Updated • Nov 2025

E-Invoicing — Key Rules, Limits & Compliance (2025 Update)

Clear guidance on applicability, IRN generation, compliance and mistakes to avoid.

By EasyPeasyTax •

What is e-Invoicing?

E-Invoicing is authentication of B2B, B2G and export invoices through the IRP, returning an IRN and QR code.

Applicability

Threshold: ₹5 crore PAN-based aggregate turnover.

  • Once applicable, remains applicable.
  • Covers B2B, B2G, exports.

Who is Exempt?

  • Banks, NBFCs, Insurers
  • GTA
  • Passenger transport
  • Cinema exhibitors
  • Notified Govt entities
  • SEZ units

Documents Covered

  • B2B invoices
  • B2G invoices
  • Export invoices
  • Taxable credit/debit notes

IRN Process

  1. Generate invoice in ERP.
  2. Upload JSON to IRP.
  3. IRP validates and returns IRN + QR.
  4. Share authenticated invoice with buyer.

QR Code Requirements

QR includes GSTINs, invoice number/date, value, IRN hash etc.

Penalties

  • Invoice without IRN may be invalid.
  • Penalties up to ₹10,000 per invoice.

Common Mistakes

  • Issuing invoice before IRN.
  • Mismatch in ERP vs JSON.
  • Missing QR code print.

Checklist

  • Verify PAN turnover.
  • Ensure no exemption applies.
  • Upgrade ERP for IRN API.
  • Train staff.

Does e-Invoicing Apply if a Business Has Only Exempt Turnover?

No. E-Invoicing does not apply if a business makes fully exempt supplies, even if its aggregate turnover exceeds the ₹5 crore threshold.

This is because:

  • Exempt suppliers issue a Bill of Supply, not a Tax Invoice.
  • Bills of Supply are not covered under e-invoicing rules.
  • Only taxable B2B, B2G, export invoices, and taxable credit/debit notes require IRN.

Example: A hospital with ₹12 crore exempt turnover does not require e-invoicing.

When a business makes both taxable and exempt supplies, e‑invoicing applicability is based entirely on its PAN-level aggregate turnover. If this PAN-wide turnover crosses the notified threshold (₹5 crore), then e‑invoicing becomes mandatory — but only for taxable supplies. Exempt supplies always continue under a Bill of Supply and never require IRN.

Rule: Taxable B2B, B2G, and export invoices require IRN. Exempt invoices do not require IRN under any circumstances, even if turnover is high.

Taxable + Exempt Example

ABC Pvt Ltd — Taxable ₹2 Cr, Exempt ₹8 Cr, Total ₹10 Cr → E-invoicing applies only to taxable invoices.

Supply TypeDocumentIRN?
B2BTax Invoice✔
B2GTax Invoice✔
ExportTax Invoice✔
ExemptBill of Supply✖
B2CTax Invoice✖

FAQs

Q: Is e-Invoicing mandatory for exports?
A: Yes, all export invoices require IRN + QR code.

Q: Does e-invoicing apply to B2C invoices?
A: No. Only B2B, B2G, and exports.

Q: What turnover is considered?
A: “Aggregate turnover” is PAN-based — including exempt supplies, branches, and all GSTINs under the PAN.

Q: Is IRN needed for delivery challans?
A: No. Only invoices, credit notes, and debit notes.

Q: Once applicable, can the business opt-out later?
A: No. Once applicable, always applicable.

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