E-Invoicing Coverage and the 30-Day IRP Reporting Limit: Two Different Tests
This article distinguishes the Rs 5 crore turnover test that decides whether a registered person must generate e-invoices from the Rs 10 crore test that triggers the portal's 30-day reporting restriction, and sets out practical controls. The position is stated as reviewed on 11 October 2026.
The two figures are routinely confused. A business with turnover between Rs 5 crore and Rs 10 crore must still obtain an Invoice Reference Number (IRN), yet is not currently subject to the 30-day block. A business above Rs 10 crore faces both. Systems, tax teams and audit files need to treat them as independent conditions.
Legal base and official documents
The obligation rests on Section 31 of the CGST Act, 2017 and Rule 48(4) of the CGST Rules, 2017. Notification No. 13/2020-Central Tax dated 21 March 2020, as amended, identifies the registered persons covered. Notification No. 10/2023-Central Tax dated 10 May 2023 reduced the threshold to aggregate turnover exceeding Rs 5 crore, effective 1 August 2023.
The 30-day limit is different in nature. It is an operational control introduced through a GSTN advisory dated 5 November 2024 and reflected in IRP release notes dated 31 March 2025. It is not a section of the Act.
Situation 1: Deciding whether the Rs 5 crore threshold is crossed
Present position. The test looks at aggregate turnover in any preceding financial year from FY 2017-18 onward. A fall in current-year turnover does not by itself end the obligation.
How turnover is measured. Section 2(6) of the CGST Act includes taxable supplies, exempt supplies, exports and inter-State supplies of persons with the same PAN on an all-India basis. It excludes inward supplies on reverse charge and taxes. The assessment is PAN-wide, not per GSTIN or branch.
Boundary. Turnover of exactly Rs 5 crore does not "exceed" Rs 5 crore.
Action. Maintain a PAN-level turnover computation for each year since FY 2017-18, signed off by the tax function, and re-run it whenever a new registration is added.