E-invoicing to cover reverse-charge purchases from unregistered persons and import of services
What changed. Notification No. 13/2020–Central Tax lists the transactions for which a business covered by e-invoicing must prepare its invoice through the Invoice Registration Portal (rule 48(4) of the CGST Rules). Until now it covered supplies to registered persons and exports. Notification No. 04/2026–Central Tax, issued on the GST Council's recommendation, adds two more categories:
- supplies received from an unregistered person where the recipient pays tax under reverse charge; and
- import of services.
The CGST (Amendment) Rules, 2026 (Notification No. 05/2026–Central Tax) separately add matching supply-type codes to FORM GST INV-01 from the same date: "RCMDOM" (domestic supply from an unregistered person under RCM) and "RCMIMP" (import of services).
Who it affects. Companies, LLPs and other businesses that are already required to issue e-invoices under Notification No. 13/2020–Central Tax and that buy from unregistered suppliers under reverse charge or import services.
From when. 1 January 2027.
What to do. - Identify your reverse-charge purchases from unregistered persons and your imports of services. - Check with your ERP or billing software provider that self-invoices for these transactions can be reported to the Invoice Registration Portal using the new codes. - Update internal procedures so that these documents are generated as e-invoices from 1 January 2027.
Official source: CBIC Notification No. 04/2026–Central Tax dated 26 October 2026
This is general information based on the law as on the date shown, not professional advice. Rules change often; check the current position before acting.