India’s Invoicing Mandate Background
The Indian government announced its invoice registration mandate late 2019, putting forward a very challenging go-live date of 1 April 2020. You can read the full back story here.
As Tungsten Network was preparing to be ready by 1 April, we have been following the developments around the mandate very closely, including recent updates, when the APIs and mandatory fields were changed significantly.
Just two weeks before the anticipated go-live for the first group of taxpayers, the Indian government decided to postpone the effective date of the mandate until 1 October 2020. This decision was taken at the 39th GST Council Meeting on Saturday, 14 March.
What’s the Latest News in 2020?
There are no indications that the Indian Government is planning to delay the invoice reporting mandate that is to go live on 1 October 2020. The GST Council is scheduled to meet on 19 September, which will most likely provide final clarity on the exact implementation date. However, there has been quite some activity; the CIBC (Central Board of Indirect Taxes and Customs) released two recent notifications: (No.60/2020) with an update to the JSON schema and (No.61/2020) with a change in the scope of the mandate. The most recent version of the JSON schema; version 1.1 is quite different from the previous version.
We already wrote about the change in scope; the revenue threshold for the October roll-out is Rs. 500 Cr or more. There are quite some exceptions; the mandate does not (yet) apply to a variety of financial services and other services. Also, Special Economic Zones units (SEZ). Note: voluntary adoption of e-invoicing for businesses that fall outside of the mandate scope is not available until further notice.
Again, so far there has been no indication that the government will further delay the mandate. It is also expected that a new deadline will be published for tax payers that were part of the original April scope (with aggregated revenues between Rs.100Cr and Rs. 500Cr).
While we see companies getting ready for the mandate by 1 October, we also see that companies are counting on further delay. It is a very risky strategy and may leave you badly exposed if the Government sticks to the plan. We highly encourage you to take action now.