Update as of 7 November 2026: Notification No. 04/2026–Central Tax gives this change a 1 January 2027 commencement date. GSTN has announced test facilities for the new recipient-generated e-invoice categories and said it will communicate the production rollout separately. Treat the law’s commencement and the portal’s technical rollout as separate milestones; check subsequent official advisories before reporting live documents.
A GST e-invoice normally starts with the seller. This change brings two recipient-side cases into the e-invoice framework: certain domestic purchases from unregistered suppliers on which the buyer pays GST under reverse charge, and imports of services. For a business already within the e-invoice mandate, that means checking purchase-side workflows as well as sales invoices.
Notification No. 04/2026–Central Tax, dated 26 October 2026, amends the class-of-persons notification under rule 48(4), Notification No. 13/2020–Central Tax. It takes effect on 1 January 2027. The 57th GST Council press release had recommended this expansion in October; the subsequent Gazette publication of the October 2026 GST notifications is the legal text to consult.
The change at a glance
| Point | What to check |
|---|---|
| Start date | 1 January 2027 under Notification 04/2026–Central Tax. |
| Covered receipts | Domestic supplies from unregistered persons where the recipient owes GST under RCM, and imports of services. |
| Taxpayer test | The existing e-invoice mandate under Notification 13/2020, as amended; verify aggregate turnover and exclusions. |
| New portal categories | RCMDOM for eligible domestic RCM self-invoices and RCMIMP for import-of-services documents in GSTN’s announced design. |
| System status | GSTN announced sandbox testing; follow its next advisory for the production process and reporting date. |
The existing B2B supply and export limbs remain. The change adds recipient-side documents to the specified transactions for eligible persons; it does not make every purchase from an unregistered seller subject to reverse charge.
Who needs to assess the ₹5 crore threshold?
Notification 13/2020 originally applied where a registered person’s aggregate turnover exceeds the notified amount in any financial year from 2017–18 onward, subject to its exclusions. Notification No. 10/2023–Central Tax substituted ₹5 crore from 1 August 2023. The Council’s October 2026 communication describes the proposal as applying to taxpayers with aggregate annual turnover of “Rs. 5 crore and above.” For a business at exactly ₹5 crore, check the operative notification’s “exceeds” wording and later amendments instead of relying on the shorthand in a press release.
Aggregate turnover is a taxpayer-level measure across registrations under the same PAN, rather than a test of one branch’s RCM spend. Check historical turnover and whether your entity falls within a notified exclusion. A recipient below the e-invoice threshold may still have ordinary RCM, self-invoicing, tax-payment and return obligations; the new e-invoice scope does not create the underlying tax charge.
Which domestic purchases are in scope?
The domestic limb concerns a supply received from an unregistered person for which the registered recipient is liable to pay GST on reverse charge. Both facts matter. First identify a valid RCM entry under the applicable GST law and rate notification. Then confirm the supplier’s registration status and whether you must issue a recipient-generated self-invoice.
For example, if a notified category of taxable service is supplied by an unregistered person and the recipient is liable under RCM, a covered recipient should prepare to report the self-invoice through the new RCMDOM route. This is an illustration, not a conclusion that all unregistered professional fees, rent or other purchases attract RCM. If a supplier is registered, or the receipt does not attract RCM, do not place it in this category simply because the buyer accounts for a purchase.
A supplier’s commercial bill, a recipient’s self-invoice and the invoice reference number (IRN) serve different purposes. Preserve the source bill and contractual evidence, generate the legally required recipient document, and build the IRP submission from that document once GSTN makes the live workflow available. An IRN is obtained from an authorised Invoice Registration Portal; it is not a new PDF invoice written by the portal.
What about services bought from outside India?
The second new limb is import of services. Businesses paying a foreign vendor for taxable software subscriptions, consulting or other services should review whether the transaction meets the GST definition and tax rules for an import of services, and whether a recipient-side document is required. The announced portal category is RCMIMP. The scope is a legal question about the particular transaction; a foreign currency payment by itself is not enough to establish GST liability.
Imports of goods are different. Customs import documents and bills of entry have their own GST treatment. Do not label a shipment of goods as an RCMIMP service document. Likewise, assess an overseas related-party arrangement on its actual facts, including whether a taxable supply exists and whether an exemption or other rule applies.
Legal date and portal rollout: two separate checks
The notification states 1 January 2027 as its effective date. GSTN’s 16 October 2026 e-invoice advisory Official ↗ introduced the recipient-generated categories RCMDOM and RCMIMP and described testing in the sandbox on authorised IRPs. GSTN said the production rollout and reporting commencement would be communicated separately. The October Gazette also carries a companion schema change to FORM GST INV-01, aligned to the new categories from 1 January 2027.
As of this article’s 7 November 2026 update, do not describe sandbox access as proof that production submission is already live. Plan around the notified date, test now, and check GSTN, CBIC and your IRP for any later operational guidance. If technical rollout instructions differ from your assumptions, update the implementation plan promptly; do not infer a legal deferral from a pending technical advisory.
A practical preparation workflow
- Confirm eligibility. Review aggregate turnover since 2017–18, the current text of Notification 13/2020 and any notified exclusions for your entity or GSTIN.
- Map RCM purchases. List domestic unregistered supplier transactions that actually attract reverse charge. Capture supplier identity, place of supply, taxable value, tax rate, document date and the legal basis for RCM.
- Separate foreign services from goods. Review overseas service contracts and invoices, and exclude customs bills of entry from the RCMIMP queue.
- Configure recipient documents. Give domestic RCM and imports separate document series or transaction types where your software needs them. Prevent duplicate IRNs when a self-invoice is corrected or retried.
- Test the IRP schema. Ask your ERP vendor or service provider to test RCMDOM and RCMIMP in an authorised sandbox. Validate party fields, GSTIN, document number, tax and error handling against the latest GSTN specification.
- Reconcile monthly. Match source bills, recipient documents, IRN acknowledgements, RCM liability, tax payment and eligible input tax credit. Check the then-current return guidance before assuming where new recipient documents will auto-populate.
- Assign an owner. Have one person track later GSTN advisories, production access, effective reporting instructions and internal training before the January change.
Self-invoice timing is a separate rule. Rule 47A, introduced through Notification No. 20/2024–Central Tax , addresses the time for issuing a recipient self-invoice for specified section 31(3)(f) cases. Do not confuse that document-issue period with any separate IRP reporting limit; verify the applicable rule and current portal instructions for each transaction.
Common mistakes to avoid
- Treating every purchase from an unregistered person as RCM. The underlying RCM provision must first apply.
- Applying RCMIMP to imported goods. It concerns services, not a bill of entry.
- Looking only at the turnover of the GSTIN making the purchase. Review the applicable aggregate-turnover rule and historical years.
- Assuming the live IRP already accepts these categories because they appear in a sandbox advisory.
- Assuming that generating an IRN settles RCM tax, input tax credit or return reporting. Those obligations still require separate checks.
Official sources and next check
Read Notification 04/2026 and the companion October Gazette changes , the principal e-invoice notification , the ₹5 crore amendment , the GST Council’s recommendation and the GSTN advisory Official ↗. Recheck the latest notifications and portal instructions before your first January submission.
