Regulatory updates - India

Based on the advisory, the e-invoicing system will introduce functionality for reporting recipient-generated self-invoices under the reverse charge mechanism (RSM). To support this reporting, two new supply types have been introduced:

1. RCMDOM: Reverse charge mechanism for domestic supplies received from unregistered persons, where the recipient generates the self-invoices and is liable to pay tax under RCM.
2. RCMIMP: Reverse charge mechanism for imports of services from suppliers located outside of India, where the recipient generates the self-invoices and is liable to pay tax under RCM.

Under these amendments, registered recipients with aggregate annual turnover (AATO) of Rs. 5 crore or more can report self-invoices for RCM transactions through authorized Invoice Registration Portals (IRPs), using the applicable supply type code RCMDOM or RCMIMP. After successful submission and validation of the e-invoice, an Invoice Reference Number (IRN) will be assigned.

The changes are ready for testing in the sandbox environments of all six authorized IRPs. Their implementation is consistent across all six environments, and the production date will be announced later. The technical requirements are also available under the National Informatics Centre (NIC) Rease Notes. 

The above changes will take effect on January 1, 2027, in accordance with the Notification No. 04/2026- Central Tax.

The proposed changes concerned:

• Introducing and making 'Ship-to GSTIN' field mandatory in Bill-to/Ship-to and Combination transactions when generating an EWB.
• Allowing usage of “URP” value in the Ship-to GSTIN field, if the delivery is done to an unregistered entity, e.g., customer or warehouse.
• Introducing an optional EWB closure facility in the portal, aiming to allow suppliers, recipients, transporters and authorized entities to mark an EWB as closed following delivery of goods.

Until further notice, taxpayers and service providers should not implement the previously proposed changes. No production environment updates are required, and all previously published advisories and FAQs will be removed from the GST Portal.

Amendments to the e-way bill (EWB) system have been introduced via the GSTIN portal, as announced in the official advisory. To clarify the new requirements, GSTN issued two FAQs in July 2026 covering the mandatory capture of the Ship-to GSTIN in certain e-way bill scenarios and the voluntary introduction of the e-way bill closure facility.

The main changes are as follows:

• Introducing and making 'Ship-to GSTIN' field mandatory in Bill-to/Ship-to and Combination transactions when generating an EWB. The portal will not accept EWB if that field is missing in these scenarios.
• Allowing usage of “URP” value in the Ship-to GSTIN field, if the delivery is done to an unregistered entity, e.g., customer or warehouse.
• Introducing an optional EWB closure facility in the portal, aiming to allow suppliers, recipients, transporters and authorized entities to mark an EWB as closed following delivery of goods.

Detailed applicability for various flows

1. Generating IRN and e-way bill together: When the EWB is generated along with the IRN number, the Gstin field should be made conditionally mandatory wherever Ship-to details are provided. In addition, where the e-invoice schema includes Ship-to Legal Name and Ship-to Address, and EWB generation is required, Ship-to GSTIN must be provided.
2. Generating e-way bill using IRN: In the API used to generate EWB by using IRN, a new mandatory field “Gstin” has been added under “ExpShipDtls”, and an optional field “Ship to Trade Name” for the Trade Name has been made available.
3. In Bill-to/Ship-to transactions: If a GSTIN is entered in the Ship-to GSTIN field, the system will validate it and accept it only when it’s correct. Moreover, the GSTIN entered in the Ship-to GSTIN field cannot match the GSTIN entered in the Bill-to field, since distinct persons must be involved in such transactions.
4. Using “URP”: If the Ship-to GSTIN is unavailable, e.g., if the Ship-to party is unregistered or GSTIN does not apply to the transaction scenario, the value “URP” can be entered instead.
5. Export e-waybill transactions: For export EWB, ship details, including the GSTIN entered during IRN generation, can be replaced when creating the EWB using IRN. In export cases where no domestic registered Ship-to GSTIN applies, “URP” can be entered in the Ship-to GSTIN field.
6. B2B and SEZ Transactions: For B2B and SEZ transactions, the Ship details entered during IRN generation cannot be replaced when creating the EWB using IRN. If GSTIN was not provided during IRN generation, it can be added while generating the EWB by IRN, subject to the applicable validations. For older IRNs generated with the same GSTIN as Bill-To and Ship-To, the EWB by IRN API will generate a regular EWB.

Updates to the e-Invoice API, EWB by IRN API, and EWB Closure API are now available in the Sandbox environment.

Taxpayers have time until August 1, 2026, to align their systems with the proposed amendments before go-live.