India: e-invoicing selectively mandatory from 1 April 2020

The Indian government has notified the implementation of e-invoicing under the GST law to specified class of persons with effect form 1 April 2020.

Companies with turnover above INR 1 billion (~USD 14 million) are to undertake e-invoicing. Registered persons with aggregate turnover in a financial year exceeding INR 1 billion must undertake e-invoicing with respect to supply of goods or services or both to a registered person (i.e. B2B supplies) from 1 April 2020.

According to the information put out by the Indian government, businesses should undertake the following activities to ensure that they are ready for e-invoicing on the go-live on 1 April 2020:

• Change in business processes to ensure timely and effective compliance with the e-invoicing procedure;
• Changes in ERP system to be implemented in the required technology for e-invoicing;
• Business evaluation to understand the impact - e.g. Identifying vendors who would issue e-invoice with effect from 1 April 2020 to ensure corresponding input tax credit is not affected;
• Employee training and customer/vendor communications to keep them abreast of the impact on the entire business cycle due to these changes.

Registered persons with aggregate turnover in a financial year exceeding INR 5 billion are required to have a Quick Response (QR) code on their invoices issued to an unregistered person i.e. (B2C invoices) with effect from 1 April 2020.

However, a registered person can make available a dynamic QR code through digital display by cross-referencing the payment made by the recipient. In such a case, the corresponding B2C invoice containing such cross-referencing shall be deemed to be having a QR code.