Understanding India's Invoice Registration Portal (IRP) for GST Compliance
The Invoice Registration Portal (IRP) is a crucial component of India's Goods and Services Tax (GST) e-invoicing system, responsible for validating and assigning Invoice Reference Numbers (IRNs) to electronic invoices. This system ensures the authenticity and standardization of invoices for GST compliance. Recent updates have introduced turnover-based mandates and reporting deadlines, making it essential for businesses to understand IRP's functions and various registration methods. The portal streamlines e-way bill generation and GSTR-1 auto-population, enhancing efficiency in tax administration.
The Invoice Registration Portal (IRP) serves as a vital tool within the GST framework, ensuring the validity of invoices by generating and assigning a unique Invoice Reference Number (IRN) to each. The e-invoicing system's trial version was launched for voluntary use on January 1, 2020, with IRP playing a central role in its operation.
Recent Developments in E-invoicing
Over time, the government has progressively expanded the scope of e-invoicing:
- May 10, 2023: The Central Board of Indirect Taxes and Customs (CBIC) mandated e-invoicing for taxpayers with an annual turnover of ₹5 crore or more (in any financial year from 2017-18) starting August 1, 2023.
- May 6, 2023: The GST department temporarily suspended the seven-day deadline for reporting older e-invoices on IRP portals for three months, with a new implementation date yet to be announced.
- April 13, 2023: As per GST Network advisories, businesses with an annual turnover of ₹100 crore or more were required to report tax invoices and credit-debit notes to the IRP within seven days of the invoice date, effective May 1, 2023.
- October 11, 2022: The GST Council considered extending e-invoicing to businesses with over ₹5 crore annual turnover from January 1, 2023, and potentially to those above ₹1 crore by the end of the next fiscal year.
- August 1, 2022: E-invoicing for B2B transactions was extended to entities with an annual aggregate turnover between ₹10 crore and ₹20 crore, effective October 1, 2022, as per notification no. 17/2022.
- February 24, 2022: The e-invoicing mandate expanded to include businesses with an annual aggregate turnover ranging from ₹20 crore to ₹50 crore, effective April 1, 2022, through notification no. 1/2022.
What is the Invoice Registration Portal (IRP)?
Invoice Registration Portals (IRPs) function as official registrars, utilizing a dedicated website to issue Invoice Reference Numbers (IRNs) for every invoice, credit note, or debit note. Users can upload invoice details to the IRP using a specified method to either generate or validate the IRN within applicable timelines. Only documents bearing an authorized IRN are legally recognized. From May 1, 2023, businesses with an annual turnover of ₹100 crore or more must report invoices and credit/debit notes to the IRP within seven days of their issuance date. However, this seven-day reporting limit was temporarily deferred for three months starting May 6, 2023, with the new effective date still pending.
Currently, the National Informatics Centre (NIC) manages an operational IRP accessible at https://einvoice1.gst.gov.in/. The government has authorized additional IRP providers to facilitate e-invoicing.
Functions of the IRP
The IRP carries out several essential tasks:
- Generation of Hash/IRN for Invoices: If invoices are uploaded without a hash, the IRP creates a unique hash or IRN for the invoice based on predefined parameters.
- De-duplication Check: The IRP checks for any duplicate IRNs by comparing the generated hash with data stored in a central repository.
- Digital Signing of Validated Invoices: All verified invoices are digitally signed by the IRP using its private key, and this digitally signed JSON is then provided to the supplier.
- Generation of QR Codes for Validated Invoices: Each validated invoice receives a QR code along with its digital signature. Taxpayers can use this QR code to verify or print the invoice, enabling quick access on mobile devices. This feature assists tax officers and other stakeholders in verifying details even with limited or no internet access. The QR code contains the following information:
- Supplier's GSTIN
- Recipient's GSTIN
- Invoice number from the supplier
- Invoice generation date
- Invoice value (taxable value and gross tax)
- Number of line items
- HSN Code for the primary item (item with the highest taxable value)
- Unique Invoice Reference Number (hash)
- Sending Invoices via Email: The IRP transmits the validated invoice to the seller's registered email address.
- Offline Application: An offline app is provided by the IRP to authenticate QR codes and view basic invoice details without an internet connection. Full invoice details are available once connected to the portal.
- Integration with GST and E-way Bill Systems: Invoice details uploaded to the IRP are automatically shared with the GST system, leading to the automatic update of the seller's GSTR-1. These details are also shared with the e-way bill system, simplifying e-way bill generation by requiring only the vehicle number.
Time Limits for Reporting Documents to IRP
Prior to April 30, 2023, no specific deadline existed for generating e-invoices. However, from May 1, 2023, taxpayers with an Annual Aggregate Turnover (AATO) of INR 100 crore or more must generate e-invoices for tax invoices and credit-debit notes within seven days of the invoice/CDN date. Failure to comply renders such documents non-compliant.
For other applicable taxpayers, there is no fixed time limit for e-invoice generation. It is recommended that these taxpayers generate e-invoices on or after the invoice/CDN date, ideally a week before filing GSTR-1 returns, as it takes approximately three days for e-invoice details to auto-populate into GSTR-1.
It is important to note that the GST department temporarily deferred the seven-day reporting deadline for older e-invoices on IRP portals by three months, with a new implementation date yet to be announced.
E-invoice Generation on IRP
E-invoicing mandates a standardized format for electronically reporting invoice information. GST taxpayers must adhere to this prescribed format to ensure inter-system readability, allowing different systems to interpret the generated output. Following this format significantly automates the return filing process.
Therefore, the Invoice Registration Portal (IRP) is designed not for online invoice creation but solely for registering the details of invoices already generated by a business. These invoices should be prepared as a JSON file using an offline tool for uploading to the IRP. Enterprise Resource Planning (ERP) systems must be integrated with the e-invoice system, either directly via API or through GST Suvidha Providers (GSPs).
Methods for Registering Invoices with IRP
Several methods are available for registering invoices on the IRP:
- Web-based through Bulk Upload: Taxpayers can input invoice details into an Excel-based offline tool, which converts the data into a JSON file. This file can then be uploaded to the e-invoice website for registration and validation, leading to the generation of an IRN and a QR code.
- API based: This integration allows large taxpayers and accounting software providers to communicate directly with the Invoice Registration Portal using their own software. This requires registering their system's server details with the e-invoice system. IRNs can be generated and validated for individual invoices or in bulk, similar to the e-way bill system's API functionality. Integration prerequisites include an IT-enabled invoice generation system with a static IP address, a pre-production system for API testing, and an SSL-based domain name.
- Mobile App based: The IRP has proposed a mobile application available on app stores that provides some of the aforementioned IRP functionalities. Users must register the International Mobile Equipment Identity (IMEI) number of their mobile devices with the e-invoice system to generate IRNs.