GST RCM and E-Invoicing in October 2026: Who Issues What?

Reverse charge and e-invoicing answer two different questions:

• Reverse charge mechanism (RCM) identifies who must pay GST for a notified supply.
• E-invoicing determines whether a supplier-issued invoice, credit note or debit note must be reported to an Invoice Registration Portal (IRP) to obtain an Invoice Reference Number (IRN) and signed QR code.

A supply attracting RCM is not automatically outside e-invoicing. The correct treatment depends on who issues the document, whether that person belongs to the notified e-invoice class, and the type of transaction.

October 2026 status: The official sources reviewed on 19 October 2026 did not identify a separate blanket October 2026 rule changing the basic RCM/e-invoice treatment described below. Businesses should nevertheless check current CBIC notifications and GST Portal advisories before acting.

Where a notified supplier makes a supply on which the recipient is liable to pay tax under reverse charge, the supplier still issues the tax invoice. If that supplier is covered by the e-invoice mandate and the document and transaction are within scope, the supplier reports it to an IRP and marks the reverse-charge field correctly.

The official e-invoice FAQ specifically states that e-invoicing applies to an invoice issued by a notified person for a supply attracting reverse charge under section 9(3). The recipient paying the tax under RCM does not, by itself, remove the supplier's e-invoice obligation.

Different rules may apply when a registered recipient receives a taxable supply from an unregistered supplier in a situation covered by reverse charge, or receives an imported service. Recipient-issued documentation may be required under the CGST Act and Rules, subject to the precise statutory conditions.

The e-invoice FAQ says e-invoicing does not arise for supplies received from an unregistered person or through import of services. IRP guidance also states that self-generated invoices are not accepted for e-invoice generation. Do not try to obtain an IRN merely because the recipient has prepared an RCM self-invoice.

Because section 9(4), notified categories and invoicing rules have changed over time, confirm that the transaction actually requires a recipient self-invoice before creating one.

An import of service generally requires the supplier to be located outside India, the recipient to be located in India and the place of supply to be in India. The precise result depends on the IGST Act, place-of-supply rules, exemptions and the facts of the arrangement.

For a taxable import of service for which the Indian recipient is liable under reverse charge:

• determine whether the transaction qualifies as an import of service and whether any exemption or special rule applies;
• identify the correct recipient GSTIN and place of supply;
• review the overseas agreement, invoice, nature of service, payment terms and foreign-currency conversion;
• determine the time of supply under the reverse-charge rules;
• prepare any recipient-issued invoice and payment voucher required by the current law;
• discharge the RCM liability through the electronic cash ledger; and
• review input-tax-credit eligibility only after the tax is paid and the documentary conditions are met.

GST Portal guidance states that reverse-charge credit on import of services is not included in GSTR-2B in the same manner as ordinary supplier-uploaded invoices. The taxpayer continues to report the relevant liability and eligible credit in the prescribed GSTR-3B fields. Portal table numbers and auto-population behaviour should be checked for the filing period.

Payments for overseas software subscriptions, cloud services, licences, consultancy, advertising, professional support and similar services should be reviewed individually. A foreign invoice or card payment does not by itself establish the GST treatment. Confirm the contracting entity, recipient, place of supply, business use, OIDAR implications and whether the foreign supplier has charged Indian GST under a special registration mechanism.

Services received from an overseas related person or establishment may require review even when no amount is remitted. Schedule I, valuation rules and the special time-of-supply rule for associated enterprises can affect the result. The CGST Act provides that, for an associated enterprise located outside India, the reverse-charge time of supply is linked to the earlier of the recipient's book entry and payment. Obtain professional advice before recording or filing such transactions.

Import of goods is different from import of services. IGST on imported goods is generally dealt with through the customs process. The Bill of Entry, customs assessment and payment evidence are central documents; the recipient should not create an e-invoice or use the import-of-services self-invoice workflow merely because IGST is payable on import.

GST Portal guidance explains that import-of-goods data is received from ICEGATE and may appear in GSTR-2B. CBIC's ITC rules recognise a Bill of Entry as a document on which eligible input tax credit may be based. If a Bill of Entry is missing or incorrect in portal data, reconcile it with ICEGATE/customs records instead of substituting a self-invoice.

Before claiming import IGST credit, review:

• importer identity and GSTIN linkage;
• Bill of Entry number, date, port code, assessable value and IGST paid;
• receipt and business use of the goods;
• blocked-credit and other eligibility restrictions;
• books, customs records and GSTR-2B reconciliation; and
• any amendment, refund, re-import, bonded-warehouse or SEZ-specific issue.

Online Information and Database Access or Retrieval services can follow special supplier-registration and tax-payment rules. Do not assume every overseas digital service is ordinary recipient-paid RCM. Determine whether the recipient is registered, whether the service meets the statutory OIDAR definition and whether the overseas supplier has charged GST under the applicable mechanism.

Other transactions—including employee reimbursements, intermediary arrangements, secondments, cross-charges, royalty or licence payments and bundled goods-and-services contracts—may require separate classification and valuation analysis.

As reflected in current official guidance, the e-invoice mandate generally applies where aggregate annual turnover under the PAN exceeded ₹5 crore in any relevant financial year from 2017-18 onward, subject to notified exclusions and transaction/document scope.

Important controls include:

Portal enablement alone does not prove that e-invoicing is legally applicable. Applicability must be determined from the notification and the taxpayer's facts.

Official IRP guidance states that, from 1 April 2025, taxpayers with aggregate annual turnover of ₹10 crore or more cannot report an invoice, debit note or credit note to the IRP more than 30 days after its document date. The portal may reject a document reported outside that window.

This restriction is not the general turnover threshold for e-invoicing. A taxpayer may be covered by e-invoicing at the ₹5 crore threshold while the 30-day restriction applies only at ₹10 crore or more. Check the current portal advisory before relying on either threshold.

Use a transaction-level review rather than one combined total:

• Assuming every RCM document needs an IRN.
• Assuming no RCM supply can require an e-invoice.
• Asking the recipient to generate an IRN for a self-invoice.
• Testing e-invoice applicability using only one GSTIN's turnover.
• Treating portal enablement as proof of legal applicability.
• Missing the 30-day IRP restriction for a ₹10 crore-plus taxpayer.
• Claiming ITC without reviewing eligibility, tax payment and documentation.
• Relying on an old RCM list, threshold or notification.

Start with the transaction and the document issuer. If an e-invoice-mandated supplier issues an invoice for a notified RCM supply, e-invoicing may apply even though the recipient pays the tax. Where the recipient must create prescribed RCM documentation for an unregistered-supplier or import-of-services case, that self-document is not reported to the IRP merely because it relates to RCM.

General-information disclaimer: This article is general educational information, not GST, tax or legal advice. RCM categories, exclusions, thresholds, forms, portal controls and effective dates may change. Verify current CBIC notifications and GST Portal advisories and obtain professional advice for the transaction before invoicing, paying tax, claiming ITC or filing a return.