Understanding The Time Limit for Reporting e-Invoices on the IRP Portal

e-Invoices must be generated within a notified e invoice generation time limit of 30 days from the invoice date. The time limit for e invoice was earlier set as seven days, but the government deferred the implementation by three months. The law currently applies to only some notified taxpayers. The restriction compels businesses to adopt real-time invoicing. Read on to get complete details.

What is the e invoice time limit?

The time limit to generate e invoice on the Invoice Registration Portal (IRP) for all tax invoices and credit-debit notes issued is within thirty days from the date given in the invoice and debit note or credit note. For instance, if an invoice is dated 2nd November 2023, the team must report it by 1st December 2023 on the IRP.

The GST Network (GSTN) released advisories on 12th April 2023, 13th April 2023 and later on 13th September 2023 on the government portal. It has notified that some taxpayers must report invoices and credit-debit notes on the Invoice Registration Portals (IRP).

When will the e-invoicing time limit rule apply?

The IRPs/e-invoice portals will begin validating the time limit from 1st November 2023 onwards. Earlier, the implementation date was set as 1st May 2023.

Who must comply with the e-invoicing time limit?

All taxpayer businesses with an Annual Aggregate Turnover (AATO) of Rs.100 crore or more must comply with the time limit defined by the GSTN. The time limit of thirty days applies to reporting tax invoices, credit notes and debit notes to any notified IRP, including any old documents unreported as on 1st November 2023.

 However, the rule or validation does not apply to taxpayers whose AATO is less than INR 100 crore.

The legal status of the e-invoicing time limit

Regarding e invoice time limit latest notification, the GST law does not fix any time limit for taxpayers to report documents on the e-invoice portals or IRP for e-invoice generation. By default, the GST provisions on the time of supply and time limit to raise invoices would apply to any taxpayer. Whereas the restriction on the time limit of thirty days to report documents on IRP is put by the GST Network/system.

Consequences of not adhering to the e-invoicing time limit

The IRP has in-built validation only to accept tax invoices, credit, and debit notes within thirty days. Such taxpayers cannot generate e-invoices and will be considered non-compliant under the GST law. 

• If the team misses the 30-day window for e-invoicing, they must once again raise the invoice and report it to IRP. It delays reporting or auto-population of e-invoices in GSTR-1.
• It affects the flow of input tax credits along the supply chain due to the delay. In turn, it hurts customer relations.
• The GST law imposes a huge penalty as follows-
  • For incorrect invoicing – Rs.25,000 per invoice (for the issue of the invoice that lacks IRN and signed QR code). 
  • For non-generation of e-invoice – 100% of the tax due or Rs.10,000, whichever is higher, for every invoice. (where the invoice is not issued)

Impact on businesses 

The move affects many large Indian enterprises pushing their teams to change their ERP and billing processes significantly. Applicable taxpayers must take the following steps to meet the new requirement-

• Get ERPs/billing systems modified/reconfigured to add the time limit validation for tax invoices and credit-debit notes raised to get timely prompts/alerts for e-invoicing. 
• Build awareness among teams about the new system update and the time limit.
• Ensure a real-time or daily reconciliation between the sales register and e-invoices to never miss out on reporting any invoice or note. 
• Retract from siloed or isolated tax solutions and minimise manual handshakes between teams and finance functions.
• Switch to a connected finance ecosystem as that allows finance teams to-
  • Automate redundant compliance tasks at source when the invoice or note is raised.
  • Instantly generate e-invoices and e-way bills.
  • Enjoy the auto-flow of sales data into the e-invoicing and GST solution for end-to-end compliance.

How Clear can help?

Due to the challenges posed by the new restriction, it is more crucial than ever to have e-Invoicing and GST solutions from the same vendor or platform or cloud-based solution. Don’t go anywhere! Auto-manage e-invoicing, e-way bill, GSTR-1 and GSTR-3B filing through Clear’s cloud-based technological solution, the Compliance Cloud. 

The Clear e-Invoicing and Clear GST solutions can assist you as follows-

• We are the official IRP approved by the GSTN network in India. 
• Enable an autoflow of invoice data for an on-demand reconciliation and up-to-date sales register.
• Secure always-on compliance with NIC and Clear IRP backup.
• Generate e-Invoices in any 50+ template options within 200 ms versus the market average of 3 sec. 
• Allows easy and automated reconciliation of e-invoices with sales register and provides MIS reports for actions.

So, hop onto Clear Compliance Cloud, our integrated platform, and generate compliant e-invoices in bulk with automatic dataflow into GST for GSTR-1 and GSTR-3B filing.