This post covers the practical side: the two 30-day periods, ITC risk, exclusions and open questions. For the basics of GSTN Advisory 678 and the RCMDOM and RCMIMP supply types, read our GSTN Advisory 678 explainer first.
Who is covered
- Registered persons already within e-invoicing: aggregate turnover above ₹5 crore in any financial year from 2017-18 onwards, tested on an all-India basis for all registrations under one PAN.
- The notification keeps the word “exceeds” from the earlier notification. Some summaries say “₹5 crore and above”, so if your turnover is exactly ₹5 crore, check the notification text.
- Existing exclusions continue, such as government departments, local authorities, SEZ units, and the categories listed in Rule 54(2) to (4A). On a plain reading, they stay excluded for the new inward supplies as well.
- A business outside e-invoicing today does not come in through this change.
Which transactions are covered
| Transaction | Position from 1 January 2027 |
|---|---|
| Services from an unregistered supplier, where you pay tax under reverse charge (for example, legal services from an individual advocate) | Self-invoice must be an e-invoice (supply type RCMDOM) |
| The same service from a registered advocate or firm | The supplier issues the invoice. You have nothing to report under this change. |
| Software or cloud subscription from a vendor outside India | E-invoice needed (supply type RCMIMP) |
| Purchase from an unregistered supplier with no reverse charge liability | No self-invoice, so no change |
| Import of goods | Not covered. It is cleared on a bill of entry. |
The two 30-day periods
Two different 30-day limits apply, and they come from different places.
- Rule 47A (the law): you must issue the self-invoice within 30 days of receiving the goods or services. This applies to everyone liable under section 9(3) or 9(4), whether or not it is an e-invoice.
- The portal rule (GSTN advisories): the IRP does not accept an e-invoice older than 30 days for taxpayers with turnover of ₹10 crore or more. Taxpayers below ₹10 crore are not subject to it at present. It is a portal validation, not a provision of the Act or Rules.
It is not yet clear whether the portal restriction will apply to RCMDOM and RCMIMP documents. The safest course is to assume it will, and to treat the Rule 47A date as your working deadline.
ITC risk and other consequences
- Tax is still payable. Reverse charge tax is paid in cash whether or not an IRN has been generated.
- Rule 48(5): an invoice issued by a covered person otherwise than through the portal is not treated as an invoice.
- ITC: you claim credit on reverse charge supplies on the strength of your own self-invoice, after paying the tax. If that document is not an invoice for want of an IRN, the credit can be questioned. The notification gives no transitional relief. A taxpayer who has paid the tax and holds the self-invoice and payment voucher would have an argument that credit should still be allowed, but that is not a settled position.
- Payment voucher: the separate payment voucher under section 31(3)(g) is not affected by this change.
Questions still open
- Whether the rule applies by date of receipt or date of the self-invoice, for supplies received just before 1 January 2027.
- How consolidated month-end self-invoices for low-value purchases will be reported.
- Whether suppliers registered only for TDS are treated as unregistered for RCMDOM.
- How these e-invoices will flow into the monthly returns.
GSTN is expected to publish a release note with technical details. Check the official portal before acting.
Checklist before 1 January 2027
- Test your turnover against the threshold at PAN level, and check the exclusions.
- List every reverse charge purchase: unregistered suppliers and imports of services such as software, cloud tools and foreign professional fees.
- Record the date of receipt for each one, because Rule 47A counts from it.
- Ask your ERP or accounting vendor when RCMDOM and RCMIMP will be supported, and test in the sandbox.
- Issue self-invoices as you go, not at month end.
- Keep the payment voucher and proof of cash payment of tax for each self-invoice.
FAQs
Do I need to generate an IRN for an RCM self-invoice?
From 1 January 2027, yes, if you are within the e-invoicing class and the supply is received from an unregistered person under reverse charge, or is an import of services.
Is import of goods covered?
No. Only import of services is covered. Goods are cleared on a bill of entry.
What happens if I do not generate the IRN?
The tax is still payable. Under Rule 48(5) the self-invoice may not be treated as an invoice, which puts the ITC on that supply at risk.
What is the time limit to issue a self-invoice?
Rule 47A requires it within 30 days of receiving the goods or services. Taxpayers with turnover of ₹10 crore or more also face a 30-day limit on the portal.
Related reading: GSTN Advisory 678 explained | CGST Amendment Rules 2026 | our services.
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Based on Notification 04/2026-Central Tax (26 October 2026), Rule 47A, Rule 48 and GSTN advisories, as summarised in professional commentary. Details may change when GSTN issues its technical guidelines. Please check the official sources before acting. This post is for general information and is not tax or legal advice.