GST E-Invoicing Update October 2026: RCM Self-Invoice Rules

The GST portal has announced an e-invoicing facility for recipient-generated self-invoices under the Reverse Charge Mechanism (RCM), covering domestic supplies from unregistered persons and imports of services. The update was listed on 16 October 2026.

What is the latest GST e-invoicing update?

The new facility relates to two categories:

• RCMDOM: Recipient-generated self-invoices for domestic supplies received from unregistered persons under RCM.

• RCMIMP: Recipient-generated self-invoices relating to imports of services under RCM.

This is particularly relevant for businesses that regularly receive services or other supplies on which GST is payable under reverse charge.

Important: The introduction of a portal facility does not automatically mean that every RCM transaction requires an Invoice Reference Number (IRN). Businesses should confirm the applicable legal requirements, turnover criteria, transaction eligibility and effective date before changing their invoicing process.

What is a self-invoice under RCM?

Under the Reverse Charge Mechanism, the recipient is responsible for paying GST instead of the supplier in specified cases.

When a registered business receives a supply from an unregistered supplier and the applicable provisions require the recipient to issue an invoice, the recipient prepares a self-invoice.

For example, a business may receive a service from an unregistered service provider. If the transaction falls under RCM, the recipient must evaluate the invoicing and tax-payment requirements applicable to that supply.

A self-invoice and an e-invoice are not exactly the same thing:

• A self-invoice is an invoice issued by the recipient where the applicable GST provisions require it.

• An e-invoice involves reporting eligible invoice details to the Invoice Registration Portal (IRP) and obtaining an IRN and signed QR code, as applicable.

Who should pay attention to this update?

The update is worth reviewing if your business or clients:

• Purchase goods or services from unregistered suppliers in transactions covered by RCM.

• Import services and account for GST under reverse charge.

• Have aggregate annual turnover of ₹5 crore or more and need to review e-invoicing applicability.

• Maintain a large volume of RCM invoices across multiple branches or GST registrations.

• Prepare GSTR-3B returns and reconcile RCM liability with accounting records.

The ₹5 crore turnover reference should not be treated as the only test for compliance. Confirm the precise scope and applicable conditions in the official advisory and relevant notifications.

What should GST practitioners check now?

Use this practical checklist before updating your client's compliance process.

1. Identify RCM transactions

Review the purchase register and expense ledgers to identify domestic purchases from unregistered persons and imports of services that may attract reverse charge.

2. Verify whether self-invoicing is required

Check the nature of each supply and the applicable provisions of the CGST Act and Rules. Do not assume that every purchase from an unregistered supplier attracts RCM.

3. Review e-invoicing applicability

Check the entity's aggregate turnover, applicable exclusions and the transaction categories covered by the latest GSTN facility.

4. Review the invoicing workflow

Confirm how self-invoices are prepared, approved, recorded in the accounting system and reported through the applicable portal process.

5. Reconcile RCM liability with GSTR-3B

Compare the RCM transactions recorded in the books with the liability reported in the relevant GSTR-3B tables. Investigate missing transactions, incorrect tax rates and differences in tax values.

6. Check input tax credit separately

Payment of GST under RCM does not automatically make the entire amount eligible for ITC. Verify the applicable ITC conditions, business use and restrictions before claiming credit.

7. Keep supporting documents

Maintain supplier details, contracts, invoices or self-invoices, tax calculations, payment evidence and reconciliation records to support the treatment adopted.

Common mistakes to avoid

• Treating every transaction with an unregistered supplier as an RCM transaction.

• Assuming that a self-invoice automatically requires IRN generation.

• Applying the ₹5 crore threshold without checking the relevant e-invoicing rules.

• Recording RCM liability without checking whether the corresponding ITC is eligible.

• Failing to reconcile RCM figures between the purchase register and GSTR-3B.

• Changing the accounting process based only on a portal announcement without reviewing the official advisory.

Where can you verify the official update?

For accurate compliance decisions, consult these resources:

• GST Self-Service Portal – GSTN advisories — look for the update dated 16 October 2026.

• Official GST portal — check the applicable e-invoicing and return-filing facilities.

• CBIC official website — verify the relevant Acts, Rules and notifications.

If the full advisory is temporarily unavailable, wait for the official text or seek clarification before relying on assumptions about the scope of the facility.

How can businesses prepare?

Businesses should review their RCM transaction records, identify applicable self-invoicing requirements and confirm whether their existing accounting or GST software can support the required workflow.

For tax professionals managing multiple clients, a standard RCM review process can help identify missed liabilities, inconsistent invoice records and potential ITC errors before return filing. GST compliance software such as SCIGST can also be considered as part of a broader workflow for managing GST records and reconciliation.