E-Invoicing System – GSTN releases API Specs and FAQs
Proposed e-invoicing system – Key documents released by GSTN
The Government had recently issued notifications notifying 1 April 2020 as the date of implementation of e-invoicing system for B2B transactions for businesses with aggregate turnover exceeding INR 1bn.
• Considering that the voluntary system would commence from 1 January 2020, the GSTN has also released1 the following documents in public domain:
• Presentations made by GSTN team in various workshops across India.
• Additional and updated FAQs on the e-invoice concept, flow and schema.
• List of application program interfaces (APIs) and the proposed methodology of interaction with the Invoice Registration Portal (IRP).
• General JavaScript Object Notation (JSON) sample of e-invoice payload sent to IRP.
• JSON schema for e-invoice.
Key highlights
Below are the key highlights of the documents shared by the GSTN:
• API Specs released: National Informatics Centre (NIC) has stated that there would be 6 different APIs. It has currently released specs for critical APIs (such as Generation). These are relevant to understand technically what all information will be required to be shared with IRP as well as the response expected to be received from IRP. Basis the review, it appears that there is further refinement in the mandatory fields required to be sent to IRP for generation of Invoice Reference Number (IRN).
• IRN Requirement: In addition to the tax invoice, IRN required for credit note, debit note, exports, Input Service Distributor (ISD) invoice, ISD credit note. This appears in contradiction to the notification recently issued, where IRN requirement was prescribed only for tax invoice.
• Document type for which IRN is not required: Documents which don’t have tax component i.e. Bill of Supply and Delivery Challan.
• IRN for B2C transactions: Not required – It has been provided that this may be allowed in long run. Hence, it appears that such option may not be available to start with. Even the API specs don’t currently include B2C transactions as transaction type, but they do include B2G (Business to Government transaction). Earlier, it was stated that generation of IRN for B2C would be optional but that doesn’t seem to be the case now.
• Printing of IRN on invoice: There are contradictory comments on whether IRN or the QR code generated by IRP is required to be printed on the invoice. This is a critical issue and currently on reading the notification it appears that IRN needs to be printed on the invoice. It is important that this aspect is explicitly clarified as it could have an impact on the IT related changes which the companies may have to undertake.
• Printing of invoice: Its being evaluated whether printing of invoice has been done away with even for the purpose of movement of goods.
• Signing of invoice by supplier: Present status remains.
• Generation of IRN: Only by IRP. There would be multiple IRPs from April 2020. Earlier the concept note provided that even a seller could generate an IRN.
• Length of IRN and parameters: It needs to be a 64 digits string based on SHA256 algorithm. It needs to be generated basis the document type (which was earlier not included), document number, seller GSTIN and financial year.
• Number of line items allowed on an invoice: An increase to 10,000 per invoice from earlier proposed 250 lines.
• Checks to be undertaken by IRP: It will undertake GSTIN validity check of seller and buyer as well as de-duplication check of invoice. Earlier only duplication check was provided.
• Email of JSON by IRP: IRP will not email any JSON e-invoice to seller or buyer directly. Earlier this was only proposed.
• Integration with IRP: In addition to GSP route, GSTN would provide an option to taxpayers to directly integrate with IRP subject to certain conditions
December 2019
What’s New
News Flash
• Provision for e-commerce platform: Government could consider allowing e-commerce platform to undertake the e- invoice compliance on behalf of the vendors supplying goods from their platform. This could go a long way in facilitating compliances for small vendors undertaking business through such platforms.
PwC comments
The documents shared were the need of the hour especially the API specs as these are the basic documents required for undertaking any IT development to prepare for e-invoicing system. Also, FAQs do provide clarification on quite a few aspects.
There have been changes since the clarification, basis the industry feedback. All the stakeholders including the Government, GSTN, NIC are working on a tight deadline, hence things would continue to evolve as we move along.
It is imperative for businesses to analyse such FAQs and undertake an impact analysis on how such e-invoicing system would impact transactions, IT systems as well as processes. Another key decision which needs to be taken is the manner of integration/ changes required in ERP systems for such change.
This development reiterates the Government’s endeavor to introduce mandatory e-invoicing system from 1 April 2020 onwards. Being a major business change, industry should start preparing on immediate basis to be ready in-time to meet the 1 April 2020 deadline.
1 https://www.gstn.org/e-invoice/
If your interest lies in a specific area or subject, do advise us so we can send you only the relevant alerts. For any additional information, please reach out to your PwC relationship manager or write in to
With Best Regards PwC TRS Team
About PwC
At PwC, our purpose is to build trust in society and solve important problems. We’re a network of firms in 157 countries with over 276,000 people who are committed to delivering quality in assurance, advisory and tax services. Find out more and tell us what matters to you by visiting us at www.pwc.com.
In India, PwC has offices in these cities: Ahmedabad, Bengaluru, Bhopal, Chennai, Delhi NCR, Hyderabad, Kolkata, Mumbai, Pune and Raipur. For more information about PwC India’s service offerings, visit www.pwc.in
PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details.
©2019 PwC. All rights reserved
Follow us on Facebook, Linkedin, Twitter and YouTube.
© 2019 PricewaterhouseCoopers Private Limited. All rights reserved. In this document, “PwC” refers to PricewaterhouseCoopers Private Limited (a limited liability company in India having Corporate Identity Number or CIN : U74140WB1983PTC036093), which is a member firm of
PricewaterhouseCoopers International Limited (PwCIL), each member firm of which is a separate legal entity.
Our Tax & Regulatory ServicesDirect Tax Indirect Tax Transfer Pricing Regulatory M & A Tax Controversy and Dispute Resolution Financial Services
NOTE : If you w ish to unsubscribe receiving communications, please send in a blank email as reply to this mail w ith subject line
"Unsubscribe".
