not get IRNs — but taxpayers with AATO above ₹500 crore must print a dynamic QR code on B2C invoices under a separate mandate.

What is the time limit for generating an IRN?+

For taxpayers with AATO ≥ ₹10 crore, documents must be reported to the IRP within 30 days of the document date from 1 April 2025 — the portal rejects anything older. Below ₹10 crore AATO there is currently no hard portal validation, but the invoice is not valid without an IRN, so reporting should be immediate in practice.

What happens if I don't generate an e-invoice when required?+

The document is not a valid tax invoice (Rule 48(5)). Consequences: penalty under Section 122 (₹10,000 or the tax involved per invoice, whichever is higher, for invoicing failures), the buyer's ITC is at risk since a valid invoice is a Section 16 condition, and e-way bill and GSTR-1 data flows break.

Do exports need e-invoices?+

Yes — exports (with or without payment of IGST) and supplies to SEZ units/developers by a notified taxpayer require IRNs. The e-invoice schema has specific fields for export invoices, and IRN data flows into GSTR-1 and refund processing.

Is e-invoicing required for reverse-charge (RCM) supplies?+

If a notified SUPPLIER issues a B2B invoice on which the recipient pays tax under RCM, that invoice needs an IRN. But self-invoices raised by a recipient for supplies from unregistered persons are not reported to the IRP.

Authoritative sources

Notification 10/2023-Central Tax (₹5 crore e-invoice threshold) — Notification 10/2023-Central Tax dated 10 May 2023, amending Notification 13/2020-Central Tax (21 March 2020) under Rule 48(4) CGST Rules — threshold ₹5 crore w.e.f. 1 August 2023. Exemptions per Notifications 13/2020, 61/2020 and 23/2021-Central Tax. 30-day IRP reporting window per GSTN advisory dated 5 November 2024, effective 1 April 2025.

Always confirm against the latest version of the source. Regulations evolve and amendments are common.

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Last reviewed: 2026-07-29 · For informational purposes only — not professional advice.