GST Form ENR-03: E-Way Bill Enrollment for Unregistered Dealers

An e-way bill allows tracking of the movement of intra and inter-state supply of goods. However, until recently, registration at the e-Way bill portal required suppliers’ or recipients’ GSTIN. The responsibility for GST compliance during the transportation of supplied goods was with the recipient GST holder if the supplier was unregistered. The introduction of Form ENR-03 changes this practice for better accountability of unregistered suppliers, transparency and improved compliance.

This article discusses everything you need to know about form GST ENR-03 and how to generate an e-way bill without GSTIN. 

What is Form GST ENR-03?

Form ENR-03 is an online feature introduced in the e-way bill (EWB) portal from 11th February 2025. The intended use of this form is to allow GST unregistered persons (URPs) to enrol themselves in the e-way bill system and create an enrolment number. This enrolment number is then used to generate e-way bills while URPs transporting, moving or supplying goods above the value of Rs.50,000. Earlier, unregistered persons were needed to mention either suppliers’ or recipients’ GSTIN to generate e-way bills. 

Advisory on the introduction of form ENR-03

GSTIN holders were notified of the new feature through an advisory on 15th February 2025. As per this advisory note, form ENR-03 has been launched in accordance with Notification No. 12/2024 dated 10th July 2024. This notification declared the insertion of a legal provision under Rule 138(3) of the CGST Act 2017 to allow URPs willing to generate EWB to register themselves in the EWB portal without GSTIN. 

According to the notification, URPs can do so online directly or through facilitation centres by submitting details, like PAN, contact, and address, in the FORM GST ENR—03. The GST Network rolled out this feature on 11th February 2025. 

Eligibility for unregistered dealers to use the form

Any person or entity who is not registered in the GST system but intends to transport or move goods above Rs.50,000 valuation is eligible to use form ENR-03 for generating an enrolment number. This number is then used to generate e-way bills instead of using recipients’ GSTIN. 

Step-by-Step process to register using form ENR-03 

URPs opting to generate e-way bills for their supplies need to register themselves in the EWB portal. We have listed the steps to follow to register URPs to the portal. 

Step 1: Go to https://ewaybillgst.gov.in/. Navigate to the section Registration> Enrolment for URP. Click the ‘Enrolment for URP’ section. 

Step 2 -  Once you click the ‘Enrolment for URP’ section, a new page opens containing the application form for enrolment of URPs (ENR-03). 

Step 3 - Select the State your business is based in, trade name and the PAN card number. You must mention the trade name (mention your name in case you do not have any separate trade name for your business) as it is in the PAN card. Click the ‘Validate’ button to verify the name with the PAN number you mentioned. If the name does not match with the PAN, the system will generate the following error message. In that case, you need to go back to Step-1 and restart the process.   

Step 4 - Once validated the PAN, you need to choose the ‘Type of enrollment’ depending on the type of your business. If you are moving the goods as an unregistered purchaser, you can choose ‘Unregistered Recipient of Goods’. Anyone moving goods as a URP supplier needs to select ‘Unregistered Supplier of Goods’. In case you are a URP dealer engaged in both supplying and receiving goods, choose the option ‘Both 1&2’. 

Step 5 - At this stage, you need to fill out your principal place of business and contact details, along with email ID and verified mobile number. The mobile number verification is done through the system-generated one time password (OTP).  

Step 6 - Once verified the mobile number, you need to create a username and password. This username and password will be required to log into the EWB portal for generating e-way bills. Finally, click the self-declaration checkbox at the end of the form, enter the Captcha and save the form. 

Step 7 - Upon submitting the form ENR-03, the EWB portal acknowledges the submission and generates the 15-digit enrolment ID for URPs. As a URP, you need to use this enrolment ID in place of the supplier’s or recipient’s GSTIN while generating an e-way bill in the future. 

Generating e-way bills after ENR-03 enrolment 

The purpose of the ENR-03 enrolment ID is to generate e-way bills without requiring to mention the supplier’s or recipient’s GSTIN. So, let us understand how to generate e-way bills without GSTIN. 

• Step 1 - Log into https://ewaybillgst.gov.in/ using the username and password you have created as a URP. 
• Step 2 - Navigate e-Waybill>Generate New through the main Menu. Click ‘Generate New’
• Step 3 - The page containing the E-Way bill entry form appears on the screen. The EWB system auto-populates the e-way bill entry form with the URP-specific 15-digit enrolment number.  
• Step 4 - Fill out details related to ‘Transaction Type’, ‘Document type’, ‘Item Details’ and ‘Transporter Details’. Click ‘Submit’ once done filling out all the mandatory fields in the E-Way bill entry form. 

If all the details submitted by the URP (as the unregistered dealer) are valid, the system generates an E-Way bill in the EWB-01 form along with a unique 12-digit E-Way bill number. 

Key considerations for unregistered dealers

The newly introduced GST Form ENR-03 feature in the EWB portal offers several benefits for both unregistered dealers and GSTIN holders doing business with them. 

• This makes generating new e-way bills easier for URPs as such dealers no longer require GST registration. 
• Goods being transported from URPs become well-documented in compliance with GST rules and regulations. Earlier, unregistered dealers used recipients’ GSTINs to move goods. It caused accountability issues as recipients were made responsible for lapses made by unregistered dealers.  
• It becomes easier for smaller traders to move goods in compliance with GST rules and regulations and avoid disruptions in the supply chain. 

However, it becomes essential for unregistered dealers to consider a few factors while opting to register in the EWB portal as URPs. 

1. Mention the correct PAN which you are using for doing business. 
2. Fill out the address of your principal place of business, which you mentioned in your PAN application. 
3. Select the ‘Type of enrolment’ correctly as applicable to your business. 
4. The new feature makes URPs accountable for any lapses or compliance issues in the transportation of goods. So, fill out details accurately while generating new bills. Cross-check before submission of the E-Way Bill Entry Form to avoid any incorrect data in the e-way bill record. 
5. Maintain all the records related to the supply of goods using Enrolment ID for future reference. Such documents will be necessary in case of any compliance proceedings.