The Goods and Services Tax Network (GSTN) has announced system enhancements to enable e-invoicing of recipient-generated self-invoices for specified domestic supplies received from unregistered persons and imports of services covered by the Reverse Charge Mechanism (RCM).

GSTN said two new supply type codes—RCMDOM and RCMIMP—are being introduced to facilitate reporting of these transactions through authorised Invoice Registration Portals (IRPs).

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The development follows the recommendation of the GST Council at its 57th meeting to extend e-invoicing to these categories of self-invoices for taxpayers having an aggregate annual turnover of ₹5 crore and above.

The functionality is currently available for sandbox testing and integration. The advisory does not announce a production rollout date or an effective date for mandatory reporting. Its scope and commencement will depend on the applicable statutory provisions and government notifications.

Two New Supply Types For RCM Self-Invoices

The proposed enhancement introduces separate codes for domestic RCM transactions involving unregistered suppliers and imports of services from overseas suppliers.

The distinction will allow eligible taxpayers to identify the relevant category of RCM transaction while reporting a self-invoice for generation of an Invoice Reference Number (IRN).

For domestic transactions, the advisory specifically refers to supplies from unregistered persons that attract reverse charge. It does not state that every purchase from an unregistered supplier will become subject to RCM or e-invoicing.

Applicability Subject To Government Notifications

According to the advisory, the new functionality is intended for registered taxpayers having an Aggregate Annual Turnover (AATO) of ₹5 crore and above, subject to the relevant statutory provisions and notifications to be issued by the government.

GSTN has clarified that the scope, applicability and effective date of the requirement will be governed by GST law and the applicable notifications.

The announcement therefore provides an opportunity for taxpayers and technology providers to prepare their systems. The availability of the facility in a testing environment should not be treated as commencement of the reporting obligation.

Recipients To Report Self-Invoices Through Authorised IRPs

Under the existing B2B e-invoice framework, invoices are ordinarily reported by registered suppliers. The proposed enhancement extends the reporting facility to eligible and active registered recipients issuing self-invoices for the specified RCM transactions.

While reporting such invoices through an authorised IRP, taxpayers will need to select the appropriate supply type—RCMDOM for the covered domestic transactions or RCMIMP for imports of services.

An IRN will be generated after successful submission and validation of the prescribed invoice particulars, in accordance with the applicable e-invoice specifications.

The change concerns the reporting of recipient-generated self-invoices. The underlying liability to pay tax under reverse charge will continue to depend on the applicable provisions of GST law.

Sandbox Facility Available Across All Six IRPs

GSTN said the system enhancements incorporating RCMDOM and RCMIMP have been implemented in the sandbox environments of all six authorised IRPs.

Taxpayers, GST Suvidha Providers (GSPs), Application Service Providers (ASPs), Enterprise Resource Planning (ERP) providers and other integration partners can use these environments to test the functionality and prepare their systems.

The advisory also identifies the NIC e-Invoice API Developer Portal, available at https://einv-apisandbox.nic.in/, for development and testing activities.

Uniform Validations Across Invoice Registration Portals

The implementation requirements, business validations and validation codes for RCMDOM and RCMIMP will be uniform across all six IRPs.

These requirements will follow the technical specifications and release note issued by NIC IRP-1. Uniform validation is intended to provide a consistent reporting framework across the authorised portals.

NIC IRP-1 will issue a detailed release note explaining the technical specifications, business validations, validation codes and other operational requirements. Taxpayers and integration partners have been advised to refer to that document for implementation details.

GSTN To Organise Webinar On Implementation

GSTN, along with the IRPs, will organise a webinar to explain the new functionality and address implementation aspects. The schedule and participation details will be communicated separately.

The advisory asks taxpayers and technology intermediaries to inform their wider ecosystem partners about the proposed changes and undertake the necessary system development, integration and testing.

For affected businesses, preparatory work will involve ensuring that accounting and invoicing systems can identify the two categories of self-invoices and report them using the appropriate supply type, once the detailed specifications and applicable requirements are finalised.

Production Rollout Date Yet To Be Announced

GSTN has expressly stated that the date of production rollout and commencement of the associated reporting requirements will be communicated in due course.

For now, the announcement marks the availability of the technical facility for sandbox testing. Taxpayers should monitor the forthcoming notifications, NIC release note and production rollout announcement to determine when and how the requirement applies to their transactions.

Further updates will be published on the official e-invoice portal at https://einvoice.gst.gov.in.

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